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2013-04-15_REVISION - M1977451 (15)
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2013-04-15_REVISION - M1977451 (15)
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Last modified
4/14/2022 10:00:29 AM
Creation date
5/8/2013 2:50:10 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977451
IBM Index Class Name
REVISION
Doc Date
4/15/2013
Doc Name
RESPONSE TO ADEQUACY REVIEW #1
From
COTTER
To
DRMS
Type & Sequence
AM1
Email Name
KAP
GRM
Media Type
D
Archive
No
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Response to DRMS Adequacy Review (1) -Cotter SR -11 Mine Reclamation Plan Amendment <br />consistently been shown to be of no concern. Geochemical conditions of high <br />alkalinity, montmorillonitic clay soils that exhibit high cation exchange <br />capacities, and an and environment where infiltration of precipitation is <br />limited to the upper few centimeters of soil all provide a sound technical <br />position that the SR 11 Mine will have no significant impact on the <br />surrounding environment. <br />To address the DBMS concern of "potentially leachable constituents," <br />regardless of the limited potential environmental impacts described above, <br />Cotter will install a 30 -mil synthetic liner under the ore pad area and cover <br />the liner with 12 inches of clay material to protect its integrity. During the <br />construction of the decline, mine waste material with a high clay content will <br />be preferentially selected to provide an additional level of protection. This <br />type of liner will also address recent concerns (discussed with DBMS) <br />regarding fines from the ore pile migrating to the underlying waste rock pile <br />that could result in additional reclamation costs if post - reclamation radiation <br />surveys were to show higher values in the waste rock pile. A cross section of <br />the ore pad is included as Attachment 3. <br />7. Addressing Rule 64.21 (16) - On page 42, the EPP states that Cotter Corp. will conduct <br />regular inspections of all structures. Please inform the Division of the anticipated <br />minimum quarterly inspection schedule and include the results in the Annual Report. <br />Cotter will at a minimum inspect all structures once per week when the mine <br />is active and once per month when the mine is inactive. <br />8. Addressing Rule 6.4.21(- 1:8)(b). Please describe the measures Cotter Corp. intends to <br />take to prevent wildlife from coming into contact with uranium, uranium by-products or <br />any other radionuclides. <br />The Colorado Parks and Wildlife was informed of Cotter's intent to mine <br />and store uranium onsite. It did not recommend any additional measures to <br />3 <br />
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