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13. Addressing Rule 6.4. 21(6) (b) (iii), please describe how Cotter Corp. will prevent adverse <br />off -site impacts during periods of Temporary Cessation. <br />The stormwater control structures will be inspected one to two times per month <br />during periods of Temporary Cessation. Cotter will maintain stormwater <br />control structures to minimize adverse off -site impacts. <br />14. Addressing Rule 6.4.21(7), the EPP states that a radiometric survey will be completed <br />prior to mining in order to document baseline conditions at the site. Baseline conditions <br />shall be established as part of this amendment process. Please conduct a radiometric <br />survey of the affected area and submit the results to the Division along with an <br />evaluation of the expected effectiveness of the proposed EPP, which specifically <br />addresses the risks, from uranium, uranium byproducts, and any other radionuclides <br />expected to be encountered during this operation, to human health, property and the <br />environment. <br />The baseline radiometric survey is included as Attachment 6 in this response to <br />DRMS comments. Cotter procedures for separating ore from waste rock are <br />designed to minimize the addition of uranium ore to the waste rock pile —an <br />approach that makes sense from an economic and environmental standpoint. <br />The EPP addressed several issues that evaluate the risks to human health and <br />the environment. The potential of acid mine drainage from the waste rock piles <br />was quantified by the SPLP tests that indicated this was not an issue. The <br />hydrogeologic evaluation presented in the EPP showed that factors of low <br />precipitation, low permeability, and geochemical conditions restricted potential <br />leachate from the waste rock piles from impacting groundwater resources. A <br />detailed Drainage Design Plan (Appendix III in the EPP) routes off -site surface <br />runoff around the waste pile and captures and contains on -site runoff from a 10- <br />year 24 -hour precipitation event. <br />5 <br />