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Page 3 <br />third-party professional expert will be engaged under this section of the Act for Powertech's Centennial <br />and Indian Springs Uranium Project. Powertech has already conducted some Baseline Site <br />Characterization work at the Project. However, Powertech still has significant baseline characterization <br />work to conduct, including the planned aquifer pumping test in section 33, T10N, R67W. Also, DRMS <br />review of the April 2009 Site Characterization Plan is underway. These are exactly the types of things <br />that can be reviewed, monitored, and overseen by a third-party expert, and the DRMS has decided they <br />will be reviewed, monitored, and overseen by a third-party expert. <br />f. The April 2009 Site Characterization Plan states in sections 1.0, 1.3, and 1.4 that it was prepared to <br />meet the requirements of §§ 112.5(5)(a), (b), and (c) of the Act, which are the sections relating to <br />Baseline Site Characterization and the use of a third-party expert. <br />5. The DRMS is not dissuaded from the conclusion described in item four above by the arguments <br />included in the April 15, 2009 Fognani and Faught letter (Fognani letter). The DRivIS response to the <br />arguments presented are described as follows. <br />a. The Fognani letter states that DRMS has not been specific about the components of prospecting <br />notice P-2008-043 it considers to be Baseline Site Characterization. Specifically, the following <br />information collected under P-2008-043 is Baseline Site Characterization because the information is of <br />the type DRMS will expect and require to be used in the preparation of a reclamation permit application: <br />i) Stratigraphic information from drilling and logging of seventeen monitoring wells and nine <br />exploration boreholes. <br />ii) Geologic information, including geochemical and mineralogical information from logging of <br />seventeen monitoring wells and nine exploration boreholes and from analysis of core and cuttings <br />such as petrographic analysis, microprobe analysis, leaching characteristic analysis, etc. <br />iii) Geohydrologic information, such as ground water gradient and aquifer/aquitard properties and <br />relationships from drilling and logging of seventeen monitoring wells and nine exploration boreholes, <br />and from completing, developing, pump testing, and monitoring seventeen monitoring wells. <br />iv) Ground water quality information from samples collected from and measurements made in seventeen <br />monitoring wells. Attachment B to Powertech's August 20, 2008 submittal to prospecting notice P- <br />2008-043 lists 65 parameters to be measured in the field, by a laboratory, or calculated for ground <br />water monitored from the seventeen wells. <br />It is further noted that the same type of Baseline Site Characterization information listed in items i-iv <br />above has been and to an extent is continuing to be collected from the 21 monitoring wells described the <br />April 2009 Site Characterization Plan. <br />b. The Fognani letter states that hiring a third-party reviewer is not appropriate in connection with a <br />prospecting notice, and can only be done in connection with baseline site characterization activities <br />conducted in connection with a reclamation permit application. This position is incorrect; part of the job <br />of the third-party reviewer is to oversee Baseline Site Characterization activities, and, as discussed in <br />items 4 a and d above, since the activities are required to occur in advance of permit application and can <br />be conducted under a prospecting notice, hiring a third-party expert is appropriate in connection with a <br />prospecting notice. Another task that can be performed by a third-party expert is to review information <br />submitted by a prospective applicant, such as the April 2009 Site Characterization Plan. The decision to <br />require a third-party expert in connection with a prospecting notice is made by DRMS on a case-by-case <br />basis considering the magnitude and complexity of the characterization work being done. <br />c. The Fognani letter presumes that it is the position of DRMS that any sampling or testing activities at <br />a potential mining site constitute baseline site characterization. The goal of the Act is that planned and