2011-03-14_REVISION - M1977493 (64)

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CM0000659 Mr. Eric Scott Climax Mine - Response to DRMS Adequacy Review Comments Permit M-1977-493; Amendment AM-06 March 1, 2011 Page 14 of 16 Construction of the TSF will be accomplished concurrent with production as tailing is deposited incrementally with embankment raises constructed using the upstream method of tailing dam construction, as described in Exhibit D. As described in Exhibit D and the Geotechnical Stability Exhibit (Rule 6.5) final engineering designs for the TSFs have not yet been completed. The final design documents will incorporate appropriate QA/QC processes and procedures to be employed during operation to ensure proper construction. This information will be provided in future submittals in accordance with Rule 7.3. The OSFs have not been identified as EPFs, however, appropriate geotechnical stability information has been provided in the Geotechnical Stability Exhibit and additional information will be submitted as necessary. Exhibit U/Section 18(b) Comment: Describe measures to prevent wildlife from coming into contact with designated chemicals, toxic or acid forming materials, or areas with acid mine drainage. Have any measures been implemented to exclude wildlife from areas of impacted waters of low pH and/or high metals content, treatment sludge deposition areas, or areas where water treatment processes are active? If so, please describe and specify with maps as appropriate, if not, please justify why this has not been done. Response: All designated chemicals will be properly stored inside of structures to eliminate exposure to wildlife. Measures to prevent wildlife from coming into contact with toxic or acid forming materials or areas with acid mine drainage consist of concurrent reclamation as discussed in the Exhibit H response to comments, Item 5. Due to the large size of the areas and the fact that CIVIC materials and process water have not been identified as a problem for wildlife during decades of operation, no measures to exclude wildlife have been determined to be necessary. Wildlife species, including large mammals, waterfowl, and shorebirds are commonly observed throughout the property without evidence of apparent harm. Exhibit U Supplemental Comment (received January 28. 2011): The Division believes that the OSF areas and the existing clean water diversion ditches clearly meet the definition of EPFs and therefore should be called our as such in the EPP. DRMS is willing to discuss the implications of this, especially with regard to the pre-existing diversion ditches, and work with Climax to identify how to best satisfy the requirements for these EPFs. Response: As discussed during the February 4, 2011 meeting with DRMS, CMC will work with DRMS to adequately describe these features in a revised EPP to be submitted to DRMS for review and approval before full-scale mining and milling operations resume. Rule 6.5 - Geotechnical Stability Exhibit Rule 6.5 Comment 1: Please address blasting program compliance as requested in comment for 6.4.4(1) 0