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Tailings Storage Facilities (TSFs) <br />- What types of stability monitoring are done on tailings dams 1, 3 and 5? Is there an approved stability <br />monitoring program with trigger levels and potential corrective actions currently in place? If so, please <br />provide a copy of this plan in the EPP. Are the results of any current stability monitoring recorded and <br />available for review? <br />Page 3 of 5 <br />- There is no mention of phreatic surface monitoring, inclinometers or any structural monument surveys of these <br />tailings dams in the EPP at this time. If this type of stability monitoring is not currently being conducted, this <br />topic will need to be addressed by Climax before full scale mining and processing resumes. Climax will need <br />to commit to submitting, and receiving DRMS approval, of a TSF Design, Operations and Monitoring Plan <br />before these facilities are further enlarged. The TSF plan and the annual report should include at least annual <br />stability monitoring/certification by a qualified engineer as well as the design and QA/QC plans for TSFs. <br />- Although obviously not part of the TSF's, what long term stability monitoring plans are in place for the open pit <br />itself? The annual report for this site should include at least an annual long -term stability <br />monitoring/certification by a qualified engineer. <br />Arkansas Basin <br />- How often are the levels in the pizeometer near the 5 -shaft pump station checked and recorded? Please note the <br />location of this pizeometer on the appropriate figures. <br />- What are the construction details of this pizeometer, and is there any reason this well could /should not also be <br />used as an internal water quality monitoring point? <br />- There do not appear to be any internal monitoring points, upstream of the Point of Compliance (POC) well <br />(ARwell). DRMS suggests at least one pair of nested wells be installed in a suitable location between ARwell <br />and the Mosquito fault to monitor internal water quality and the effectiveness of the 5 -shaft pumping. <br />- Are any water quality samples collected currently from the 5 -shaft discharge or the Storke seepage collection <br />site? This question also applies to all other TSF dam seepage collection sites, groundwater cut -off sites, or <br />other discrete source of impacted water on -site. Again, water quality /quantity measurements of this impacted <br />drainage may provide useful insight into geochemical processes at the site, document success of EPFs, and /or <br />help to guide future treatment options for impacted drainage. <br />Eagle River Basin <br />- DRMS will require Climax to verify and monitor the effectiveness of the Dam 4 seepage cutoff system through <br />the installation of a nested pair of groundwater monitoring wells immediately downstream of the final seepage <br />cutoff and return structure. The Division would also consider other methods of verification, such as the <br />collection and analysis of the impacted seepage vs. the surface water immediately down - gradient of the cut- <br />off structure, if these alternative methods could be reasonably demonstrated to be reliable indicators of the <br />success or failure of the cutoff structures. <br />- Eagle Park Reservoir has been removed from the permitted area and is now a source of surface water discharged <br />directly to the East Fork Eagle River. Nested POC wells will need to be installed and sampled in at least the <br />two proposed and one existing EVMW locations to establish appropriate Numeric Protection Levels (NPLs) <br />and monitor for potential groundwater impacts to the reservoir or off site impacts. <br />