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Technical Revision (TR -28) <br />Environmental Protection Plan <br />T-1 Introduction <br />T-1.1 Purpose and Objectives <br />Climax Molybdenum Company <br />Permit No. M-1977-493 <br />In April 1994, the Colorado Mined Land Reclamation Board (Board) approved and promulgated <br />amendments to the Mineral Rules and Regulations for Hard Rock, Metal, and Designated Mining <br />Operations (Rules) under the Colorado Mined Land Reclamation Act (Act). The most important of these <br />changes was the classification and definition of a "Designated Mining Operation" and the addition of <br />Section 6.4.20 Exhibit T - Designated Mining Operation Environmental Protection Plan in Rule 6 (the <br />current amended version of the Rules, effective September 30, 2010, now address Environmental <br />Protection Plan requirements in Section 6.4.21 — Exhibit U). <br />A "Designated Mining Operation" (DMO) is defined as a mining operation where: <br />■ designated chemicals used in metallurgical processing are present on-site; or <br />■ toxic or acid-forming materials will be exposed or disturbed as a result of mining operations; or <br />■ acid mine drainage occurs or has the potential to occur due to mining or reclamation activities. <br />The Colorado Division of Reclamation, Mining and Safety (DRMS — formerly "Division of Minerals and <br />Geology" or DMG), the agency that administers the Mineral Rules and Regulations, formally notified the <br />Climax Mine that it was a DMO on August 3, 1994 (letter to Mr. Frank Zancanella). The Climax Mine <br />concurred with the designation on August 31, 1994 (letter to Mr. Bruce Humphries, DRMS). <br />Briefly, the purpose of the Environmental Protection Plan (EPP) is to define how the DMO operator will <br />protect those areas that potentially could be affected or impacted by "designated chemicals, toxic or acid- <br />forming materials or acid mine drainage." "Designated Chemicals" are defined in Rule 1, Section 1.1 (13) <br />as "toxic or acidic chemicals used within the permit area in extractive metallurgical processing, the use of <br />which, at certain concentrations, represents a potential threat to human health, property or the <br />environment." DRMS has jurisdiction over the designated chemicals used in mineral production <br />processes. <br />Climax Molybdenum Company - Climax Mine (Climax) originally submitted the Climax EPP as Technical <br />Revision (TR) 7 to its existing Regular 112(d) Mining and Reclamation Permit (Number M-1977-493; <br />"Permit") on August 11, 1995. The objective of this EPP update, submitted as TR -28, is to reflect current <br />and anticipated future conditions as of 2018. <br />For purposes of the record, tClimax is wholly owned and operated by the Climax Molybdenum Company <br />(CMC), a wholly owned subsidiary of Freeport-McMoRan Inc. with headquarters in Phoenix, Arizona. <br />T-1.1.1 Reference and Indexing <br />Since Climax was continuously considered by DRMS to be an active operation with an approved life -of - <br />mine Permit, much of the information and data required for the EPP has been developed previously. The <br />most recent version of the EPP (R3) was submitted and approved by DRMS in October 2014 as <br />Technical Revision 24 (TR -24) to the Climax Reclamation Permit. EPP R3 was designed to supersede all <br />previous EPP amendments and revisions. This EPP version (R4) reflects current and anticipated future <br />mining and milling conditions and is intended as an update to EPP R3. Where applicable, Appendices <br />that have not changed are incorporated into this version with their original footer. Also, as stated in EPP <br />R2, previously submitted information regarding design details or construction certification of EPFs are not <br />included in this EPP, and may not be specifically referenced but remain part of the public record and <br />official Permit files. <br />T-1.1.2 Changes in Referenced Information and Documents <br />Changes in the reclamation plan can trigger the need for submittal of a formal Amendment, Technical <br />Revision, or Modification depending upon the type of change as defined in the Rules. Because the EPP <br />references numerous public record documents and information on file with the DRMS and other state <br />EPP: Version R4 T-3 August 2018 <br />