1997-02-11_REVISION - M1977342

• Permit No: M1977342
• IBM Index Class Name: Revision
• Doc Date: 2/11/1997
• Doc Name: Procedural memo Bonding for Water Treatment
• From: DMG
• To: Climax Molybdenum Company
• Type & Sequence: TR6
• Media Type: D
• Archive: No

PROCEDURAL MEMORANDUM
Date: 2/6/97 Prep. By: ACS
Project: Henderson Mine
Operator: Climax Molybdenum Company
Permit No.: M-77-342
RE: Bonding for Water Treatment
ReQUlatorv Basis
Rule 4.2.1(4): The amount of the Financial warranty shall be sufficient
to assure the completion of reclamation of affected lands if the Office
has to complete such reclamation due to forfeiture. Reclamation
includes all measures taken to assure the protection of water
resources, including costs to cover necessary water quality protection,
treatment and monitoring as may be required by Permit, these Rules or
the Act.
Application of Rule 4.2.1(4)
In applying Rule 4.2.1(4) the Division may require that sufficient bond
be secured to allow the Division to manage and treat water during the
period of site reclamation such that compliance could be maintained
with applicable water quality laws, including compliance with existing
discharge permits for the site.
In terms of traditional surface reclamation, the Division may have to
maintain compliance with the existing site Storm Water Management Plan
by cleaning ditches and culverts, replacing silt fence and hay bales,
dredging sediment ponds, etc. In addition, the Division may have to
install new storm water management structures to prevent siltation of
surface water bodies during reclamation earthmoving. Once surface
reclamation is completed, the storm water permit is released as a
matter of course.
At sites where mining has intersected ground water, such as at the
Henderson Mine, the ground water must either be pumped from the mine,
or a drainage tunnel must be constructed to allow the ground water to
drain from the mine via gravity to allow continued operations in the
mine. If the water pumped or drained from the mine cannot be used for
mineral processing or disposed of in evaporation ponds or by land
application, a discharge permit would be required to release the mine
water into surface water bodies. At the Henderson Mine, water
treatment is required prior to release of the mine water in order to
comply with the terms of the discharge permit that has been issued. At
the conclusion of mining at the Henderson Mine, Climax Molybdenum
Company (CMC) may choose to continue pumping, treating and releasing
mine water since they hold the water rights, and the cost of pumping
and treating could be offset by the leasing of those rights to front
range water users. Also, by continuing to pump the mine CMC could
divert their west slope water holdings through the haulage tunnel for
sale on the eastern slope.
If the Division had to reclaim the site under a forfeiture situation,