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Response to DRMS Adequacy Review #2 — Cotter JD -8 Mine Reclamation Plan Amendment <br />Cotter Corporation (N.S.L.) ( "Cotter ") submits this response ( "Response ") to the May 21, 2012 <br />letter from Russell Means, Division of Reclamation, Mining and Safety ( "DRMS "), to Glen <br />Williams, Cotter. The DRMS comments are in italics and Cotter's responses are in bold. <br />On June 8, 2011 the Division of Reclamation, Mining, and Safety (Division) called Cotter <br />Corporation's (Cotter) submittal of an Environmental Protection Plan (EPP) amendment, AM- <br />01 for the C -JD -8 Mine, Permit No. M -1984 -014, complete for review. On October 3, 2011 the <br />Division issued a Preliminary Adequacy Review (PAR) regarding administrative and technical <br />issues. The Division received a response to the PAR on April 18th, 2012. Staff has reviewed the <br />responses submitted and has a few issues that need additional clarification or correction: Please <br />respond to the following: <br />1) On June 20, 2011 the Division received and forwarded comments from the Colorado <br />Historical Society. The Society noted five sites in the area were surveyed in the past. They <br />recommended resurvey of sites after ten years. The Division requested Cotter respond to <br />the Historical Society and copy to Division staff. On May 4, 2012 the Division received a <br />Cultural Resource Inventory Report from ERO Resources on behalf of Cotter. The report <br />was forwarded by ERO to the State Historic Preservation Society on May 15, 2012. One <br />site, 5MN973, was found to be eligible for the National Register of Historic Places. <br />Please provide documentation that the site will be outside the proposed future fan pad <br />sites and access roads. <br />Cotter response: The proposed future fan pad (vent hole 1) site will be located <br />north of the Cultural Site 5MN9732 as shown on the drawing C6 which is provided <br />in Attachment 1. <br />2) Rule 1.6.5(2), the applicant must provide proof of publication. The Division received <br />proof of publication but it was of poor quality. Cotter submitted a clear replacement copy <br />on May 4, 2012. <br />Cotter response: The copy of the proof of publication has been submitted to the <br />Division, as noted above by DRMS. <br />3) The Gamma Survey Map, E -2, gives an overview of the entire project area but are very <br />general. Details are lacking as to the readings around relevant structures within the <br />permitted area. Please provide a map, preferably similar in size and nature to storm <br />water maps submitted with the response. <br />Cotter response: A larger scale 11 inch x 17 inch Gamma Survey Map of the lower <br />mine permit area is provided in Attachment 2. <br />4) On Page 6, # 6 and in other sections relevant to this issue Cotter has submitted data that <br />supports no or very limited groundwater interdiction with mine workings. Item 6 <br />discusses the practice of gobbing waste materials underground. The practice is common <br />in dry mines with the following stipulation: Should groundwater be unexpectedly <br />encountered in quantities that require retention measures and / or pumping, <br />approximately a gallon per minute or more, Cotter shall notify the Division in writing <br />Page 3 <br />