2021-09-29_GENERAL DOCUMENTS - M1977493

• Permit No: M1977493
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 9/29/2021
• Doc Name: Revision Required
• From: Climax Molybdenum
• To: DRMS
• Email Name: LJW
• Media Type: D
• Archive: No

po Molybdenum Climax Mine
>` ° ® ClimaxMlbd y HWY 91 - Fremont Pass
A Freeport-McMoRan Company Climax, CO 80429
Phone [phone]
Fax[phone]
September 24,2021 7D
Mr.Lucas West SEP 2 y 20
Division of Reclamation,Mining and Safety 21
Department of Natural Resources DIVISION OF`1!:CLAMATION
1313 Sherman St. Room 215 MINING AND SAFETY
Denver, Colorado 80203
Re: M-1977-493,Climax Mine,Permit No. M-1977-493,Revision Required
Dear Mr. West:
Climax would like to thank you for the opportunity to meet with you on September 7, 2021 to
discuss your letter dated June 22, 2021 regarding designated chemical storage and Environmental
Protection Facilities(EPF)associated with the mill. We would like to confirm our understanding
of the next steps.
Climax appreciated the constructive discussion in which it was confirmed that the Division's
focus for purposes of review and permit revision is providing adequate containment of designated
chemicals, and not a change in the milling processes. Climax understands that the Division
requests a consolidation of information existing in separate earlier submittals and approvals with
additional information.
Climax stores designated chemicals in the mill,the storage and containment of which is regulated
by DRMS. The apron of the mill building serves as a secondary containment for the designated
chemicals used in the building and is an EPF under the existing EPP.As a result, Climax will
provide the following information on this EPF:
• Climax proposed to provide a general description of the mill process. Some of this
information is already included in AM-06,but to meet the Division's interest in having
information in one place, Climax will provide a submission that summarizes this information
that may include more detail from AM-06 in an attachment.
• As to environmental protection facilities,Climax agreed to provide:
o A summary of construction on the building apron, including a drawing. This drawing
does not have to be stamped by a professional engineer.
o Information on any coatings that may have been applied to concrete at the time of
construction,which also serve as containment.
o A summary of calculations to demonstrate that the various EPFs can contain
materials spilled in the event of a failure of equipment in the building, including the
designated chemical storage area.
The Division indicated that they are also interested in receiving information on the geochemistry
of tailings material generated from the mill. Climax and the Division agreed during the meeting
that TCLP is not the appropriate methodology to characterize tailings material. Climax will
submit information on tailings geochemistry provided in earlier submittals.
{00912573.1}