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Response to DRMS Adequacy Review (1) -Cotter SR -11 Mine Reclamation Plan Amendment <br />18. Addressing Rule 6.4.21(12), on Page U-15, the EPP states that "Water encountered <br />during mining will be sampled and sent for chemical analysis. If levels of uranium- <br />related constituents are above regulatory guidelines, Cotter will initiate monitoring <br />according to DRMS regulation. A well will be placed down gradient of the mining area ". <br />If groundwater is encountered during mining, a minimum of three monitoring wells shall <br />be installed. The location of the wells must be approved by the Division prior to <br />installation. Also, subject to Division approval, a sampling and analysis plan shall be <br />implemented in accordance with Rule 6 4.21(12) and Rule 3.1.7, regardless of the results <br />of the chemical analysis. <br />As stated in the response to item 11, due to the lack of recharge and the drill <br />hole data, it is expected that there will be no significant groundwater in the <br />mine. However, if groundwater is encountered during mining of one gallon <br />per minute or more sustained for more than ten days, Cotter will notify the <br />Division of the encounter and will work with the Division in addressing steps <br />to evaluate the prevailing hydrological balance, which may include wells and <br />a monitoring plan. <br />19. Page U -4(2) states that maps showing drill hole data are found in this exhibit. A map <br />showing drill hole data was not provided. Please submit 2 copies of a map that displays <br />drill hole data. <br />Figure U2 is included as Attachment 7. <br />20. Due to waste rock containing constituents at levels higher than federal, state and <br />agricultural levels, is any type of impermeable liner proposed below that waste rock pile <br />to prevent unpermitted discharges? <br />No liner is planned for the waste rock pile. The EPP provides a solid case for <br />the lack of any impacts to the environment from the waste rock pile. The <br />waste rock pile sits on low- permeability shales and mudstones of the Brushy <br />Basin member of the Morrison Formation. The low availability of moisture, <br />geochemical conditions, and low unsaturated hydraulic conductivity values <br />7 <br />