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PERMIT #: M-1977-493 <br />INSPECTOR'S INITIALS: ECS <br />INSPECTION DATE: September 23, 2015 <br />OBSERVATIONS <br />This was a routine monitoring inspection for the Climax molybdenum mine, a 112d -3 hard rock mine operated by the Climax <br />Molybdenum Company — a division of Freeport McMoRan. This site is located at the summit of Freemont Pass on Highway 91. <br />DRMS representatives for this inspection, Eric Scott, Elliott Russell and Dustin Czapla arrived on-site at approximately 0945. DRMS <br />was guided/accompanied on the inspection by Climax representatives Ray Lazuk and Aaron Hilshorst. <br />The DRMS inspection started with an MSHA safety briefing, followed by a general discussion of the site overall and some items of <br />interest identified by Climax. DRMS then observed the active open pit from the north survey shack area, and the McNulty Gulch OSF <br />area. DRMS noted that the "North 40" low-grade ore storage area has again significantly expanded since the previous inspection. <br />Waste rock from active mining continues to be deposited on the previously existing footprint of the McNulty Gulch OSF. Activity <br />related to the expansion of the McNulty Gulch OSF as approved has not yet commenced. <br />DRMS visited the Sludge Densification Plant (SDP), examined the top of 3 -Dam where deposition had recently taken place and to <br />verify the measures put into place to secure and visually inspect the tailings delivery lines to prevent additional tailings releases. <br />Climax reported that no lines had come loose since these new measures were adopted. DRMS then visited the Property Discharge <br />Water Treatment Plant (PDWTP) and the bypass tunnel outlet area. The avalanche diversion berm extension is scheduled to be hydro - <br />seeded this fall. While on site DRMS also observed the clean water interceptor ditches, pump barges, TDL's, the inlet for the <br />Mayflower TSF, and many other features associated with the water capture, routing, diversion and treatment for the site. All were <br />observed to be operating as designed. Topsoil continues to be salvaged from the perimeter of the Mayflower TSF and parts of Searle <br />Gulch and stockpiled near the south end of the Tenmile TSF dam (3 Dam) for use in final reclamation activities. Biosolids recycling <br />for use in reclamation continues on the far west end of the Robinson TSF. The refuse located near the north area of the Robinson <br />TSF has been segregated and is awaiting removal/disposal or use in composting. This area will likely be reclaimed in the near future, <br />and complete the reclamation of the surface of the Robinson TSF. <br />Although the Mayflower TSF was not being utilized at the time of the inspection, it will be the primary tailings facility going forward. <br />Winter -length leadoffs were observed in place. Because there is limited remaining tailings capacity in the Tenmile TSF, it will remain <br />available online as a "backup" for tailings deposition for the next several years in the event that there is an upset or some other <br />temporary issue preventing the Mayflower TSF from being utilized. Deposition is also moved between TSF areas to prevent process <br />water from encroaching too much into the beach area at Mayflower while the deposition area is still relatively small compared to the <br />Tenmile TSF. <br />DRMS visited the Robinson Lake, and Eagle Park Reservoir to discuss ongoing groundwater monitoring in these areas. Climax has <br />been proactive in gathering additional data to help characterize the groundwater hydrology in this area to determine if additional <br />groundwater protection measures are necessary in this drainage. To date it appears that the concentrations of several constituents of <br />possible concern in the shallow aquifer monitoring wells, which had previously triggered increased monitoring and investigation, have <br />leveled off and even begun to decrease to previous levels. Climax will continue to conduct monitoring as required by the approved <br />Water Monitoring Plan in the updated EPP (TR24). It was noted that several new toe -drains had been installed into the south area of <br />1 -Dam. In order to track and document these types of maintenance activities in the tailings dams (additional/replacement toe drains, <br />piezometers, groin repairs, slope monitors, etc.) DRMS will require that these types of activities be summarized in the annual report <br />with the appropriate location maps and installation data. <br />Climax also continues to gather data for the characterization of the identified groundwater to surface water seep(s) near the base of the <br />reclaimed Stork Yard area. Although some of the seeps show indications that the water is impacted, there have been no observable <br />effects on the surface water of the Arkansas drainage. DRMS will evaluate the data and any potential remedial plans as provided by <br />Climax. Because CDPHE is the primary regulatory entity for surface water quality, Climax has also contacted CDPHE regarding the <br />seeps, and is still awaiting regulatory guidance from CDPHE with regard to the seeps. No other issues of concern were noted during <br />this inspection. <br />DRMS ended the inspection with a walk-through of the mill and the reagent loading and storage area. No issues of concern were <br />noted during this inspection. <br />Inspection Contact Address <br />Ray Lazuk <br />Climax Molybdenum Company <br />Highway 91, Fremont Pass <br />Climax, CO 80429 <br />Page 2 of 2 <br />