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to Highway 91. After mining and milling operations cease, the East Side Channel would be <br />modified to convey clean stormwater run -off from reclaimed areas on both sides of Highway 91. <br />The East Side Pipeline (ESP) would be constructed to convey impacted water from the Camp <br />area and OSFs to the Mayflower Pond and PDWTP for treatment. In AM -06 the converted East <br />Side Channel and new ESP are shown to begin at the south side of the North 40 OSF, near the <br />TDH structure below the Camp area (Figure AM- 06- G -04). <br />Climax has reevaluated the need for the converted East Side Channel and ESP upgradient of <br />Robinson Pond and McNulty Gulch in light of proposed changes to the OSF diversion system to <br />be submitted to DRMS as TR -22. The stormwater runoff diversions that are being proposed for <br />the North 40 and McNulty OSFs will terminate at the base of McNulty Gulch such that <br />stormwater can be directed to either the East Interceptor or to the newly constructed Tenmile <br />extension of the East Side Channel. As needed, clean stormwater from portions of the reclaimed <br />Camp area will then be diverted to the North 40 OSF stormwater conveyance. With this design <br />concept there is no longer a need for the converted East Side Channel to extend up to the Camp <br />area. Instead, the converted East Side Channel would begin at the spillway from the reclaimed <br />Robinson Pond (Figure AM- 06 -G -06) and extend to the Tenmile Creek drainage. <br />With the revised OSF water management design, the ESP segment that was envisioned to begin <br />at the TDH also is no longer needed since impacted water from the Camp area and North 40 OSF <br />can be conveyed for treatment using the ETDL, TDL or the existing segment of the East Side <br />Channel that extends up to the Camp area. The ESP would now begin near the Robinson Pond <br />spillway, at or below the starting location of the converted East Side Channel, and would collect <br />impacted water from the existing East Side Channel upgradient of this location. <br />Conversion of the East Side Channel and construction of the ESP from the TDH to below the <br />Robinson Pond spillway is no longer required for site closure. This represents approximately <br />$3,500,000 that can be eliminated from the site reclamation performance bond, or used for <br />financial assurance to cover other reclamation costs not identified in AM -06, Exhibit L. Climax <br />also is evaluating other post - closure, water management design changes such as the conversion <br />and utilization of the TDL to replace the ESP along the east side of Tenmile and Mayflower <br />TSFs. These types of changes will provide additional reclamation cost reductions and additional <br />buffer in the Climax financial warranty. <br />Climax appreciates the Division's consideration of these responses. Please feel free to contact <br />me should you have any remaining questions or comments. <br />Sincerely, <br />Raymond Lazuk <br />Environmental Manager <br />attachments <br />3 <br />