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2011-03-08_REVISION - M1977493
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2011-03-08_REVISION - M1977493
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Last modified
6/15/2021 5:47:16 PM
Creation date
3/10/2011 7:24:03 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977493
IBM Index Class Name
REVISION
Doc Date
3/8/2011
Doc Name
Response to July 8, 2010 Letters
From
Climax Molybdenum
To
DRMS
Type & Sequence
AM6
Email Name
ECS
Media Type
D
Archive
No
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I . Potential impacts from movement and quality of ground water tributary to Eagle Park Reservoir: <br />The Reservoir Company and Eagle Entities have expressed concern that CMC's plan to eventually raise <br />the No. 3 Dam on the Tenmile Tailings Storage Facility (TSF) by approximately 28 feet could cause a <br />change in flow direction of the ground water, potentially allowing seepage from Tenmile TSF to enter the <br />Eagle River drainage and to affect water quality in the Eagle Park Reservoir. <br />CMC Response: Existing systems are in place to collect seepage from No. 1 Dam, on the south side of <br />the Tenmile TSF, and direct collected water to the water management and treatment system. Existing <br />monitoring and collection systems are in place, including a Water Quality Monitoring Plan submitted as <br />part of TR-08. CMC recognizes that refinement of the Groundwater Monitoring Program will be <br />addressed in a future submittal for review and approval by DRMS before full-scale mining and milling <br />operations resume. Although no impacts are expected to Eagle Park Reservoir, CMC will examine the <br />hydrologic conditions in the area of concern and will incorporate into the refined Groundwater <br />Monitoring Program submittal to DRMS any additional monitoring measures deemed necessary by CMC <br />to provide further protection of surface water. <br />2. Potential impacts from additional storage of process water in Robinson Lake and potential <br />failure of the Robinson Reclaim Pipeline: The Reservoir Company and the Eagle Entities expressed <br />concern that the current Robinson Lake Seepage Pump Station may not be adequate to collect increased <br />seepage associated with the planned increase in storage in Robinson Lake, and that water quality in the <br />Eagle Park Reservoir could be negatively impacted from this seepage or if the planned Robinson Lake <br />Reclaim Pipeline were to fail. <br />CMC Response: During the completion of the Eagle Park Reservoir reclamation work in 1997, a cutoff <br />wall was installed between Robinson Lake and the Eagle Park Reservoir. The Robinson Lake Seepage <br />Pump System also is currently in place at the toe of the Robinson Dam at the cutoff wall. The Robinson <br />Lake Seepage Pump System consists of a seepage collection system, pump station and pipeline that <br />convey seepage water to Robinson Lake. This facility is an identified Environmental Protection Facility <br />approved by DRMS in the Climax Environmental Protection Plan in CMC's permit, and is regulated and <br />inspected by the DRMS as such. <br />The Robinson Lake operating level may increase by up to four feet when operations resume. Although <br />some increase in seepage could occur from the increase in hydraulic gradient, the seepage collection <br />pump system is sized with sufficient capacity to capture any increased seepage (by over a factor of 10) <br />resulting from the increase in water stored in Robinson Lake. Also, ground water quality has been <br />measured at the Robinson Lake Seepage Pump System and from a monitoring well located downgradient <br />from the cutoff wall, and water quality at the pump system has improved substantially since the <br />installation of the cutoff wall in 1997 and continues on this trend based on monitoring from the well. <br />With regards to potential failure of the Robinson Lake Reclaim Pipeline, if that were to occur, CMC <br />engineered systems include containment and other measures to provide notice of possible leakage. A <br />failure of the pipeline above the point where it passes the Robinson Dam Spillway (approximately 19,000 <br />feet of pipeline) would be contained in Robinson Lake, or other process water facilities if the failure <br />happens further up the line (e.g. Robinson TSF). There is an approximately 1,180 foot long section of the <br />pipeline between the new pump station and the point where it crosses Robinson Dam Spillway. A failure <br />in this section would report to the Robinson Lake seepage collection system. This seepage pump system <br />has enough capacity to contain a large leak in this section of the pipeline. Instrumentation and alarms <br />also would be triggered if there is a high level in the seepage collection pond, indicating a pipeline leak. <br />2
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