1997-05-27_REVISION - M1977493 ‎(4)‎

• Permit No: M1977493
• IBM Index Class Name: REVISION
• Doc Date: 5/27/1997
• Doc Name: Response to Adequacy Review
• From: Climax Molyb
• To: DMG
• Type & Sequence: AM3
• Email Name: ACS
• Media Type: D
• Archive: No

Allen Sorenson - DMG40
May 23, 1997
Page 2
For item iv), CIVIC makes note of the fact that the approved 1989 amendment did not
include the interceptor system.
Pipeline alignments have been included in the affected land area as have underground
boreholes and vent raises, Storke yard access roads, number 4-Dam, and various roads
established by and used in conjunction with the Climax operation.
4. Attached is the 3-Dam borrow area reclamation plan. The plan follows methods
approved of in the 1989 reclamation permit
5. A revised cost summary is attached that reflects acreage changes and required
Colorado DMG Administration cost factor of 5%.
6. A technical revision is pending to modify reclamation methodologies for the Climax
Mine. With this revision, CMC intends to modify the approach taken to soil development,
soil fertility, species and seed selection, and plant protection. In answer to the Division's
questions, yarrow has not been included in any seed mixes used to date. Furthermore,
seed application in 1994 Climax was adjusted upward to 100 pounds per acre following
the a germination and purity test of seed purchased in 1992. The adjustment equated to
a delivery of approximately 50 pounds PLS per acre.
7. Climax agrees that Rule 3.1.12(2) stating that boundaries of the affected lands shall
be clearly marked and adequate to delineate such boundaries is an impractical rule for
the Climax property. This was discussed with the Division following promulgation of the
rule. Due to the extent and shape of the property it would be an inappropriate use of
resources to clearly delineate all of Climax's affected land or property boundaries and
therefore, the boundaries have not been marked. An alternate plan for affected land
identification is as follows:
d) Upon authorization of Amendment AM-003, affected land boundaries will be
clearly delineated around all large construction projects in order to ensure the
protection of all non-affected lands.
e) Maps, clearly identifying all affected lands, shall be posted in conspicuous
locations where employees and contractors can identify the affected lands.
Project managers and equipment operators will be informed of the requirement to
avoid all disturbances on non-affected lands. The information will be delivered in
formalized descriptive literature attached to contractor policy packages and
employee policy manuals.
The Climax Mine property boundary is not marked except at vehicular access points to
the industrial facilities.
8. CIVIC appreciates the allowance to submit maps on a 1:12000 scale. Pursuant to
Rule 6.2.1(2), signatory requirements and dates have been included on the exhibit.