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Response to DRMS Adequacy Review β€” Cotter LP -21 Mine Reclamation Plan Amendment <br />2. Addressing Rule 6.4.21 (6)(b)(iii) β€” Please describe how Cotter Corporation will prevent off - <br />site impacts during periods of Temporary Cessation. <br />The site will be inspected one to two times per week during periods of temporary <br />cessation. If any adverse off -site impacts are noted, Cotter will take appropriate <br />steps to correct the problem. The reclaimed waste rock pile has a 413:1V slope and <br />vegetation is well established. As discussed in sections 6.1.3.3, 8.3.2 and (10) of the <br />EPP, it is unlikely that there would be any adverse effects on surface or <br />groundwater from this site. <br />Once active mining resumes at the LP -21 mine, the recommended stormwater <br />structures will be constructed and left in place after final reclamation. The goal of <br />these structures will be to divert any offsite stormwater from coming into contact <br />with the waste rock and to retain any stormwater runoff from the waste rock pile <br />itself. Good housekeeping will be exercised at all times which include keeping the <br />site free of debris, cleaning up any spills and repairing any damage to stormwater <br />structures. <br />3. Addressing Rule 6.4.21(7) β€” The EPP states that a radiometric survey will be completed prior <br />to mining in order to document baseline conditions at the site. Baseline conditions shall be <br />established as part of this amendment process. Please conduct a radiometric survey of the <br />affected area and submit the results to the Division along with an evaluation of the expected <br />effectiveness of the proposed EPP, which specifically addresses the risks, from uranium, <br />uranium byproducts, and any other radionuclides expected to be encountered during this <br />operation, to human health, property and the environment. <br />The baseline radiometric survey is included as Attachment 4 in this response to <br />DBMS comments. Cotter procedures for separating ore from waste rock are <br />designed to minimize the addition of uranium ore to the waste rock pile β€”an <br />approach that makes sense from an economic and environmental standpoint. The <br />EPP addressed several issues that evaluate the risks to human health and the <br />environment. The potential of acid mine drainage from the waste rock piles was <br />quantified by the SPLP tests that indicated this was not an issue. The hydrogeologic <br />evaluation presented in the EPP showed that factors of low precipitation, low <br />permeability, and geochemical conditions restricted potential leachate from the <br />waste rock piles from impacting groundwater resources. A detailed Drainage <br />Design Plan (Appendix III in the EPP) routes off -site surface runoff around the <br />waste pile and captures and contains on -site runoff from a 100 -year 24 -hour <br />precipitation event. <br />3 <br />