1996-02-06_REVISION - M1977493 (11)

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Mr. Allen Sorenson Division of Minerals and Geology February 1, 1996 Page 4 7. Climax Molybdenum Company agrees that there may be discrepancies between the original permit application, submittals related to bond recalculation, and statements made pertaining to the post closure land use. Any confusion as to the final site reclamation should be clarified. However, we do not believe that the EPP is the most appropriate place for specifying final land use or closure considerations. Climax Molybdenum Company will commit to submitting an amendment or technical revision (whichever is deemed most appropriate) to the existing reclamation plan within one year to clarify the issues raised in this comment by DMG. 8. Climax Molybdenum Company does not attempt to maintain the in -house expertise necessary to respond to all hazardous material spills or releases. Instead, Smith Environmental Services (formerly Reidel) is retained on a 24 -hour basis for both spill response and technical assistance. In addition, Climax has historically maintained correspondence with Copper Mountain and Lake County Emergency Response agencies. Their contact numbers, and those of responsible individuals at Climax, are provided on pages 1 -7 of the SPCC found in attachment B of the EPP. Climax maintains a supply of absorbent materials, such as dry sweep, which is stored at the warehouse, personal protective equipment, and mobile earth moving equipment. Spill Kits have not been identified as EPF's. 9. Climax Molybdenum Company agrees that the requirements of Rule 6.5 have not been addressed in the EPP technical revision. However, we do not believe that the Geotechnical Stability Exhibit under Rule 6.5 is or should be part of the EPP. We request that these issues be addressed outside of this technical revision, as we believe that the issues raised may delay issuance of the EPP if they must be resolved prior to EPP approval. In general, we believe that the geotechnical stability for many of the areas raised has been demonstrated on the ground through over seventy years of operation of the mine and mill. (c) CMC concurs with the Division that static stability of the tailing impoundments is appropriate. There is abundant information present from design and construction records of the tailing impoundments at Climax that' contain reference to stability evaluations. Thorough understanding of these data, however, will require more time to compile. CMC proposes that a schedule for evaluation of available data and, if necessary, collection of additional data, be allowed for incorporation into the EPP by June 1, 1996. CMC recognizes that tailing impoundments are identified as EPF's in the EPP under Rule 6.4.19 and therefore agrees with the Division's request to determine stability of these impoundments during a seismic event. We view the needed discussion with the Division as having two parts, however, and we therefore request that the Division review and approve of the approach made to assess probable magnitude prior to any discussion of other seismic parameters. CMC proposes the following two phased schedule.