2011-03-14_REVISION - M1977493 (57)

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Permit Amendment (AM-06) - Climax Mine CM0000498 AM-06-T-02. • As discussed previously, the Climax Mine site lies within the headwater areas of three watersheds - the East Fork of the Arkansas River, the East Fork of the Eagle River, and Tenmile Creek, with most of the mine's water treatment/management activity occurring within the Tenmile Creek drainage area. Discharge to Tenmile Creek occurs in accordance with CDPS Permit No. CO-0000248. Before Climax implemented its current water treatment/management system in the 1960s, there was a near complete absence of stream life in Tenmile Creek upstream of its confluence with West Fork Tenmile Creek near Copper Mountain. These conditions were attributable primarily to acid mine drainage from historic mining activity within the headwaters area of Tenmile Creek. Over the past 40 years, Climax has implemented a water treatment/management system in the Tenmile headwaters area, which has included reclamation of many historic mining sites, and capture and treatment of impacted waters from many inactive mines in the drainage area. Since Climax has implemented its water treatment/management scheme, Tenmile Creek has recovered to support a viable and reproducing fishery downstream from the point of the Climax outfall. The complete responsibility accepted by Climax for water treatment/management within the headwaters area of Tenmile Creek is reflected in the Water Quality Control Commission's 1987 rulemaking regarding the Climax outfall, in which the Commission stated: The evidence in these proceedings on Ten Mile Creek have shown that Ten Mile Creek for all intents and purposes begins at the Climax property boundary at a place designated as the "Parshall Flume." It is at this point that the natural flows that are intercepted by Climax in the Ten Mile Creek Basin are channeled together and form the source of Ten Mile Creek. Hence the Commission believes Parshall Flume to be the source of the mainstem of Ten Mile Creek. Also included in this segment are all tributaries to Ten Mile Creek including those natural tributaries intercepted by Climax. (5 CCR 1002-33.11 & 33.16) Stormwater management information for the Climax Mine site is discussed throughout this EPP. Stormwater is managed in accordance with Stormwater Permit COR-040178. T-8 Climate and Air Quality Information regarding climate as required in the EPP Rules is presented in Exhibit K - Climate Information of this amendment AM-06. In addition, details regarding air emissions and the fugitive dust control plan are found in the Construction permit issued by the Air Pollution Control Division of the CDPHE. T-9 Geochernical Information As discussed in Section T-4.1.2, Climax accepted the DRMS determination that the three TSFs and the OSFs contain materials that are acid-forming and from which acid drainage could occur. Thus, based upon discussions with DRMS personnel, development of specific geochemical data for these facilities are not necessary. Data regarding geochemistry of Climax tailing, McNulty OSF, E and F Dumps, the process facility/mine yard area, and the Storke Yard area has been provided in previous submittals. The Storke Yard and the process facility/mine yard areas contain materials potentially conducive to acid generation. Acid-base accounting analyses were used to test samples from various depths in the yard. The results of these tests have been provided previously. Data for the Storke Yard indicate that, while spots exist that are potentially acid producing, these fill materials generally are low in sulfur and have acid neutralization potential in excess of three times the acid generating potential. However, the opposite appears to be the case for the process facility/mine yard area where samples indicate excess acid generating potential over acid neutralizing potential. T-10 Construction Schedule Prior to restarting mineral extraction and production at the Climax Mine, additional construction activities will occur. A defined schedule for these activities has not been developed at this time. Once a Exhibit T T-26 May 2010