2009-03-12_REVISION - M1978222UG

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Nuvemco, LLC's Monogram Mine M-1978-222UG Response to Preliminary Adequacy Review March 10, 2009 Exhibit L, reclamation cast: Staff notes that the exhibit does not include mobilization, overhead and insurance and a total for all tasks. DRMS will calculate the estimated reclamation liability after all issues have been addressed. Nuvemco has modified Exhibit L as follows: EXHIBIT L - RECLAMATION COSTS As described in Exhibit E - Reclamation Plan, The reclamation will be limited at the owner's request "that the general area be left as is for recreational purposes leaving the existing roads and trails." Thus, reclamation will include re- grading the Knob and Pit areas and removal of all trailers, c-cans, and mining equipment from the site. Much of the slope contouring will occur concurrently with mining. Finalizing slopes at the mine site will require about 1-2 days of dozer work using Nuvemco personnel and equipment at a cost of about $2,000. Potentially radioactive materials such as the concrete ore bins and retention sump will be buried in one of the abandoned mines prior to closure and reclamation, or hauled to an approved disposal site. These concrete materials and sump tanks would be broken up or crushed prior to disposal. Break up 56 cubic yards of concrete and haul to disposal at $40 per cubic yard = $2,400 Thus, surface reclamation will be limited to reclaiming only about 6.3 acres and after re- contouring the land surface and potholing the slopes, scarifying and seeding is estimated to cost about $6,930, as follows. Scarifying at $350/acre Re-seeding at $350/acre Mulching, if required at $400/acre Total = $1,100/acre x 6.3 acres = $6,930 The office and storage facilities will be moved to another mining operation and those costs borne by that mine. Some aspects of reclamation will be concurrent with the exploration and development efforts and complete within six months of termination of mining efforts. In the event that further underground mining is warranted, a major permit revision will be prepared and include revised reclamation costs and timetables. Table L-1. Worst Case Reclamation Summary Task Description Cost Time Needed No. (days) 1. Re-grade the Monogram Knob and Pit area $2,000 2 2. Break up ore bins and wastewater sump/tanks and put $2,400 4 in mine or ship for disposal 3 Portal/adit closure and reclamation $5,000 5 14