2000-09-13_REVISION - M1977493 (3)

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Petition for Partial Rele, (Financial Warranty Climax Molybdenum Co.,yany Permit #M-77 493 September 1, 1999 potential to contain lead-based paints were tested for lead and other RCRA metals to determine if on-site disposal was suitable. Non-toxic materials were buried in the disposal site approved by DMG in a letter dated September 26, 1994 prior to grading. The Permit (AM-001 and AM-002) allows burial onsite of non-salvageable material such as concrete and rubble ancillary to demolition. However, neither the permit nor any subsequent amendments or technical revisions specify cover thickness over buried, non-hazardous rubble or foundation concrete. However, Climax adhered to the 6"-36" cover thickness criteria approved in the 1989 Amendment (AM-002) for the Robinson and Mayflower tailings impoundments in conducting the work at the Storke Complex. Approximately 3,000 cu.yds. of fill and soil materials were hauled to the area for use in berm construction around the Storke waste water pump station, erosion control, and growth media. Native materials on the area also were incorporated as growth media. While Climax Mine personnel conducted much of the work at the Storke Complex, ASI-RCC was contracted to complete the grading tasks during the construction seasons of 1995 and 1996. Because of its visible location adjacent to State Highway 91, the Storke area is an excellent site to preserve some of the mining history in the area. Thus, while the distinctive headframe for the No. 5 Shaft was retained as protection for the shaft itself, the headframe may be preserved to serve as a landmark for the mining heritage of the upper Arkansas River Valley. Although the present financial warranty accounts for demolition of the headframe, Climax may in the future petition DMG (through the TR process) to have this structure left in place. Figures 2 through 5 show work conducted at the Storke Complex from 1994 through 1996 when the project was completed. Figures 6 and 7 document the area as of summer 1999. The current financial warranty for closure and reclamation of the Storke Complex is $191,828 (Section 4.1, page 59). Since 81 percent of this task has been completed (46 of 57 acres), Climax seeks a reduction in warranty for this element of. $155,381• Reclamation of the remaining 16 acres involving 11 acres around No. 7 Shaft and nine acres of restoration of the Arkansas River channel (Section 4.15, page 73) has not been completed. Therefore, the warranty for those portions remains unchanged. 3.2 E-Dump The E-dump encompasses 171 acres between the open pit/mill area and the Robinson tailings impoundment. At one time, the material in this rock dump was considered low-grade ore. However, lowered international molybdenum prices and the shifting of the Climax operation to status of a"swing-producer" in 1989 effectively reclassified this material as waste rock. In July 1994, reclamation work on E-dump was initiated as part of an interrelated project to cap the Robinson tailings impoundment (discussed in Section 3.5). Waste rock from the west side of E-dump was removed and hauled to Robinson tailings impoundment for capping. As rock was 100419/Climax/Report.doc 5