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Response to DRMS Adequacy Review (3) — Cotter SM -18 Mine Reclamation Plan Amendment <br />Cotter Corporation N.S.L. (Cotter) submits this response to the May 28, 2013 letter from Travis <br />Marshall, Division of Reclamation, Mining and Safety ( "DRMS ") to Glen Williams, Cotter. The <br />DRMS' comments are in italics and Cotter's responses are in bold. <br />Exhibit F <br />1. The revised Figures Fl and F2 submitted were signed and dated. However, the revised <br />version of Fl submitted does not portray an acceptable post mine configuration and the <br />contour lines do not show how the reclaimed area will tie into the adjacent non - disturbed <br />lands outside of the permit boundary. Please submit a revised Fl that displays the <br />proposed reclamation configuration with contours that accurately tie into the adjacent <br />non - disturbed land. <br />Attached is a revised Figure F1 showing proposed reclamation contours for the <br />south permit area in the vicinity of the Wright portal. <br />Environmental Protection Plan <br />2. Regarding the radiometric survey submitted. Please clarify the highest levels detected. <br />According to the survey figures provided in attachment 6 areas that are black are greater <br />than 120 uR/hr. <br />• The response provided states that the highest reading from the radiometric <br />survey was 751 uR/hr. Please provide a revised radiometric survey figure <br />that shows where the levels greater than 120 uR/hr are located and <br />identify the levels and location on the figure with contour intervals of 100 <br />uR/hr for levels greater than 120 uR/hr that cover the range of readings <br />up to > 750 uR/hr. Also, please display the permit boundary on the <br />revised figure. <br />• Specify what methods will be used upon reclamation to bring the radiation levels <br />back to the background levels (background levels are considered to be <br />radiometric readings from adjacent non disturbed lands.) <br />Attached are two maps showing the results of the radiometric survey conducted of <br />the north and south permitted areas including contour lines for contour intervals of <br />100 pR/hr, up to the maximum readings. <br />It is Cotter's understanding based on previous discussions with DRMS personnel <br />that it is the intent of DRMS to use the radiometric surveys that have been <br />submitted to determine the background radiation levels in the currently permitted <br />area. This approach takes into account the fact that the currently affected areas <br />were affected under an authorized reclamation permit which did not contain any <br />radiometric clean -up "standards ", either health based or arbitrarily arrived at, and <br />1 <br />