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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />( <br />(9) <br />levels of radiation from natural and man -made radioactive materials needs to be clearly <br />defined for the purposes of establishing reclamation bench marks. While <br />bioaccumulation and sequestration are important tools for evaluation, they are not <br />required by the Division and do not help establish the necessary baselines. A survey shall <br />be required on a maximum 50 foot by 50 foot grid and must include current and future <br />affected lands, with offsite control measurements. It is highly advisable that areas of <br />stormwater discharge and other critical areas be given additional attention. Please note <br />the requirement in Rule 6.4.21 (7) - Facilities Evaluation. Please submit a plan for <br />conducting a radiometric survey, for Division approval, prior to initiation. The survey <br />must be completed and submitted as part of the A111-01 EPP application. <br />Cotter response: The site radiation survey was conducted on October 19, 20, and <br />24, 2011. The results of the site radiation survey are included with this submittal in <br />revised Exhibit E — Reclamation Plan, as Figures E -1, E -2, and E -3 (attached). <br />Section 6, Page 25 should have detailed discussions on the handling of the toxic <br />materials such as ore and waste rock, to prevent cross contamination of unaffected waste <br />rock How are different grades of ore going to be handled and isolated from waste rock? <br />Cotter response: Mining of the ore is generally accomplished by "split- shooting" <br />the ore and the associated waste material. During the "split- shooting" effort the <br />drill round is completely drilled, the drillholes are probed to determine where the <br />break between ore and waste material is, and then the waste material is blasted and <br />removed. Once the waste material is removed, the ore material is blasted and <br />removed to the ore stockpile area. This information on ore handling will be <br />included in any future revisions to the EPP. <br />(8) On Page D -1, Paragraph 2, it notes that water diversions and impoundments are covered <br />under the attached EPP. Per Rule 6.4.7(2) all structures need to be clearly identified and <br />shown on the Exhibit C - Mining Plan Map. The submitted Exhibit C maps do not clearly <br />show the proposed structures. <br />Cotter response: Stormwater diversions and impoundments have been added to the <br />revised maps in Exhibit C — Pre - mining and Mining Plan Maps of Affected Lands. <br />The groundwater data provided under Section 9 primarily appears to have been <br />extracted from the information gathered on the Pinion Ridge Mill site located north of the <br />mine and substantially lower in elevation on the Paradox Valley floor. The geological <br />stratigraphy, as presented, indicates the dip goes away from this area to the south as well <br />as being isolated by several block faults. None of the information addresses the areas to <br />be mined but appears to focus solely on the surface disturbance area of the lower mine. <br />Per Rule 6.4.21 (8) (c) the EPP must address "all geological media down to and <br />including the upper most aquifer under proposed sites of material storage, stockpiles, <br />waste piles, disposal sites ... or proposed affected area where such subsurface materials <br />and any associated waters have the potential to be contaminated by ... materials that are <br />toxic ... " The submitted plan does not address the potential impacts to groundwater <br />Page 10 <br />