2012-04-18_REVISION - M1984014 (13)

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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment include the submission of as -built engineering drawings ( "As- Builts "). The As- Builts will be provided within 90 days after the stormwater facilities are constructed and will be certified (signed and stamped). (14) Rule 7.3.2, written acceptance of certification for facilities under this paragraph (Environmental Protection Facilities) must be provided by the operator via a certified professional engineer or other appropriate qualified professional. None of the proposed facilities has an engineer's stamp or certification of design. Cotter response: The EPP and Drainage Design Plan submitted for AM -01 on June 1, 2011, were written and designed by Susan Wyman, Colorado Registered Professional Engineer No. 34662. Revisions to the Drainage Design Plan have been reviewed and signed and stamped by the same. Because the existing Environmental Protection Facilities (waste rock pile and ore transfer pad) were designed and constructed in the late 1980's (before "Environmental Protection Facilities" were defined and before the P.E. certification was required for such facilities) and because no re- design of the waste rock pile is proposed in its current configuration, the waste rock pile is not certified as having been designed by a professional engineer. (1 S) Table 26, the seed mix and associated text should also be noted in the Reclamation Plan, Exhibit E. Cotter response: The seed mix specified in the EPP has been added to the Reclamation Plan (Exhibit E). (16) A map of sufficient size, that clearly shows stormwater control structures, is needed. The map should show stormwater run -on prevention structures, a storm water collection system within the permit area and affected areas, and their relationship to containment structures. The map with limited arrows is too general. Cotter response: The stormwater control structures are shown in larger maps in Attachment 4 - the revised Drainage Design Plan (see Revised Supporting Documentation for Exhibit U). (17) Please provide a detailed map of the ore storage pad area that highlights storm water retention, and run -on, run -off structures. Please detail measures that will be put into place to prevent cumulative collection and infiltration of radioactive sediments into the substrata below the footprint of the stockpile area. A geo- synthetic liner or some other approved barrier for the area needs to be part of the EPP. Cotter response: Two or more sequential sites for the ore storage pad are planned, because the ore pad will be relocated as the waste rock pile is built up. At both sites, design components (BMPs) will be employed to prevent cumulative collection and infiltration of radioactive sediments into the substrata. These design components Page 13