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V <br /> Climax Molybdenum Climax Mine <br /> Hwy 91 —Fremont Pass <br /> Climax, CO 80429 <br /> A Freeport-McMoRan Company Phone(719)486-2150 <br /> Fax(719)486-2251 <br /> Sent by Certified Mail <br /> November 21, 2016 <br /> Mr. Eric Scott, Environmental Protection Specialist <br /> �T <br /> Colorado Division of Reclamation, Mining and Safety NUU � 1U1 <br /> 1313 Sherman St., Rm. 215 <br /> Denver, CO 80203 DIV buy 1°- i.)r RECLAMATION, <br /> MININti ^'-MINERALS <br /> RE: Notification of Reagent Change - Climax Mine Permit No. M-1977-493 <br /> Dear Mr. Scott: <br /> Climax currently uses Nalco 8836 Plus as our primary frother reagent. We would like to begin using <br /> Nalco Froth Pro 509 in place of the Nalco 8836 Plus in mid-December. Section T-3.1 of the <br /> Environmental Protection Plan (EPP) submitted as Technical Revision 24 lists Nalco 8836 Plus "or <br /> similar" as the primary frother reagent. Based on recent testing, Climax identified Nalco Froth Pro <br /> 509 as a more efficient frother for our process. Since both reagents come from the same chemical <br /> feedstock they are considered to be similar. Froth Pro 509 (MSDS attached) is removed higher in <br /> the distillation column than 8836 Plus, changing the ratios of the primary constituents, which remain <br /> as straight chained aliphatic alcohols, aldehydes, and esters. Both reagents produce a froth to float <br /> the molybdenum concentrate to the surface of the floatation cell, and both reagents will mostly <br /> adhere to the molybdenum concentrate that is shipped off site. We recently requested and were <br /> granted approval to use this reagent by Colorado Department of Public Health and Environment - <br /> Water Quality Control Division with no changes necessary in the monitoring requirements of our <br /> CDPS permit (C00000248). <br /> Given its chemistry, this new reagent is essentially the same as the currently approved frother and <br /> we do not believe that an update to the EPP is necessary. However, based on our previous <br /> discussions with you on this new reagent, our understanding is that DRMS will allow this permanent <br /> change immediately, but that you may still require a revised EPP listing this new reagent. As you <br /> know we are contemplating a revision to our Water Quality Monitoring Plan(WQMP)to be <br /> submitted as a Technical Revision to the Reclamation Permit. We propose to provide you with an <br /> updated EPP that includes this new reagent when we submit the revised WQMP. The timeframe for <br /> this submittal to DRMS is anticipated to be in the first quarter of 2017. <br /> Sincerely, <br /> Raymond Lazuk <br /> Environmental Manager <br /> attachment <br /> 67 <br />