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Climax Molybdenum Climax Mine <br /> y HWY 91 - Fremont Pass <br /> A Freeport-McMoRan Company Climax, CO 80429 <br /> Phone (719) 486-2150 <br /> Fax(719) 486-2251 <br /> August 11, 2021 RECEIVED <br /> Mr. Lucas West <br /> Division of Reclamation,Mining and Safety AUG 13 2021 <br /> Department of Natural Resources <br /> 1313 Sherman St. Room 215 = .E Cl AMATION <br /> Denver, Colorado 80203 <<a,.:r«4U SAFETY <br /> Re: M-1977-493,Climax Mine,Permit No. M-1977-493,Revision Required <br /> Dear Mr. West: <br /> This an interim reply to your letter dated June 22,2021. It appears to be a follow up on some of <br /> the issues we discussed with you when you were at the mill on June 1, 2021. <br /> Climax is studying the detailed implications of your letter as well as the detailed history of the <br /> above referenced permit in order to be in a position to discuss the issues identified and requests <br /> made. <br /> But,we did want to provide our preliminary view that the entire mill building is not appropriately <br /> considered an Environmental Protection Facility(EPF). Rather, only the identified reagent <br /> storage and containment areas are EPF's. Drawings of such areas are included in the EPP. <br /> Historic Technical Revisions have identified these areas in the many submissions to the Division. <br /> Rule 1 of the Hard Rock/Metal Mining rules defines an EPF as a structure identified in the <br /> Environmental Protection Plan(EPP)"as designated, constructed and operated for control or <br /> containment of designated chemicals, [etc.]." Only segments of the Climax mill building qualify <br /> under this definition, as the majority of the mill is constructed and operated to process and extract <br /> minerals. <br /> Following our review of the history of the permit, we ask for an opportunity to discuss the issues <br /> with the Division, including the appropriateness of the suggestion that a Technical Revision is <br /> needed. We understand that even though the letter uses the word"determination,"it is not a final <br /> decision of the Division. That is welcome information, as we look forward to responding to <br /> issues raised in the letter and discussing our questions and concerns with the Division. <br /> Climax has enjoyed a long collaborative working relationship with the Division and is confident <br /> that we will be able to work through the questions and issues you raise. <br /> If you have any questions or concerns, please contact me at 719-486-7525. <br />