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and Monitoring Plan before these facilities are further enlarged. The OSF plan and the annual report should <br />include at least annual stability monitoring/certification by a qualified engineer as well as the design and QA/QC <br />plans for any structures, such as under - drains, associated with these features. DRMS may also require the use of <br />"temporary" low permeability covers over areas of exposed waste rock if placement sequencing does not allow <br />for final concurrent reclamation of dump areas as the mining progresses. <br />What is the proposed monitoring plan for ARD generated by the OSFs and tailings impoundments? This drainage <br />is collected in several areas across the site for treatment at this time, but does not appear to be analyzed. Water <br />quality /quantity measurements of this impacted drainage may provide useful insight into geochemical processes at <br />the site, document success of Environmental Protection Facilities (EPFs), and/or help to guide future treatment <br />options for impacted drainage. Groundwater monitoring, using nested wells to differentiate between alluvial and <br />deep groundwater (if present), should also be conducted near the toe of the OSF facilities. <br />In several areas of the plan the proposed Ceresco ridge haul road is mentioned as a potential source of impacts <br />(such as run -off into the Arkansas basin, and page 4 of the Water Quality Monitoring Plan (WQMP)). During the <br />last DRMS site visit, there was discussion with Climax regarding relocating this road from the route proposed in <br />AM06, and that this new alignment would possibly minimize the potential impacted runoff from the road and <br />other impacts on the surrounding areas. Please review the statements in the EPP regarding the proposed Ceresco <br />Ridge haul road and make any needed alterations. <br />Emergency Response Plan (ERP) <br />- Who is the Emergency Coordinator referred to in the ERP that will be directing initial on -site response <br />activities? This individual(s) should be clearly identified in the plan and contact list and be Incident <br />Command System (ICS) trained. <br />- Given that most of the designated chemicals on site are inhalation hazards, or can off -gas toxic breakdown <br />products, how many SCBA trained and approved responders would be on -site and able to respond if needed <br />under normal circumstances? (As noted in the plan at least 4 are required to do a Level B entry) <br />- How often are PPE, response, and monitoring equipment checked by qualified personnel? There should be a <br />listing of available response gear (SCBA, Saranex suits or similar, etc) and its location and intended use in the <br />ERP. <br />- Does Climax hold periodic response drills for employees to exercise and improve this plan and emergency <br />communications? If so, do these drills include local emergency responders? <br />- There appear to be several phone numbers for the Henderson Mine facility in the emergency contact list <br />provided in the ERP, is this intentional? <br />Robinson Lake Operation Plan <br />Page 2 of 5 <br />- The Division acknowledges that the SEO has primacy over the Robinson Lake Dam as a jurisdictional dam. <br />Has the SEO set trigger levels for the phreatic surface monitoring conducted in Robinson Dam? If so, what <br />actions are taken if these levels are exceeded? The same question should be addressed for the structural <br />monument surveys for dam stability. <br />- How often is the water level in Robinson Lake measured and recorded at this time by Climax? <br />- Is there a projected completion date for the Robinson Lake Pump Station and the automated water level <br />monitoring system? Will the water level data from the automated system be recorded, and if so at what <br />intervals? These records should be maintained for review upon request. <br />