1997-06-03_REVISION - M1977493

• Permit No: M1977493
• IBM Index Class Name: REVISION
• Doc Date: 6/3/1997
• Doc Name: Second Adequacy Letter
• From: DMG
• To: Climax Molyb
• Type & Sequence: AM3
• Email Name: ACS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver,Colorado 80203
Phone:[phone]
FAX:[phone] iom
DEPARTMENT OF
NATURAL
/ RESOURCES
June 3 , 1997 V- Roy Romer
Governor
James S.Lochhead
Mr. Bryce Romig Executive Director
Climax Molybdenum Company Michael B.Long
Climax Mine Division Director
Climax, CO 80429
RE: Adequacy of the Amendment Application - Second Adequacy Letter,
Climax Molybdenum Company, Climax Mine, Amendment AM-003 Permit
No. M-77-493V
Dear Mr. Romig:
The Division of Minerals and Geology (Division) has completed a review
of your adequacy review response letter dated May 27, 1997 regarding
the above referenced amendment application, and has determined that
Climax Molybdenum Company (CMC) must address the following issues in
order for the application to meet the minimum requirements of the
Colorado Mined Land Reclamation Act (Act) and the Rules and
Regulations of the Mined Land Reclamation Board (Rules) . In order to
provide additional time to address the remaining issues, the Division
hereby extends the decision date for amendment AM-003 to June 16, 1997 .
This is in accordance with the terms of Rule 1 . 8; please note that
CMC' s last filing with respect to the amendment AM-003 application was
received at the Division' s offices on May 29, 1997 . If CMC requires
additional time beyond the June 16, 1997 decision date to address the
remaining issues, a written request for an extension must be submitted.
1 . In the May 27, 1997 adequacy response letter, CMC makes note that
the approved 1989 Climax Mine permit amendment did not include the
interceptor system in the area of affected lands. CMC' s observation
was made in relation to the Division' s position that reclamation of the
interceptor system, such as vegetation and weed control, would be
regulated under the Mined Land Reclamation Act . It is not clear
whether CMC is disputing this position in the May 27, 1997 letter, and
this matter must be clarified prior to approval of amendment
application AM-003 .
2 . The statutory requirement to include a 5 percent administrative
cost as a component of each reclamation bond dictates that 5 percent be
applied to the estimated cost of the total contract, rather than the
direct costs estimated as was done in the revised cost summary attached
to the May 27, 1997 letter. The administration cost at 5 percent needs
to be revised upward to $195, 951. 00, making the total amount of