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Technical Revision (TR -28) <br />Environmental Protection Plan <br />Climax Molybdenum Company <br />Permit No. M-1977-493 <br />Agency/Organization <br />Applicable Permit or <br />Description <br />Authorization <br />US Department of Agriculture <br />Forest Service Special Use Permit <br />Permit for Supply Canal No. 1 <br />#2720 <br />T-3 Designated Chemicals <br />The chemicals listed and discussed herein are those used specifically in: 1) the extractive metallurgical <br />processing of molybdenite ore to produce MOS2 concentrate; and 2) the wastewater treatment system at <br />Climax. Climax produces molybdenum concentrates, thus most of the designated chemicals associated <br />with metallurgical processing are currently present on site. The rates of chemical usage are variable, <br />depending on properties of the ore and other process considerations. Records of chemical usage are <br />maintained by Climax. Information relative to water treatment chemicals used at the site is also provided, <br />however, these are not identified as designated chemicals. <br />The information provided regarding designated chemicals is presented as the best information available. <br />These chemicals, quantities, and concentrations may vary based upon production needs and processes. <br />For example, brand name chemicals may be changed out for different brands of similar chemicals based <br />on factors such as cost, effectiveness, material handling requirements related to safety, or environmental <br />reasons. Changes in brand and reagent usage are a part of the production process and are not <br />considered to be grounds for notification to the DRMS. <br />Climax also will periodically conduct both bench -scale and pilot -scale reagent testing of new reagents to <br />improve processing and economic efficiencies, and reducing safety and/or environmental impacts. <br />Bench -scale testing will adhere to standard industry practices for handling and disposal of reagents. <br />Climax will provide information electronically or in writing to DRMS for pilot -scale testing, whereby new <br />chemicals are temporarily introduced into the process. This information will include rationale for testing <br />the new reagent, MSDS information, expected quantities to be used during the test, and anticipated <br />duration of the test. <br />Notification to the DRMS also will be made per the review/reporting discussed in Section T-1.1.2 in the <br />event that: 1) new types of chemicals, not discussed herein, are added to the process; 2) the storage <br />location of a designated chemical is changed; or 3) the specific containment facility for a designated <br />chemical must be modified. <br />TR -14 described the new mill and ancillary buildings for use during resumed production; however the final <br />design and layout of the mill and accessory buildings had not been fully developed at that time. TR -14 <br />designated the mill building as a location for several Environmental Protection Facilities (EPFs) <br />associated with designated chemicals. Details of the mill facility are provided in general arrangement <br />drawings (Figures AM -06-T-05 and AM -06-T-06). <br />T-3.1 List of Chemicals and Specific Locations <br />Designated chemicals that may be used at Climax during periods of production and for on-going water <br />treatment are listed in Table T-2. The table includes the list of designated chemicals used in the froth <br />flotation metallurgical process for concentrating MOS2 and, for informational purposes, also lists water <br />treatment chemicals. Not all chemicals in Table T-2 may be present on site. For example, Climax has no <br />immediate plans for using sodium cyanide, and this chemical is not being stored on site. It remains in the <br />list of designated chemicals in the event it is ever used at Climax. <br />The individual reagent tank volumes are presented in Table T-2 and their locations are illustrated on <br />Figure AM -06-T-05. There are two enclosed reagent storage rooms within the mill building. There are <br />three tanks in one room; the collector, frother and iron depressant tanks. The largest of these tanks is <br />13,500 gallons, or approximately 1,800 ft3. The total maximum volume of reagents stored in this room is <br />32,800 gallons, or approximately 4,400 ft3. As illustrated on Figure AM -06-T-05, this room has a total spill <br />containment capacity of approximately 44,000 gallons, or 5,900 ft3. The other room contains one tank, <br />the liquid Nokes (iron/lead/copper depressant) tank, whose size is 18,000 gallons, or approximately 2,400 <br />ft3 with a spill containment capacity of approximately 29,000 gallons, or 4,000 ft3. All of the reagent <br />EPP: Version R4 T-7 August 2018 <br />