2016-06-27_GENERAL DOCUMENTS - M1977493

• Permit No: M1977493
• IBM Index Class Name: General Documents
• Doc Date: 6/27/2016
• Doc Name: Asbestos Exposal Site Exemption
• From: Climax Molybdenum
• To: DRMS
• Email Name: ECS
• Media Type: D
• Archive: No

3 •
Climax Molybdenum Climax Mine
Highway 91 - Fremont Pass
0429
A Freeport-McMoRan Company Climax, 8
p p y Phone [phone]
Fax [phone]
Sent by Certified Mail
June 22,2016 RECEIVED
Ms.Heather Barbare,Environmental Protection Specialist Z---JUN 2 7 2016
Colorado Department of Public Health and Environment plVIISM OF RECLAMATION
HMWMD-HS-B2 INNING AND SAFETY
4300 Cherry Creek Drive South
Denver, CO 80246-1530 Q-7-7
Re: Climax Mine Crusher Adit Vent Raise(CAVR)Asbestos Disposal Site Exemption from
Environmental Covenant Requirement
Dear Ms.Barbare:
The Climax Molybdenum Company—Climax Mine(Climax)received the May 16,2016 conditional
approval from the Colorado Department of Public Health and Environment(CDPHE),Hazardous
Materials and Waste Management Division(HMWMD)in response to the May 12,2016 submittal of
Climax's Crusher Adit Vent Raise(CAVR)Asbestos Disposal Shaft closure documentation. The CAVR
is a former underground mine ventilation shaft(referred to as a"raise"in mining terminology)that was
used in historical underground mining activities at Climax. The shaft extends vertically downward 660
feet from the ground surface and provided air ventilation to miners in an area where ore was crushed
underground before being transported up to the surface. After both underground and surface mining
activities ceased at Climax in the mid-1980s,the shaft was used(with HMWMD approval)to dispose of
asbestos containing materials associated with mine facility demolition.
Your May 16 letter conditionally approved the closure report for the CAVR provided that Climax submit
a signed environmental covenant to HMWMD. The environmental covenant would restrict the use of the
CAVR such that there will be no future disturbance of the CAVR without HMWMD approval.
Climax appreciates HMWMD's conditional approval of the closure report and has closely examined the
request for an environmental covenant in light of CDPHE regulatory requirements. We believe that the
regulations do not require an environmental covenant for closure approval of this particular site because
the project is exempt or,alternatively, it is not needed to protect human health or the environment at the
Climax mine site. In either case,Climax is willing to include a condition in its reclamation permit that
serves as a functional equivalent to an environmental covenant,as described below.
A remedial decision re2ardine the CAVR asbestos disposal site was made prior to July 1,2001,
therefore the proiect is exempt from the environmental covenant requirements,as stated in C.R.S.
25-15-320(2)
In a letter dated July 7, 1988, Climax requested approval from the Colorado Department of Health,
Hazardous Materials and Waste Management Division(predecessor to the current CDPHE-HMWMD)to
dispose of asbestos materials in the shaft. The request(see attached)contained details on the preparation
of the CAVR for asbestos disposal,the types of asbestos materials to be disposed,the methods of
disposal,and the proposed methods for closure.