2012-04-18_REVISION - M1984014 (13)

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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment (4) Maps C -1, C -2, and C -3 indicate the Department of Energy Lease Tract and permit areas. However, the maps do not differentiate the permit area from the affected area. Please provide an additional map that is a close up of the permit area and clearly shows the affected areas. Cotter response: A new Map C -4 (attached) is a larger scale map of the permit area providing more detail. (5) (7) On Map C -2, there is a discrepancy between the property name identified as the Black Tom and that owned by Brown Family Trust as Black Point. Please clarify and correct. Cotter response: On Map C -2 the Black Point claim owned by the Brown Family Trust is located adjacent to the northwest boundary of the JD -8 lease tract, and the Black Tom claim owned by William Barnett is located adjacent to the northeast boundary of the JD -8 lease tract. (6) Page D -1, Paragraph 1, in reference to gobbing waste rock underground, please demonstrate that proposed locations for such activities will not be susceptible to contact with groundwater or surface water intrusions. Gobbing shall not be allowed until the groundwater regime is fully characterized through the EPP process. Cotter response: Groundwater conditions have been further characterized. Attachment 6 is a technical memorandum, dated April 13, 2012 entitled "Hydrogeologic Data Compilation for the JD -8 Mine." (See Revised Supporting Documentation for Exhibit U.) This information was presented to DRMS in the November 30, 2011 meeting. In summary, data compiled from 559 drill holes confirms that the JD -8 mine is a dry mine. Only 29 percent of the exploration drill holes encountered water during drilling, and in most cases, the groundwater occurred at or below the contact of the Brushy Basin Member of the Morrison Formation and the underlying Summerville Formation (which overlies the Entrada Sandstone). The mine workings have remained dry for the life of the mine. (Some of these workings have been open for more than 30 years.) Gobbing is planned for the dry portions of existing and future workings. On Page D -1, Paragraph 2, it notes that water diversions and impoundments are covered under the attached EPP. Per Rule 6.4.7(2) all structures need to be clearly identified and shown on the Exhibit C - Mining Plan Map. The submitted Exhibit C maps do not clearly show these structures. Cotter response: Surface water diversion and impoundment structures have been included on Maps C -1 and C-4 (attached). (8) The language on Page D -1, Paragraph 3, and elsewhere is confusing. While it understood the upper mine area is not in the immediate plans, structures and disturbances for this area are outlined in the mine plan, reclamation plan, and the reclamation cost exhibits. If Cotter wishes to include the proposed operations for the upper mine area in the permit now, all required information, including all EPP requirements for these operations must be addressed in this amendment. Otherwise, any Page 6