2011-03-14_REVISION - M1977493 (64)

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CM0000652 Mr. Eric Scott Climax Mine - Response to DRMS Adequacy Review Comments Permit M-1977-493; Amendment AM-06 March 1, 2011 Page 7 of 16 Exhibit L - Reclamation Costs Exhibit L Comment: Exhibit L is under review by the Division at this time. At this time the provided estimate looks reasonable, however, pending changes to other areas of the amendment may impact the reclamation cost estimate. Due to the scope and detail of the reclamation estimate, a meeting between Climax and DRMS may be beneficial to discuss this Exhibit. Response: CMC attended a meeting with the Division on January 25, 2011 to further discuss the reclamation costs provided. Updated cost tables and a new narrative on reclamation cost calculations are attached. Suoplemental Comment (Received January 28, 2011): With respect to the bond calculation discussion on January 25, 2011, DRMS will accept a °clean slate" approach to the Exhibit L calculations in AM06. DRMS will still need comprehensive documentation for the resulting bond amounts, both for existing work to complete, and for reclamation associated with proposed new activity in AM06. Also as we discussed, a list of reclamation tasks that have been completed to date should be included so we can document for the file the work that has been done. Due to the scope and detail of the reclamation estimate, additional meetings between Climax and DRMS may be beneficial to discuss this Exhibit. Response: A revised Exhibit L has been prepared based on the discussions of January 25 and 0 the above comment. CMC is available to schedule additional review meetings to discuss the reclamation estimate at the convenience of the DRMS. Exhibit M - Other Permits and Licenses Exhibit M Comment: Has the CDPS permit for discharge of process and storm water to Tenmile Creek been renewed by CDPHE? AM-06 only states that the permit expired 10131109 and that renewal applied for on 3131109. Please demonstrate that operations since the expiration of the previous CDPS permit have been authorized by CDPHE to continue under the terms of the previous permit. For completeness, Climax may also want to reference the USFS Special Use Permit included in Exhibit N in this section as well. Response: CMC submitted a complete renewal application for the CDPS permit 180 days in advance of the permit expiration, as required by the existing permit. CDPHE has not yet issued a renewed permit. As described in the permit (Part II.6.11 and Part 11.6.14), filing this timely and complete application causes the expired permit to continue in force to the effective date of the new permit. The USFS Special Use permit has been incorporated into an updated version of Exhibit M - Other Permits and Licenses. It is noted however, that a copy of this permit was included with the original application in Exhibit N. Supplemental Comment (Received January 28, 2011): For completeness, Climax should also referencelinclude any permitting required by A. T.F. (Federal Explosives License) in Exhibit M in this section as well. 0