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1- <br /> Climax Molybdenum Climax Mine <br /> � Highway 91 - Fremont Pass <br /> A Freeport-McMoRan Company Climax,one <br /> ppy Phone (719) 486-7718718 <br /> Fax (719) 486-2251 <br /> Sent by Certified Mail <br /> June 23,2014 <br /> Eric Scott <br /> RECEIVED <br /> Environmental Protection Specialist <br /> Division of Reclamation,Mining and Safety JUN 2 4 2014 <br /> Department of Natural Resources Division of Reclamation. <br /> 1313 Sherman St. Room 215 Mining&Safety <br /> Denver, Colorado 80203 <br /> Re: Second DRMS Adequacy Review of TR-Z3—Mayflower TSF Design,Stability and <br /> Operations and Monitoring Plan,and Modifications to the Tenmile TSF Operations and <br /> Monitoring Manual,Climax Mine,Permit No.M-1977-493 <br /> Y <br /> Dear Mr. Scott: <br /> This letter is in response to your June 10,2014 second adequacy review letter for Technical Revision 23 <br /> (TR-23)consisting of the Mayflower Tailing Storage Facility(TSF) 5 Dam Operating Condition, Seepage <br /> and Stability Analyses and Operations and Maintenance Manual(OMM),and modifications to the <br /> Tenmile TSF Operations and Maintenance Manual. This letter with responses and attachments will be <br /> included as an addendum to the TR-23 documents. <br /> The DRMS comments are in italic font followed by the Climax responses below. We also are including <br /> replacement pages(attached)to the Mayflower TSF OMM(Revision 1.1) in response to your first <br /> comment. Pending acceptance of these responses,we will transmit a complete electronic version of the <br /> OMM with replacement pages to you over the internet. <br /> Video InspectionslMonitoring of sub-drain Piping- <br /> In the response to adequacy letter Climax stated that annual video inspections of the CMP drains was <br /> "impractical and unnecessary". DRMS and DSB feel video inspection is a very useful tool to proactively <br /> monitor the condition of these critical features. However, DRMS would be willing to consider a proposal <br /> for a less frequent inspection schedule (every 2-5 yrs) if baseline video logging of the current existing <br /> conditions of the drains will support it. <br /> Response: The original Mayflower 5 Dam sub-drain collection system was video inspected by Climax in <br /> 2012. The video inspection indicated that sections of the main CMP collection line had failed. The main <br /> collection pipe was therefore replaced with HDPE pipe in 2013. Attempts were made to video the smaller <br /> laterals. However, sharp angles and debris in some of the pipe prevented access to video inspect the <br /> entire system. The video did show that flow was coming from each of the laterals. Climax will <br /> implement a program to video inspect the main sub-drain collection system at 5 Dam every 5-years or <br /> sooner if there is a large variation in monitored flows entering the collection box. The pipe will be video <br /> inspected for condition of the pipe, obstructions, scaling or other issues that could impact flow. <br /> Annual Reporting and Certification of TSFs <br /> DRMS initially requested that the annual TSF inspection/evaluation/certification report be submitted to <br /> DBMS within 30 working days of the inspection. Climax has requested that the report be included with <br /> the standard annual reporting for the site. DRMS will allow the submittal of the TSF certification report <br /> with the other annual reporting if Climax will commit to noting DRMS within 30 days of the inspection <br />