2011-12-15_REVISION - M1977493 - Laserfiche WebLink

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Climax acknowledges and commits that OSF designs and monitoring plans for enlargement of the OSFs beyond their pre -AM -06 footprint must be submitted to DRMS for review and approval. Climax is currently preparing the pit to expose the ore body in anticipation of commissioning and start-up activities. The majority of the overburden being removed during this effort is being placed within the pit for the construction of haul roads. Some of this overburden material is being relocated within the existing footprint of the McNulty and E and F dumps. Climax will submit an OSF Operations and Monitoring Plan for DRMS review and approval prior to resuming full scale mining operations (consistent with the response to adequacy review comments on Amendment AM -06, dated 3/1/11). The drilling program for the geotechnical investigation of the OSF areas was completed in late 2011, which is the first phase of this effort. Laboratory testing and engineering evaluations are being performed, and Climax expects to submit plans to DRMS by the end of January 2012. Due to the variability with mining operations and OSF construction, Climax may provide such plans incrementally (i.e., reflecting sequential construction stages such as beginning with the North 40 portion). However, OSF expansion will not be initiated until DRMS approves the plans for that portion of the OSF. Climax is also in the process of considering appropriate monitoring instrumentation for the OSFs and is evaluating the use of GPS deformation monitoring equipment to monitor movement of the placed material. This system consists of monitoring stations installed a fixed locations. The system will monitor the located of the fixed stations, through GPS signals, at regular intervals to detect movement. With regards to the use of temporary low permeability covers, such covers are impractical for OSFs inasmuch as there is a no available clay material on site for such covers, the large scale of the OSF areas, the need to maintain operational flexibility for overburden placement (Le., Climax will utilize the entire area of the OSFs as a function of proximity to the locations of activity in the open pit), and the potential for creating stability issues with capping that is subsequently covered by overburden. The OSF designs and operations and monitoring plan will include provisions for runon control and grading and drainage to quickly shed water from the OSF material and eliminate ponding of water on the OSF surfaces. More importantly, Climax will maintain its site -wide water capture and treatment system to capture runoff and seepage that may have impacts associated with ARD from OSF areas. What is the proposed monitoring plan for ARD generated by the OSFs and tailings impoundments? This drainage is collected in several areas across the site for treatment at this time, but does not appear to be analyzed. Water quality/quantity measurements of this impacted drainage may provide useful insight into geochemical processes at the site, document success of Environmental Protection Facilities (EPFs), and /or help to guide future treatment options for impacted drainage. Groundwater monitoring, using nested wells to differentiate between alluvial and deep groundwater (if present), should also be conducted near the toe of the OSF facilities. Analytical data of impacted water sources are available, including seepage from the OSFs, TSFs and other sources from around the site that are collected and treated. The geochemical processes at the site are well understood to ensure the effectiveness of the water management and treatment system. A new table is incorporated into Appendix T -E (Geochemical Data) of the EPP which presents a summary of water quality data from impacted sources, and includes data from a recent data collection effort performed as part of the treatability studies performed for the design of the new Property Discharge Water Treatment Plant. Samples of impacted water sources will continue to be collected by Climax on an as needed basis. 3