1996-02-06_REVISION - M1977493 (11)

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Mr. Allen Sorenson Division of Minerals and Geology February 1, 1996 Page 6 All waters within the tailing impoundment area report to the Climax CPDS Permit outfall. As such, any discharge from the tailings impoundments is regulated by the discharge permit (c) The point that Robinson Lake freeboard should be an enforceable permit requirement is inappropriate. It is true that Robinson Reservoir serves as a retention area for process water and that such rare events where discharge from the reservoir are required compromise the intended reclassification of Eagle Park Reservoir. The implementation of a permit condition on the Robinson Lake spillway, however is redundant in that the Robinson Reservoir and Pump Station, an EPF controlling the handling of process waters to treatment, would have to fail. therefore, the control at the spillway is not only enforceable in terms of the EPF requirements of the pump station, but also by the terms of protective measures to Eagle Park water under the Clean Water Act. Climax controls water level in Robinson Reservoir to prevent discharges and has permitted the spillway as a stormwater discharge point (see the Climax Stormwater Management Plan). (d) Enclosed is a description of the Mayflower decant system. I concur that the understanding of this system is difficult. The clear water pond does not have a minimum freeboard specified. Discharges from the clear water pond at Mayflower constitute a bypass under the Climax CPDS Permit with the exception of the 'snowmelt bypass' period from May 1 to July 31 annually. (e) CMC believes that any discussion of future pit lake scenarios is outside the purview and intent of the EPP. 11. Please note that there needs to be a correction in the EPP concerning the potential volume of water in the mill water tanks. Capacity for these tanks is 2 million gallons each. With respect to your concern, with the change in operating status that has occurred since the original August 1995 submittal of the EPP, other environmental risk management projects have a higher priority. CMC takes exception to implied design criteria requirements for seismic events that are over and above catastrophic failure scenarios cited in other environmental regulations calling only for 110% containment of the largest tank. CMC also believes that the Division does not have the authority to mandate the methods, controls, and timing required to manage risks associated with historic Environmental Protection Facilities. These tanks were constructed prior the formulation of design and construction requirements under Rules 7.3 and 7.4 of the Minerals Rules and Regulations. CMC is committed to sound management of the risks associated with this EPF. 12. Anecdotal information from personnel at Climax suggests that there are no adverse wildlife impacts associated with the high pH waters in the Mayflower Pond. While we do not believe that there is any ingestion of the alkaline water, there does appear to be seasonal and short lived use of the pond by deer in the Tenmile Valley who have been seen swimming in the treated water. The Mayflower area at Climax has abundant wildlife activity including activity by species of deer, elk, fox, birds of prey, and marmot. No other accounts are available at this time.