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Nuvemco, LLC's Monogram Mine M-1978-222UG <br />Response to Preliminary Adequacy Review <br />March 10, 2009 <br />4.1 acres of exploration borehole drilling; sites approx. 30 x 20 ft = 600 sq ft each; 50 <br />boreholes per drilling phase = 30,000 sq ft/phase = 0.7 acres/phase = 4.1 acres total <br />1.0 acres in parking, office, ore bin and staging area <br />1.0 total acres to be reclaimed following portal investigation and reclamation <br />• 8.3 acres total will be disturbed <br />2.0 acres in road improvements for hauling and drilling will be left intact at owners <br />request <br />• 6.3 total acres to be reclaimed <br />The reclamation plan does not give any details for the reclamation of the ore bin / office area other than removal <br />of the bins and office. Please submit additional information for reclamation of this area. DRMS has requested <br />additional information within Exhibit T for this area in relation to reclamation as well. <br />Prior to construction of the detention berm around the staging area, the minimal available topsoil <br />will be removed and stockpiled at a suitable location west of the staging area. The soil stockpile <br />will be of low profile, reseeded with the approved seed mix, and surrounded with a silt fence <br />and/or fallen logs and brush to minimize erosion. The berm will be constructed from materials <br />in the immediate area including sandy sub-soil and gravels removed from the ore loading and bin <br />area and the storm water retention sump and detention pond. <br />Reclamation will include removal of all trailers, c-cans, and mining equipment from the site. <br />Potentially radioactive materials such as the concrete ore bins and retention sump will be buried <br />in one of the abandoned mines prior to closure and reclamation, or hauled to an approved <br />disposal site. These concrete materials and sump tanks would be broken up or crushed prior to <br />disposal. The final ore loading and bin sites will be surveyed with scintillometer to confirm <br />radiation is at or below background levels prior to their construction. <br />Section 2, Pit and knob <br />If concurrent reclamation is revised please revise this section to note reclamation will be completed upon <br />termination of excavation. Please note that 0.2 acres may not be sufficient to hold all rock waste until <br />reclamation commences. Also it is noted that a road is blocked by the stockpiled materials and remains so after <br />reclamation. Please provide details that this is acceptable to the landowner. <br />Please revise paragraph 2 as follows: <br />Initially, the floor of the Pit will be deepened as remaining ore is excavated from it. Then the <br />cap rock from the Knob will be removed and placed in the fully excavated Pit. As much as <br />practical, as each area is mined, waste rock will be placed in the mined area and then covered by <br />the adjacent cap rock. When the excavation/mining is complete the replaced cap rock will be <br />contoured to the surrounding area as shown on Map F-1. The minimal available topsoil will be <br />spread and re-vegetated with a seed mixture recommended by the Bureau of Land Management. <br />The operator will post a reclamation bond with DRMS sufficient to ensure reclamation of the site <br />in accordance with the mining plan. The existing road/two-track will be reestablished across the <br />southern edge of the reclaimed area if so requested by the landowner. <br />10