2003-05-18_REVISION - M1977342 (2)

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CLIMAX MOLYBDENUM COMPANY ~ &Midry a Nrq D~ Gorpanuan March 7, 2003 Certified Mail No. 7002 0510 0000 5652 2135 Chairman Colorado Mined Land Reclamation Board Henderson Ooerations P.O. Box 6B Emp~ro. Cobretlo BD438 [303)569-3221 Fex (3031569-2830 RECEIVED MAR 18 2003 ~~ Division of Minerals and Geolo9Y 1313 Sherman Street, Room 215 Denver, Colorado 80203 Re: Henderson Mine and Mill Permit -77-342 evisions to Amendment A~M-0~4 ~`// -- '~~ Dear Mr. Chairman: Climax Molybdenum Company, Henderson Mine and Mill ("Henderson") is requesting the following changes to AM-04, submitted to the Colorado Division of Minerals and Geology on January 14, 2003. Revision of 100 Percent Dry Cover Reclamation of Tailing Impoundment to 70 Percent Water Resource Reclamation In AM-04, section 2.4, Henderson proposed to revise the plan for reclaiming the current tailing impoundment with 100 percent dry cover. Instead, we offered a plan that would create a developed water resource over approximately 70 percent of the impoundment, with the remaining 30 percent of the impoundment being reclaimed under the dry-cover scenario. In our AM-04 request, we specified that Henderson would submit a Technical Revision (TR) at a later date to provide DMG with engineering design and other information necessary to evaluate this alternative and determine the relevant changes in the financial warranty (FW). Rather than submit a TR request, Henderson proposes to provide this additional information in a subsequent permit amendment. Henderson is proposing the use of the amendment process in order to allow public review and dialogue on the details of awet-cover. Revision of Tree and Sbrub Planting In AM-04, section 2.2, Henderson proposed to plant lodgepole pine or shrnbs at a rate of 50 per acre. Henderson requests that this proposed revision be eliminated, and that the tree and shrub planting be done in accordance with standards specifed in Section 9.2 of Henderson's original 1977 reclamation plan. Additionally, Henderson requests that plans to plant trees and shrubs on the reclaimed tailings deposition area (area 9) be eliminated. Based on our experiences at Urad and Climax, we expect close to 100% failure of trees and shrubs in this area. As an alternative, we propose the following: Construct "islands" of thicker cover on portions of the reclaimed tailing areas using material from the coarse ore stockpiles. Henderson would then plant trees and shrubs on these islands.