2023-09-13_REVISION - M1977493

• Permit No: M1977493
• IBM Index Class Name: Revision
• Doc Date: 9/13/2023
• Doc Name: Adequacy Review Response
• From: Climax Molybdenum
• To: DRMS
• Type & Sequence: TR36
• Email Name: DMC
• Email Name: LJW
• Email Name: ACY
• Email Name: TJ1
• Email Name: THM
• Media Type: D
• Archive: No

® Climax Mine
Climax Molybdenum
Highway 91 - Fremont Pass
0429
A Freeport-McMoRan Company climax, ) 4 87718
p p y Phone {719) 486-7718
Fax [phone]
September 13, 2023
Mr. Dustin Czapla, Environmental Protection Specialist
Colorado Division of Reclamation, Mining and Safety
1313 Sherman St., Rm. 215
Denver, CO 80203
Re: TR-36 Adequacy Review Response—Climax Mine Permit No. M-1977-493
Dear Mr. Czapla:
The purpose of this letter is to provide additional information requested in DRMS's August 3, 2023, TR-36
Adequacy Review. The Division's comments are in italics with Climax's response following.
1. As indicated by Climax, the Environmental Protection Plan (EPP) will be inadequate and will
need to be revised. Pursuant to Rule 7.2.8, a revised EPP shall be submitted in the form of a
Technical Revision with the Required Revision Fee by December 15, 2023.
Climax commits to updating the EPP in the form of a Technical Revision and will contain the
required information for an Environmental Protection Facility. The submittal will include the
required fee and be submitted by December 15, 2023.
2. in conjunction with the updated EPP to be submitted by December 15, 2023, please submit
updated/revised Reclamation Plan and Maps as it pertains to this Environmental Protection
Facility(EPF). As well as any other features that have been modified to ensure the Plan and
Map(s) accurately reflect site conditions pursuant to C.R.S. 34-32-112(3).
Climax commits to submitting updated/revised Reclamation Plan and Maps in conjunction with
the EPP update.
3. The originally submitted narrative including the bullet point key project elements list does not
provide enough detail to accurately characterize the scope, purpose, and function of the
proposed EPF. Please provide a more detailed narrative, supported by additional and revised
drawings, discussing all aspects of the proposed EPF, pursuant to Rule 6.4.21(7). Please also
include directional flow arrows on all revised figures.
The attached narrative has been revised to include additional detail on the scope, purpose, and
function of the proposed EPF. Revised drawings are also included with directional flow arrows
where appropriate.
4. Please state where the three spoil piles and one topsoil pile which need to be relocated will be
placed. (Per drawing##6-807-00102 and##6-80 7-00 1 06) What is the estimated volume of the three
spoil piles needing to be removed?
The three spoil piles depicted on Drawing Nos. 6-807-00102 and 6-807-00106 are artifacts from
when the topography was last flown and have been previously removed. The topsoil pile has
also been relocated to adjacent to 5-Dam in preparation for spreading onto an un-reclaimed area
of the dam face in 2024.