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All the reagent storage tanks are vented to atmosphere within the reagent area. In addition, the liquid <br />Nokes tank has a powered vent to the outside of the building. We believe this is sufficient to protect <br />personnel in the event of a release. <br />- Is there any air monitoring in place for HCN or H2S concentrations in the mill or reagent storage area? <br />HCN monitoring is not required at this time since the mill will not be using cyanide compounds. HCN <br />monitors will be revisited if this situation changes. <br />We do plan to use liquid Nokes, purchased as a pre -mixed solution rather than mixing it on -site. This will <br />significantly reduce the risk of H generation since the potential for gas generation is greatest during the <br />mix phase. Nevertheless, H monitoring is provided at two locations. One is the truck unloading point <br />where the solution is transferred from a bulk tanker to our storage system. The other is in the liquid <br />Nokes storage tank area. Both monitors are located at low points to quickly detect any H that might be <br />generated. <br />- It does not appear that there has been any consideration for groundwater monitoring near the mill area at <br />this time. Please address the mill /processing area as a source of potential contamination. <br />The EPP (Section T -5.3) describes potential sources in the mill /processing building. Other potential <br />sources in the general vicinity include the E and F Dump areas and other historic mine disturbance. <br />Groundwater in the vicinity of the mill is controlled by either the gradients created towards the open pit or <br />to the Robinson TSF. The open pit is currently dewatered through the connection to 5 Shaft and flow <br />from the Robinson TSF is captured through a series of collection drains. Collected water is directed to <br />the SDP for treatment and discharge in accordance with the Climax CDPS permit. <br />Also, an underdrain system has been installed beneath the mill to collect any sub - surface water. This <br />water reports to a sump that can be pumped to the storm drain system that is conveyed to the SDP for <br />treatment <br />Climax is developing a conceptual hydrogeological model of this and other areas of the mine site to help <br />characterize groundwater flow patterns for the purpose of identifying new monitoring well locations (see <br />responses to comments on the Water Quality Monitoring Plan regarding groundwater monitoring). The <br />results of this analysis will be completed in March 2012 to allow sufficient time for DRMS review and <br />approval prior to the 2012 field season. The need for groundwater monitoring near the mill area will be <br />evaluated during this hydrogeological characterization. <br />T-4 Acid Forming Materials and Acid Mine Drainage <br />Although the Division's primary concern with the Overburden Storage Facility (OSFs) must be for the long <br />term safety and stability of these features, the Division is also adamant that every reasonable measure be <br />taken to minimize the impacts from, and the quantity of, ARD generated by the OSFs both while in operation <br />and after final closure. Climax will need to commit to submitting, and receiving DRMS approval, of the OSF <br />Operations and Monitoring Plan before these facilities are further enlarged. The OSF plan and the annual <br />report should include at least annual stability monitoring /certification by a qualified engineer as well as the <br />design and QA/QC plans for any structures, such as under - drains, associated with these features. DRMS <br />may also require the use of "temporary" low permeability covers over areas of exposed waste rock if <br />placement sequencing does not allow for final concurrent reclamation of dump areas as the mining <br />progresses. <br />2 <br />