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Letter to Jay Jones -6- November 29, 1995 <br /> Based on Climax's knowledge of the fracturing, faulting, and <br /> underground openings in the area, it is believed that the pit <br /> basin ultimately will impound surface and ground waters to the <br /> 10,868 ' msl elevation. The 300 foot difference between the <br /> ultimate surface elevation and the pit rim will provide the <br /> surge capacity to contain the PMF. <br /> The 10,868 ' msl elevation correlates with the elevation of the 600 <br /> level of the underground workings. The water level in No. 5 Shaft <br /> at the Storke Yard has already risen well above this elevation. <br /> Please provide details on Climax's knowledge of the fracturing, <br /> faulting, and underground openings in the area upon which the <br /> estimated Glory Hole Lake surface elevation was predicated. <br /> 11. In section 5. 1. 1 of the EPP application, it is indicated that <br /> catastrophic failure of the industrial process water tanks could <br /> result in discharge to the Arkansas River. Section 5. 3 . 1.7 of <br /> Appendix B to the EPP application states that containment <br /> improvements, in the form of a berm, are being designed and will be <br /> built in 1996 after approval of the capital budget. Design and <br /> construction of such a berm would have to be completed. in accordance <br /> with Rules 7. 3 and 7.4 of the Mineral Rules and Regulations. Design <br /> of the berm should consider the potential for simultaneous <br /> catastrophic failure of both tanks in the event of an earthquake. <br /> If a berm is not built in 1996 to provide full containment in the <br /> event of a catastrophic failure, the Division will require that some <br /> minimum measures be implemented to direct and disperse flows from <br /> less than catastrophic spills (e.g. slow leaks from a tank, or <br /> piping failures) such that impacts to the Arkansas River would be <br /> minimized. <br /> 12. The Division is concerned with the potential impacts to wildlife <br /> that may be caused by the maintenance of an approximately 180 acre <br /> pond at pH 10.5 to 11.5 in the Mayflower impoundment. The Division <br /> is currently researching the potential for impacts to wildlife that <br /> may be caused by exposure to high pH waters, and it is premature to <br /> discuss what wildlife protective measures, if any, might be needed. <br /> Please provide any information that you have regarding observations <br /> of wildlife utilization of the Mayflower treatment pond. Please <br /> also provide any information that you have regarding observations of <br /> wildlife utilization of the other tailing ponds and of Robinson <br /> Lake. <br /> 13. In section 9. 0 of the EPP application the statement is made that by <br /> stipulating to the acid forming nature of waste rock and tailing at <br /> the Climax Mine, the need to develop specific geochemical data is <br /> obviated. In section 4. 1. 2 of the EPP application, it is stated <br /> that Climax has retained the services of a full-time geochemist, and <br /> that during the next 18 months acid rock and acid mine drainage <br /> issues at the site will be investigated in depth resulting in a <br />