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iii niniiuiiu iii • <br />999 <br />DIVISION OF MINERALS AND GEOLOGY <br />DeV.lnmenl u( Nahrt~J Rrooun c. <br />I { I .l Sharnl.tn 51 , Koum ! 15 <br />Denver, Colorado NIl!0 4 <br />Phone I1(I 11 N6L 1567 <br />FAY L{Oll N1!~N 111E <br />October 2, 1996 <br />• <br />STATE OF COLORADO <br />I~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Guvemor <br />Ms. Anne Beierle lame.s.f«nhe.,d <br />E rcc utive Dueuor <br />Climax Molybdenum Company <br />P . O . Box 6 8 mlchael8 Lang <br />Drvi.~on Director <br />Empire, CO 80438 <br />RE: Alternate Reclamation Plan, Nenderson Mine, Technical Revision TR- <br />006, Permit No. N-77-342 <br />Dear Ms. Beierle: <br />The Division has reviewed the above referenced technical revision <br />submittal, and requests that the following issues be addressed and <br />clarifications provided prior to revision approval. <br />1. It needs to be clarified that this is an alternate reclamation plan <br />to be followed by the Division in the event of bond forfeiture, and <br />understood that in order to approve this plan for implementation by Climax <br />Molybdenum Company (CMC), the appropriate permit amendments and revisions <br />necessary to address the impacts of mine flooding would have to be <br />approved, including, but not limited to, a technical revision providing <br />design details for the haulage tunnel bulkhead. Although it is not <br />necessary to provide a design for the bulkhead at this time, certain <br />details related to bulkhead design will need to be addressed as part of <br />the pending technical revision TR-006. Specifically, the approximate <br />length necessary for the bulkhead to be effective needs to be established <br />in order to estimate installation costs. This aspect of bulkhead design <br />is discussed below. <br />2. Please provide a justification for CMC's selection of a three year <br />time period for bonding to cover pumping and treating of Henderson Mine <br />water. The May 31, 1996 letter from the Division to CMC states that bond <br />needs to be posted "sufficient to allow the Division to operate the <br />Henderson Mine water treatment facilities during the period of <br />reclamation", and the 1977 reclamation plan for the Henderson Mine states <br />that reclamation of the mine site is anticipated to take 6 years, with an <br />additional 5 years for vegetation establishment. If an additional year <br />is added to account for the time necessary for the Division to plan and <br />contract the work, the total period of reclamation could be 12 years. <br />3. It is stated in Section 2.3.2 of the TR-006 submittal that once the <br />haulage tunnel bulkhead is installed, the 200-300 gpm of water entering <br />the mine through the tunnel would be halted. This implies that all of the <br />