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Mr. Peter Hays, DRMS <br />February 17, 2015 <br />containment was pumped back into the Mill circuit. Upon discovery of the leak from the <br />secondary containment, Belfor Environmental was immediately called to assist with the <br />cleanup. <br />After discovering the tank had overflowed on February 12th, the Mill Emergency Response <br />Team was again called to respond to the situation. Belfor was not called to respond <br />because the amount of material that escaped from outside the building was minimal. <br />(b) The NaOH releases on February 11th and February 12th did not adversely impact human <br />health, property or the environment. All material associated with this event flowed into a <br />storm drain which ultimately discharges into the tailing impoundment. <br />(c) The contact person for these events is: <br />Amber Parmet <br />19302 County Road 3 <br />Parshall, CO 80468 <br />Phone: 720 - 942 -3480 <br />amber parmetO- fmi.com <br />(d) No monitoring or analyses were performed for these situations since NaOH was not <br />released off -site and did not impact waters of the United States. <br />(e) February 11th - The investigation following the incident determined that the tank overflow <br />was caused by a missed step in the SOP that requires the operator to turn off two water <br />valves after transferring NaOH from the tanker truck to the tank. The secondary <br />containment had enough capacity to contain the volume of the spill, however investigation <br />showed compromised condition of the containment in two locations. The integrity of the <br />containment will be checked and repaired to prevent future releases. <br />February 12th — The investigation following the event determined there was an error in <br />communication between the Warehouse (who receives the material) and Process Control <br />who confirmed the instrumentation levels that day. It was also determined that the high <br />level alarm was set to 100% instead of 90% so it did not sound as designed while the driver <br />was offloading. The secondary containment had enough capacity to contain the volume of <br />the spill, but the containment leaked from the same location as the spill that occurred on <br />February 11th. As mentioned above, the containment will be checked and repaired to <br />prevent future releases. The high level alarm will be calibrated to the correct level. A <br />thorough investigation will be completed to ensure transfer operations are being managed <br />correctly. Corrective actions will be taken as deemed appropriate. <br />If you have any additional questions or concerns, please feel free to contact me at 720 - 942 -3480 or Bryce <br />Romig at 720 - 942 -3231. <br />Sincerely, <br />GL—�—?'� <br />Amber Parmet <br />Environmental Engineer II <br />Climax Molybdenum Company <br />Henderson Mill <br />Page 2 <br />