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Technical Revision (TR-28) Climax Molybdenum Company <br /> Environmental Protection Plan Permit No. M-1977-493 <br /> As described in Exhibit E — Reclamation Plan to AM-06, both Tenmile and Mayflower TSFs will be <br /> reclaimed with a combination of dry and wet covers. Due to concerns regarding water treatment, flood <br /> control, constructability, and dam safety, a wet cap is needed for the Climax site. Climax manages water <br /> to reduce the volume and flow rate of water requiring treatment. This management includes the use of <br /> interceptor canals, diversion ditches, surface treatments, and reclamation of formerly impacted land. The <br /> seepage from TSF dams and water pumped from the open pit or underground mine workings, however, <br /> will continue to require treatment well into the future. These future sources of impacted water are <br /> expected to follow a similar pattern of significant seasonal variability. The use of a wet cap reclamation <br /> scenario provides detention storage capacity that allows for seasonal attenuation during the peak flow <br /> periods and promotes a more constant flow rate for water treatment. This detention storage dampens the <br /> peaks of the impacted water hydrograph and reduces the required capacity of the treatment system. In <br /> addition, an active reservoir to store impacted water provides flexibility in the timing and rate of water <br /> treatment and therefore reduces the risk of releasing impacted water during an upset scenario in the <br /> water treatment system or under unusual hydrologic conditions. <br /> Hydrologic flood studies indicate that peak flow rates onto the TSFs are generally in the thousands of cfs <br /> during a PMP event If there is no detention storage capacity within the TSF to attenuate these flows, <br /> which would be the case in a dry cover scenario, then very large and heavily armored channels would be <br /> required to convey the flood flows safely beyond the site. The detention storage capacity provided by the <br /> wet cover configuration allows for much lower capacity flood conveyance facilities. The detention concept <br /> is less sensitive to peak flood flow estimation and results in lower risk from erosion, channel failure, and <br /> potential dam breach <br /> The wet cap configuration also is consistent with that presented to DRMS and approved in Technical <br /> Revision TR-13. The wet covers are anticipated to develop into a sustainable mosaic of mesic, wet <br /> meadow, and emergent marsh habitats that will support a variety of wildlife and waterfowl species. In <br /> addition, the infrastructure at the TSFs, will allow the ponds to be utilized for detention storage capacity at <br /> closure. <br /> Final reclamation of the OSFs, also described in AM-06 Exhibit E — Reclamation Plan, will involve <br /> regrading of the overburden material to the final closure grades as determined through the ongoing <br /> geotechnical stability evaluations and placement of a soil cover and revegetation. <br /> T-5 Climax Environmental Protection Facilities <br /> An "Environmental Protection Facility" (EPF) is defined in Section 1.1(15) of the Rules as "...a structure <br /> which is identified in the "Environmental Protection Plan" as designed, constructed and operated for <br /> control or containment of designated chemicals..., acid mine drainage, or toxic or acid-forming materials <br /> that will be exposed or disturbed as a result of mining or reclamation operations " Except where noted, <br /> the EPFs as defined are present and operational at Climax. Because of Climax's unique geographic <br /> position affecting both sides of the Continental Divide and three distinct and major watersheds (Arkansas <br /> River, Eagle River, and Tenmile Creek), the following discussion of EPFs and controls is organized by <br /> watershed Within the three watersheds, defined EPFs involve (in no particular order): <br /> ■ Control of run-off that contacts potentially contaminated material, <br /> ■ The process water circuit, which includes process water reclaimed from the TSFs for use in the <br /> mill process, the TSFs and seepwater control systems; <br /> ■ Mine water drainage and control systems; <br /> ■ Storage and containment facilities for designated chemicals used in the milling process; and <br /> ■ Facilities associated with the water management and treatment system. <br /> The EPFs discussed throughout this EPP are shown on Figures AM-06-T-01 through AM-06-T-06. In <br /> addition to these EPFs, a number of internal systems also exist to provide additional control. The internal <br /> systems are classified separately to identify those systems that while serving an important function at the <br /> Site, are not absolutely necessary for the control, and prevention of a release, of acid mine drainage, or <br /> toxic or acid-forming materials. The EPFs and internal controls are listed in Table T-3 and detailed <br /> EPP: Version R4 T-16 August 2018 <br />