1997-06-06_REVISION - M1977493

• Permit No: M1977493
• IBM Index Class Name: REVISION
• Doc Date: 6/6/1997
• Doc Name: Second Adequacy Response
• From: Climax Molyb
• To: DMG
• Type & Sequence: AM3
• Email Name: ACS
• Media Type: D
• Archive: No

JUN-06-97 FRI 11 :11 P. 02/06
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j CLIMAX MOLYBDENUM COMPANY Gaumma
Climax mine
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A Divaicn of Ciays C�unmc M=js Ca 81
Climax Colorado 80249
June 6, 1997 (7191486.2150
Fax[phone],2251
Nand Delivered
Mr.Allen Sorenson
Divisio.%of Minerals and Geology
1313 Sherman Street, Room 215
Denve;, CO 80203
Dear 10 Sorenson:
The Climax Molybdenum Company (CMC) is in receipt of the Division's adequacy review letter of
June 3 received via facsimile on June 4, 1997. This letter serves as a point-by-point response to
the remaining issues required for approval of Amendment AM-003. Climax would appreciate
prompt review and approval of the amendment prior to the June 16 approval date due to
construction window constraints associated with the 3-Dam capping project.
1. CMC is not disputing the incorporation of interceptors into the affected land area or the
Climax Mine. Item number 3 (iv) of the Division's adequacy review letter dated April 20,
107, states that "...CMC has never requested, and the Division has never conducted, a
bona release type inspection of the interceptor system..' CMC is making the observation, for
the record, that the interceptors were not part of the bonded affected area in the 1989
An^r>:ndment, AM-002. AM-003 incorporates, and bonds, interceptors as affected land area
for Une Climax Mine.
2. Att.-:hed is a revised cost calculation for the financial warrantee using the 5% administration
cost of $195,951.00_ The total amount of bond adjustment for Amendment Am-003 is
$4,114,972. A rider for this increased financial warrantee is attached.
3. CMC suggests that the Division and CMC agree to address final slope criteria for the 3-Dam
borrow areas as reclamation occurs in the fall of 1997. The current reclamation plan for many
affected areas at the Climax Mine calls for grading to a 31-1:1V slope where practical. Where
practical and feasible, CMC is willing to discuss,with the Division, final slope configurat'.ans of
31-1:1 V for the borrow areas that recognizes the presence of indurated materials, the iFccess,
egress, and borrow area development conducted by the contractor. and borrow area
configurations with respect to the overall slope. Because the reclamation needs for the
bor,,�ow areas will not be known until the extent of disturbance has been determined, slope
con::derations for the disturbance can most pragmatically be evaluated after the disturbance
haE, ,iccurred. CMC concurs with the Division that slopes in the borrow areas are, generally,
lest -flan 2H:IV.
Thank you in advance for your prompt reply. Please contact me with any questions.
Sincerely,
1011"Bryce Romig
Environmental Coordinator
Climax Mine