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Response to DRMS Adequacy Review (3) — Cotter SM -18 Mine Reclamation Plan Amendment <br />the fact that it is not realistic to guess at what the background conditions were prior <br />to the mine area being affected by the current mining effort. <br />Cotter proposes to use a clean -up standard of 5 pCi/g Ra226 above background in <br />the first 15 cm of soil for determining the clean -up limit. If necessary Cotter can <br />place 6" —18" of clay based soils over any areas of concern to minimize potential <br />radiation exposures and potential leaching of uranium constituents into the <br />surrounding area. <br />During remediation, if radionuclide levels in the permit area are found to be above <br />acceptable levels, Cotter proposes to collect representative soil samples to determine <br />the amount of material to remove and place inside the mine portal as part of the <br />initial backfill material. <br />N <br />