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CM0000660 <br />Mr. Eric Scott <br />Climax Mine - Response to DRMS Adequacy Review Comments <br />• Permit M-1977-493; Amendment AM-06 <br />March 1, 2011 <br />Page 15 of 16 <br />Response: Please refer to response to comment on Exhibit D. <br />Rule 6.5 Comment 2: What is the monitoring/documentation program that has been implemented <br />to monitor for stability issues that may occur in the OSF and TSF dams during construction, <br />operation and maintenance (phreatic surface monitoring, permanent inclinometers, etc)? This <br />monitoring/documentation protocol should be clearly specified, and will be included as an <br />enforceable condition of the permit when approved. <br />Response: The monitoring program to be employed will be incorporated into the final design <br />submittals for these facilities. Additional geotechnical evaluations of the OSF areas are being <br />conducted in 2011, the results of which will be used to finalize stability evaluations and determine, <br />what types of monitoring will be necessary. <br />Rule 6.5 Comment 3: The introduction of the Geotechnical Stability Exhibit submitted with AM-06 <br />states that the information submitted is a preliminary overview, and that the design at this time is <br />not considered final. Obviously the long-term stability of the OSF and TSF features is a primary <br />concern of the Division. While the preliminary evaluations appear in order, DRMS does not <br />review/approve "preliminary designs" and will therefore require final design specification evaluation <br />and approval before the site resumes mining and additional material is placed in the existing TSF <br />or OSF facilities. Please consolidate and provide the CPT and laboratory data protocols and <br />reporting referenced and used in the preliminary design modeling. Also, when submitting the final <br />design specifications and evaluations, complete dynamic loading analysis for the TSF features will <br />be required. These final design specifications and stability evaluations may be subject to third <br />party review as outlined in Rule 7.4.3. <br />Response: As described in the Rule 6.5 Exhibit and in previous comment responses, CMC has <br />committed to providing final engineering design to the Division. The design submittal and <br />geotechnical analyses will be submitted to the Division prior to resuming full-scale mining and <br />milling operations, and will include appropriate documentation of site investigation information <br />relied upon for the analyses. <br />Rule 7.3 - Environmental Protection Facilities - Design and Construction Requirements <br />Rule 7.3 Comment: Climax should review these sections of the rule carefully to determine if <br />ongoing and planned construction activities (mill facility, new pumping facilities, EPF's etc.) and <br />the associated required submittals and certifications are being carried out in compliance with these <br />requirements. <br />Response: Comment acknowledged. <br />0 <br />