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PERMIT#:M-1977-493 <br /> INSPECTOR'S INITIALS:ECS <br /> INSPECTION DATE:October 19,2016 <br /> OBSERVATIONS <br /> This was a routine monitoring inspection for the Climax molybdenum mine, a 112d-3 hard rock mine operated by the <br /> Climax Molybdenum Company—a division of Freeport McMoRan. The inspection was conducted by DRMS <br /> representative Eric Scott. DRMS arrived on-site at approximately 0915. DRMS was guided/accompanied on the <br /> inspection by Climax representatives Ray Lazuk, and Aaron Hilshorst. <br /> The DRMS inspection started with a general discussion of the site and some items of interest identified by Climax and <br /> DRMS. One topic of discussion was the current groundwater monitoring plan and establishing NPLs for all compliance <br /> points. DRMS is currently adopting a policy that will clarify the required groundwater standards with respect to the <br /> requirements of Water Quality Control Commission Rule 41 —Basic Standards for Groundwater. In separate <br /> correspondence Climax will be asked to demonstrate that the standards outlined in Rule 41 are being met at all <br /> groundwater compliance locations. If the standards in the approved groundwater monitoring plan differ from those given <br /> in Rule 41,the standards in Rule 41 will apply. This may require submittal of a TR to the EPP/Groundwater Monitoring <br /> Plan, but that determination will be made after DRMS reviews the available data. <br /> There was also discussion of the Financial Warranty review that Climax has been tasked to conduct and submit to DRMS <br /> for review by Dec. 31, 2016. Climax stated that this task is underway and on schedule for submittal, and that several <br /> errors in the previous calculations had been identified and corrected. Bonding issues related to the US Army Corps of <br /> Engineers required wetlands mitigation associated with the McNulty Gultch OSF expansion were also discussed. The <br /> McNulty OSF expansion was approved on a conceptual level as TR22,however,the evolution of the mine plan since the <br /> restart,wetland permitting requirements for the expansion, and other design revision issues will require a final engineered <br /> pre-construction design submittal for DRMS approval prior to start of work on the OSF expansion. <br /> Climax also updated DRMS with the progress in addressing the removal of an abandoned culvert that had provided a <br /> preferential path for groundwater migration under Hwy 91 from the Storke Yard area. It has been determined that a <br /> CDOT permit is needed prior to conducting the work in the Hwy 91 right-of-way to excavate the end of the culvert and <br /> properly plug and abandoned it. Climax is currently working on obtaining this permit from CDOT and plans to conduct <br /> the required work to abandon the culvert during spring of 2017. <br /> Due to the recent snowfall at the site and the resulting muddy/snowy conditions, the remaining site tour was somewhat <br /> abbreviated. DRMS began the inspection with a tour through the active mill facility, followed by a visit to the Storke <br /> Yard area where the work to abandon the culvert will take place next spring. The inspection proceeded past the bio-solids <br /> processing area to Robinson Lake where there was discussion regarding the proposed clean out of accumulated sediment <br /> from the settling area adjacent to Warren's Pump Station. The settling pond will need to be cleaned soon to prevent <br /> sediment from interfering with the operation of the pumps. <br /> DRMS observed the Tenmile and Mayflower TSF dams and tailings deposition areas. The last lift of the Tenmile TSF is <br /> in place and tailings were being deposited here during the inspection. Climax is currently conducting field trials of two <br /> dust-suppression products to determine the best product for use in ongoing dust control from the TSFs. Recent high wind <br /> events have been a challenge for dust control,but this is a seasonal occurrence, and needs to be managed to the best extent <br /> practicable. DRMS then visited the Tenmile Creek drainage compliance well locations, and returned to the mill offices <br /> prior to departing the site. <br /> No issues of concern were 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 />