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(phreatic surface monitoring, permanent inclinometers, etc)? This monitoring /documentation protocol should <br />be clearly specified, and will be included as an enforceable condition of the permit when approved. <br />Response: The monitoring program for the Tenmile TSF is described in the attached O &M Manual. <br />Rule 6.5 Comment 3: The introduction of the Geotechnical Stability Exhibit submitted with AM -06 states that <br />the information submitted is a preliminary overview, and that the design at this time is not considered final. <br />Obviously the long -term stability of the OSF and TSF features is a primary concern of the Division. While the <br />preliminary evaluations appear in order, DRMS does not review /approve 'preliminary designs" and will <br />therefore require final design specification evaluation and approval before the site resumes mining and <br />additional material is placed in the existing TSF or OSF facilities. Please consolidate and provide the CPT <br />and laboratory data protocols and reporting referenced and used in the preliminary design modeling. Also, <br />when submitting the final design specifications and evaluations, complete dynamic loading analysis for the <br />TSF features will be required These final design specifications and stability evaluations may be subject to <br />third party review as outlined in Rule 7.4.3. <br />Response: The attached Seepage and Stability Analyses report provides site investigation information and <br />third party design and stability analyses for the Tenmile TSF. <br />Specific DRMS comments in the September 9, 2011 DRMS adequacy determination letter for TR -18 <br />addressed by TR -20 are as follows: <br />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 />- There is no mention of phreatic surface monitoring, inclinometers or any structural monument surveys of <br />these tailings dams in the EPP at this time. If this type of stability monitoring is not currently being <br />conducted, this topic will need to be addressed by Climax before full scale mining and processing resumes. <br />Climax will need to commit to submitting, and receiving DRMS approval, of a TSF Design, Operations and <br />Monitoring Plan before these facilities are further enlarged The TSF plan and the annual report should <br />include at least annual stability monitoring /certification by a qualified engineer as well as the design and <br />QA/QC plans for TSFs. <br />Response: The attached TR -20 documents provide design, stability, operations and monitoring information <br />for the Tenmile TSF. The Operations and Maintenance Manual will be incorporated into the EPP by <br />reference. <br />Thank you for your review and consideration of the TR -20 documents. Please feel free to contact me at 719- <br />486 -7584 if you need any additional information. <br />Sincerely, <br />Raymond Lazuk <br />Environmental Manager <br />enclosures <br />