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 Section 3, Exploration: Please note that exploration within the permit area is considered mining activities. There is not enough detail to accurately project total disturbance and a reclamation liability. There are references vOthin the reclamation plan of such disturbances. Please outline in the mine plan how many drill holes are proposed and their typical characteristics. Haw many and locations of all mine features that will be disturbed in the exploration project? What will the extent of those disturbances be? Please clarify any discrepancies between the mining and reclamation plans. Drilling As shown on Map C-3 Monogram Permit Topographic Base, the northern part of the area which includes the Office, Ore Bin and Monogram Knob is on a lower bench than the south half of the permit area. The topographic benches are separated by very steep slopes and cliffs which have had several horizontal southwest trending adits driven into them. Mining activities have occurred on both benches, and adits from the lower bench (north) may have accessed ore beneath the upper (south) bench. Map C-6 is a geologic map on which these steep slopes and cliffs are shown as faults and the benches as fault blocks. These probable fault-block features are present and parallel to the Paradox Valley on this part of the Monogram/Davis Mesa with a probable origin related to the dissolution of salts beneath the anticline that preceded the Paradox Valley. As shown on the photographic base of Map C-4, many old drill trails are present and frequented by recreational four-wheelers and ATVs. Nuvemco plans to drill exploratory holes along many of the roads and two tracks to evaluate geology and uranium-vanadium mining potential across the permit area. Initial drilling will probably be on 100 foot centers. Based upon results of geophysical logging, closer spaced holes may be drilled in some areas. Although the potential exists to drill 300 exploration boreholes, reclamation will be concurrent with drilling and no more than 50 holes will be drilled in any phase prior to reclamation. Drilling should be a one time event - drive rig along existing road/trail/clearing - drill hole - pull rig off (generally forward 50 to 100 ft) - pull up logging truck - geophysically log hole - logging truck follows rig - pull up with pickup and crew to P&A hole and reclaim site - move to next site. Drilling will be done using a self-leveling, 10-wheel truck mounted air rotary rig which has the capability of driving to each borehole location with minimal disturbance. Drill holes will be 6 inches in diameter, an estimated 200 to 400 feet deep, and plugged and abandoned in accordance with all regulations. No new roads will be constructed and the maximum area disturbed will be less than 20 ft x 30 ft per hole (area where truck is parked and crew is working) resulting in a potential temporary and minor disturbance of 50 x 600 sq ft = 30,000 sq ft. Thus, with respect to drilling, no more than 2/3 acre will be disturbed at any time, but a total of up to 180,000 sq ft or about 4.1 acres could be disturbed. Many drill sites will be directly on bedrock with no potential re-vegetation, but if soil exists, it will be reseeded and monitored to confirm successful re- growth. Reclamation on roads/trails will be limited to reduce road to pre-e):fisting width and erosion control. Extensive and continuous truck and equipment traffic will be limited to the ore hauling road to the Monogram Knob and on the Montrose County roads. All of this drilling will be designed to evaluate ore potential and existing mine workings which are beneath this area and could potentially be accessed from the adits which may exist or be constructed to the north.