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Nuvemco, LLC's Monogram Mine M-1978-222UG <br />Response to Preliminary Adequacy Review <br />March 10, 2009 <br />Exhibit DA Nfinina Plan <br />Rule 6.4.4 <br />Section 2, Surface Mining: <br />The mine plan notes extraction ofrock by an excavator. If the rock is too hard for the exuivator will explosives <br />be used? If so please provide the required information for Rule 6.4.4(i). <br />Based upon experience in the area, the operator is confident that the excavator will be able to <br />break up the material and in many cases load ore directly in to ore hauling trucks. In the unlikely <br />event that blasting is required, Nuvemco will notify DRMS and demonstrate Geotechnical <br />Stability in accordance with 6.5 (4) as follows: <br />6.5 Geotechnical Stability Exhibit <br />(4) At sites where blasting is part of the proposed mining or reclamation plan, the Applicant shall <br />demonstrate through appropriate blasting, vibration, geotechnical, and structural engineering analyses, that <br />off-site areas will not be adversely affected by blasting. <br />Nuvemco does not anticipate the need for blasting. Should it become necessary, they will <br />comply with the above requirements. Nuvemco will advise DRMS of the need to blast and offer <br />a demonstration to document that adjacent off-site area will not be impacted. Nuvemco does <br />control the adjacent property by mining claims. Any blasting required would be performed in <br />accordance with MSHA regulations and under Nuvemco's current explosive handling licenses. <br />Since the purpose would be to break up the rock in place, limited explosives would be placed in <br />drilled holes and the ore would be broken, but not displaced. Also, there are no structures, roads, <br />buildings, workings or other features to be disturbed by the mining operation. The small adits in <br />the Monogram Knob Mine area will be removed as part of the mining operation. <br />The mine plan notes that much of the reclamation will be concurrent to mining. However the proposed <br />disturbance area appears not to be sufficient to allow room for truck turn arounds and loading. Given that only <br />1.1 ache is the total disturbance of the new pit area staff has concerns that the commitment to eoncun-ent <br />reclamation cannot be achieved. Please clarify that concurrent reclamation will not be disturbed by current <br />mining activities or remove the concurrent reclamation proposal from the plan. <br />Nuvemco anticipates being able to modify the existing ore hauling road by closing the loop in <br />the area of surface mining allowing ore trucks to drive in a circular manner through the mine and <br />be loaded directly by the excavator. If the loop is blocked by mining activity, the proposed 20 or <br />22 ton tandem dump trucks will be able to use the fork in the road to turn and back up to the <br />loading area. <br />Note that should ore grade require blending, or intermittent storage be necessary, ore will be <br />transported by loader or ore buggy from the Monogram Knob to the ore bins on the west end of <br />the claim near the office trailer and storage unit. <br />As DRMS notes in comment above, final reclamation in the vicinity of the mine may not be <br />possible until the mining is complete, although replacement of barren waste rock in mined out <br />areas should occur. Nuvemco would like to remove the "concurrent reclamation proposal" from