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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />(9) <br />references to the upper mine area proposed operations should be deleted from the <br />current submittal and resubmitted in a future amendment. <br />Cotter response: The revised Exhibit D — Mining Plan (attached), eliminates <br />reference to the upper mine area. The potential affected areas remaining on top of <br />Monogram Mesa are the three vent holes and associated access roads. <br />Per Rule 3.1.5 (5), Materials Handling, all toxic producing materials that have been <br />mined shall be handled and disposed of in a manner that will control unsightliness and <br />protect the drainage system from pollution. Please provide details of how high grade and <br />low grade ores are handled and best management practices to prevent ore cross <br />contamination with waste rock <br />Cotter response: A description of the mining process incorporating split- shooting of <br />the ore and waste rock is included in the revised Exhibit D — Mining Plan. <br />(10) The lower mine area is on patented claims and not under the jurisdiction of the DOE. <br />Therefore the requirements for reclamation shall meet the specifications of the Act and <br />Rules of the State of Colorado and the issued reclamation permit. Therefore, please <br />remove or revise the statement in Exhibit E, Page E -1, Paragraph 1, which states Cotter <br />will restore the affected areas in accordance primarily with DOE lease requirements for <br />JD -8. <br />Cotter response: The revised Exhibit E — Reclamation Plan (attached) contains a <br />revised statement regarding reclamation requirements. <br />(11) On Page E -1, Paragraph 5, there is a lengthy discussion of reclamation of the upper <br />mine area. If the area is only a potential disturbance then the details of reclamation are <br />confusing to the current plan. Please see comment no. 8 above. If proposed plans for <br />mining operations in the upper mine area are to be included in AM -01, those plans must <br />include descriptions of the size of the shaft, details of construction of the head frame, <br />and /or the hoist house, and how the power will be supplied. The reclamation plan and <br />reclamation bond will need to address details and costs for removal of the head frame <br />and other mine infrastructure. <br />Cotter response: Reference to the upper mine area have been eliminated in the <br />revised Exhibit E — Reclamation Plan (attached). <br />(12) The reclamation plan refers to vent hole reclamation but does not address reclamation of <br />the access roads or power lines to the structures. Please submit reclamation plans for all <br />access roads and power lines to be reclaimed. <br />Cotter response: The vent hole access roads are addressed in the revised Exhibit E <br />— Reclamation Plan (attached). <br />(13) The last paragraph of Page E -1 that carries over to E -2 notes the "material depth to be <br />removed will be determined in the field during reclamation effort, based on a gamma <br />survey ". The Division needs to know what the gamma readings are prior to disturbance, <br />or currently, to establish baseline levels. A baseline radiometric survey is required for all <br />Page 7 <br />