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STATE OF COLOMDO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 COLORADO <br /> <br />Phone: (303) 866-3567 D I V I S I O N O F <br /> <br />FAX: (303) 832-8106 RECLAMATION <br /> MINING <br /> <br /> SAFETY <br /> <br />May 22, 2008 c/ Bill Ritter, Jr. <br /> Governor <br />Mr. Ken Kloska Harris D. Sherman <br />Climax Molybdenum Company Executive Director <br /> <br />Climax, CO 80429 Ronald W. Cattany <br />/ Division Director <br /> Natural Resource Trustee <br />RE: Review of Technical Revision TR-15, Climax Mine, Permit No. M-1977-493 <br />Dear Mr. Kloska: <br />The Division of Reclamation, Mining, and Safety (DRMS) has reviewed the application for TR-15, and has identified <br />the following issues to be addressed prior to approval. <br />1. It is stated in section 3.3 of the TR-15 application native soil excavated from Robinson Lake will be hauled to <br />and stockpiled on 1-Dam crest for later use in reclamation. The DRMS is supportive of this aspect of the <br />plan; use of native soil excavated from Oxide Pond during the Eagle Park Reservoir project has benefited <br />reclamation along the Highway 91 frontage. However, DRMS will require sampling and analysis for metals <br />and agronomic properties prior to deployment of the materials from the 1-Dam stockpile, and may limit the <br />locations for use of this material depending on the results. Metals analysis, at a minimum, must include lead, <br />manganese, zinc, copper, cadmium, and total metals digestion. Also, if the soil remains in stockpile in <br />October 2008, DRMS will require that it be seeded prior to the end of the month. <br />2. Section 3.5 of the TR-15 application states that areas to be revegetated following the completion of the <br />project will be seeded with perennial rye. This type of seeding is suitable for areas requiring interim <br />stabilization and that will be redisturbed in the near term for some other pending project, such as the stockpile <br />discussed in item no. 1 above, but is not suitable for areas to be revegetated over the longer term. Please <br />provide a rationale for seeding with rye only, or commit to seeding with the Climax seed mix that is approved <br />in the permit at the time that the seeding occurs. <br />The decision date for TR-15 is June 18, 2008. Please respond to the issues listed above sufficiently in advance of the <br />decision date to allow time for DRMS review. DRMS can approve or conditionally approve TR-15 prior to the <br />decision date once the above listed issues are satisfactorily addressed. If you have any questions, please contact me at <br />303-8664063 or by email at allen.sorenson(a)state.co.us. <br />Sincerely.; <br />1 Ien C. Sorenson <br />Reclamation Specialist <br />cc: Gary Slifka, Climax Mine, via email <br />c:\acs files\My Documents 4-19-06 thru\climax trl5 review.doc <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines