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Response to DRMS Adequacy Review — Cotter LP -21 Mine Reclamation Plan Amendment <br />4. Addressing Rule 6.4.21 (8)(c) — The EPP states, on page U-8, that geological units in the area <br />dip steeply to the northeast. On page U -11, under section 8.3.2, the EPP states that <br />geological formations dip to the northwest. On page U -13, the EPP again states that strata <br />dip to the northwest. Please clarify. <br />The first paragraph on page U -11, under section 8.3.2, should read, "The geologic <br />structure of the area is also important in predicting the direction of groundwater <br />flow. LP -21 is located on the flank of the Paradox anticline with the geologic <br />formations dipping to the northeast at 0.07. Groundwater flow directions in the <br />area are controlled by the dip of the rock and would flow in a similar northeast <br />direction." <br />The second to last paragraph on page U -13 should read, "Assuming saturated <br />conditions existed in the Salt Wash sandstone, a porosity value of 0.2, and a <br />hydraulic gradient of 0.07, equal to the regional dip of the strata, then calculated <br />groundwater transport rates for uranium and related constituents from ore bodies <br />would be approximately less than 4 feet a year in a northeast direction. Average <br />transport rates in the upper -most potential aquifer, assuming that the Wingate <br />Formation contains groundwater, would be less than 100 feet per year in the same <br />northeasterly direction." <br />S. Addressing Rule 6.4.21 (8) — On page U-15, the EPP states that '`numerous boring continued <br />through the ore zone and into the upper portion of the Salt Wash Formation". It has been <br />previously stated that the upper portion of the Salt Wash Member is the ore zone. Please <br />clarify. <br />The borings penetrated the ore zone that is located in the upper sandstone unit of <br />Salt Wash Member but did not penetrate into the middle or lower portions of the <br />Salt Wash Member. The ore zone is located within the upper sandstone. <br />6. Addressing Rule 6.4.21 (8) (b) — The EPP discusses, under section 8.3.1 on page U -10, several <br />mapped springs in the area. The unnamed spring was not field identified Please provide the <br />Division with the location and elevation of the Horsethief Spring. <br />Horsethief Springs is located directly east of the LP -21 site at approximately 6300 <br />feet. The location and elevation can be found on Figure U-1 — Geological map. <br />7. Addressing Rule 6.4.21 (12) — On page U -17, the EPP states that if water is encountered <br />during mining, and chemical analysis determines that uranium related constituents are above <br />regulatory guidelines, then a monitoring well will be installed If groundwater is encountered <br />during mining, a monitoring well shall be installed and a monitoring plan shall be established <br />in accordance with this rule, regardless of the results of the chemical analysis. Please commit <br />to this. <br />4 <br />