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2012-04-18_REVISION - M1984014 (13)
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2012-04-18_REVISION - M1984014 (13)
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Last modified
6/15/2021 2:25:40 PM
Creation date
4/23/2012 4:00:35 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1984014
IBM Index Class Name
REVISION
Doc Date
4/18/2012
Doc Name
RESPONSE TO ADEQUACY REVIEW
From
COTTER
To
DRMS
Type & Sequence
AM1
Email Name
GRM
TC1
Media Type
D
Archive
No
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Response to DRMS Adequacy Review — Cotter JD -8 Mine Reclamation Plan Amendment <br />(1) <br />proposed affected surface areas that could potentially be contaminated with radioactive <br />materials such as waste rock, ore, radioactive dust, radioactive water, etc. to establish <br />current on site conditions and will be part of the EPP. <br />Cotter response: A gamma survey of the lower mine area and the proposed vent <br />hole locations and proposed vent hole access roads was conducted and three maps <br />are included in the revised Exhibit E — Reclamation Plan (attached). Of note on the <br />maps, there are several areas which have noticeable gamma readings from pre- <br />existing mine waste dumps and mine haul roads. <br />(14) The seed mix referred to in Exhibit E text was not included in the exhibit. Please submit <br />the applicable seed mix. <br />Cotter response: The referenced seed mix is included with the revised Exhibit E — <br />Reclamation Plan (attached). <br />(1 S) Exhibit F, the Reclamation Map does not show the fan locations and access road <br />reclamation for the upper mine. Nor does it give sufficient detail of stormwater structures <br />to remain in place at the lower mine for the access road and reclaimed areas. <br />Cotter response: The stormwater structures to remain in place after mining are <br />shown on the Map F -1 in revised Exhibit F — Reclamation Plan Map (attached). <br />(16) Please provide the Threatened and Endangered Species study referred to in Exhibit H. <br />Cotter response: The Threatened and Endangered Species Study could not be <br />located in our files. Consequently later this spring, when the snow cover has gone <br />away, a new Threatened and Endangered Species study will be conducted for the <br />currently affected and proposed affected areas. <br />(17) Please respond to issues raised by the Division of Parks and Wildlife in their May 5, <br />2011 letter. <br />Cotter response: A response to the issues raised by the Division of Wildlife is <br />attached as revised Exhibit H — Wildlife Information. <br />(18) The Division will calculate a reclamation liability estimate once all issues are resolved <br />and prior to a decision. <br />Cotter response: Comment noted. <br />Environmental Protection Plan Review: <br />On Page 1, Paragraph 3 the statement "the mine is in intermittent status rather than <br />active state means many of the EPP requirements do not currently apply", should be <br />removed. The statement is misleading. The EPP requirements for stormwater <br />management and baseline hydrologic and radiometric characterization are essential to <br />address current affected area disturbances. The required elements shall be initiated upon <br />approval of the EPP and completed in a timely manner, not some unspecified time in the <br />future. <br />Page 8 <br />
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