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Page 4 of 4 <br />neither DRMS nor the Summit County Emergency Manager were listed as contacts on the daily inspection <br />checklist form. Is the Tailings Engineer /Supervisor responsible for appropriate emergency notifications? <br />Contingency Planning/Data Review <br />Has Climax conducted any failure scenario modeling /contingency planning to determine what the potential <br />impacts /results of a partial or complete TSF failure would likely be? Have other failure modes such as piping or <br />overtopping been considered during this design? If it has not already been done, is recommended that the owner <br />and the engineer closely review all past records to identify any reports of unusual events that could affect the <br />safety of the proposed dam and impoundment. Such events could include plugged or failed drains, unusual or <br />uneven settlement, sinkholes or slumping on the dam or the beaches, elevated piezometer readings, episodes of <br />increased and /or cloudy seepage discharge, etc. There is brief mention in the executive summary of the SSA that <br />historical data was for the facility was reviewed in 2007, but there was no mention of any more recent <br />comprehensive data review. <br />This concludes the Division's adequacy review of TR23. This letter shall not be construed to mean that there are no <br />other technical issues in the submittal. Other issues may arise as additional information is supplied. As stated <br />previously, DRMS is committed to working with Climax to implement a "best available practice" approach for the <br />TSFs at this site that will allow mining to continue while implementing all reasonable protections in compliance <br />with DRMS rules. As stated previously, DRMS is open to additional meetings with Climax if it would be useful to <br />help resolve any remaining issues. <br />If you have any questions, please contact me at (303) 866 -3567 x8140. <br />Sincerely, <br />Eric Scott <br />Environmental Protection Specialist <br />