2014-06-10_REVISION - M1977493

• Permit No: M1977493
• IBM Index Class Name: Revision
• Doc Date: 6/10/2014
• Doc Name: Second Adequacy Review
• From: DRMS
• To: Climax Mine
• Type & Sequence: TR23
• Email Name: ECS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St,Room 215 D O L D RA D O
Denver, Colorado 80203 D I d t S t O N OF
Phone [phone] REMI NGON
FAX:[phone] —&—
SAF ETY
John W Hickenlooper
Governor
June 10,2014
Mike King
Executive Director
Climax Mine
Attn: Mr. RayLazuk Loretta Pineda
Director
Highway 91
Climax,CO 80429
RE: File M1977-493; Climax Mine; Second Adequacy Review of Technical Revision 23 (TR23)—Mayflower
TSF Design, Stability and Operations and Monitoring Plan, and Modifications to the Tenmile TSF
Operations and Monitoring Manual
Mr. Lazuk:
The Division of Reclamation, Mining and Safety received Climax's responses(dated May 21,2014)to the initial
adequacy review(dated February 2014)for Technical Revision 23—Mayflower TSF Design, Stability and
Operations and Monitoring Plan, and Modifications to the Tenmile TSF Operations and Monitoring Manual
submitted to DRMS on October 15,2013. DRMS and DSB have reviewed the responses provided and have
found them to be satisfactory with only a few exceptions. The first is the response to the request for video
monitoring of the CMP sub-drain piping. DRMS is also requesting some additional clarification of the fault
inventory utilized for the PSHA submittal for the site,and the annual reporting and certification for the TSF
facilities. These items are discussed in additional detail below. At this time DRMS and DSB consider all other
adequacy issues to have been sufficiently addressed.
As before, DRMS/DSB would also be willing to meet with Climax to discuss these comments if further
clarification or discussion is needed, and DRMS anticipates that as mining continues at this site that development
of TSFs will evolve based on the implementation of additional items and best practices,the collection of
additional data, field conditions, and ongoing discussions between DRMS and Climax.
Video Inspection/Monitoring of sub-drain piping
In the response to adequacy letter Climax stated that annual video inspections of the CMP drains was"impractical
and unnecessary". DRMS and DSB feel video inspection is a very useful tool to proactively monitor the
condition of these critical features. However, DRMS would be willing to consider a proposal for a less frequent
inspection schedule(every 2-5 yrs) if baseline video logging of the current existing conditions of the drains will
support it.
Annual Reporting and Certification of TSFs
DRMS initially requested that the annual TSF inspection/evaluation/certification report be submitted to DRMS
within 30 working days of the inspection. Climax has requested that the report be included with the standard
annual reporting for the site. DRMS will allow the submittal of the TSF certification report with the other annual
reporting if Climax will commit to notifying DRMS within 30 days of the inspection(or sooner if possible)of any
issues identified in the inspection report that require corrective actions or modification to the existing approved
TSF plans.
PSHA/Fault Inventory
In general, DRMS and DSB agree that the PSHA is very well done; however,there are a few items that will
require some clarification. The first appears to be a"typo" in the fourth line of the second paragraph of page 4
Office of Office of
Mined Land Reclamation Denver-Grand Junction•Durango Active and Inactive Mines