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1\ +/`' •{ • (Page 3) MINE ID of` OR PROSPECTING ID ~` M-77-493 INSPECTION DATE 9 15 94 INSPECTOR'S INITIALS ACS The Storks Yard Complex was visited. Extensive building and facility demolition was completed this summer in accordance with the approved reclamation plan. The Reclamation Permit anticipates on-site disposal of the demolition debris, however it was agreed that the specifics of the debris disposal plan should be reviewed by DMG. The specifics have been submitted and the review is in progress at the time that this report is being written. The operator intends to relocate-the pump station for de-watering of the underground workings of the Climax Mine to a higher level. This will result in flooding of a large portion of the underground workings. it was agreed that specifics of this plan will be submitted for DMG review, particularly in terms of the potential for surface or groundwater impacts that could result from mine flooding. It was further agreed that the Division would inspect the underground workings prior to flooding. This inspection has been scheduled for October 17, 1994. A meeting took place with mine and mill pereonel to discuss the necessary components of the Environmental Protection Plan (EPP) required for Climax. The EPP for thin site will largely consist of identification of locations and facilities that pose the potential for off-site impacts to be caused by designated chemicals, acid or toxic materials or acid mine drainage (note that off-site does not necessarily refer to the permit boundary), and detailed descriptions of facilities designed to contain or prevent such impacts. The question arose as to the extent of geochemical testing required for existing operations in order to develop their EPP. It is the Division's view, that if the operator concedes that any overburden, waste rock, mill tailings, waste water treatment sludge, or other mined placed, disposed or stockpiled material is an acid or toxin generator, geochemical tenting, in general would not be required. The Division can envision instances when geochemical evaluation would be necessary to determine if proposed reclamation measures or environmental protection facilities are appropriate or adequate, but these instances can be handled on a site specific or case by case basis. Mined, disturbed or exposed earthen materials that do not have the containment of an environmental protection facility will have to be sampled and evaluated in terms of the potential for adverse geochemistry. The question arose as to the time frame for the requirement of certified designs for existing operations that are Designated Mining Operations (DMO) (Rule 6.4.19(10)). It is the Division's view that the requirement for certified design submittal ie not activated until the EPP ie approved (see Rule 7.3.1(4)). However, the Division recommends that operators collect and maintain documentation of the design and construction of any facilities that may fit the definition of an Environmental Protection Facility designed or constructed during the interim period between DMO designation and EPP approval. The Robinson tails capping is probably the largest reclamation project underway at a permitted mine site in Colorado for this year. The Division would like to commend Climax personel for this and other on-going reclamation efforts. No problems were noted during this inspection. cc: Carl Mount, DMG Dori J. Webb Administrative Assistant Summit County Government P.O. Box 68 Breckenridge, CO 80424 I & E Contact Address ^ CE NAME Bruce Romic ^ BL OPERATOR Climax Molvbdenvm Co. ^ FS STREET Climax Mine ^ HW CITY/STATE/2IP Climax. CO 80429 ^ HMWMD (CH) ^ SE ^ WQCD (CH) `OTHER