2021-08-17_REVISION - M1977342 (4)

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TR-34 to Permit M-1977-342 Environmental Protection Plan Maintenance and/or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases. Mill EPF 2.3.a — Frother Chemical Storage — Dowfroth 250-C Frother (or substantially similar chemical), a frothing agent used in the flotation process, is stored in 250 gallon totes in the Mill building with a maximum storage of approximately 2,750 gallons. Effectiveness: Releases of this chemical would be contained directly by the Mill sump system. The Mill sump also contains a high-level alarm to provide warning in the event of a large release. Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC Plan by Mill personnel to assess effectiveness and integrity of each EPF system. Maintenance and/or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases. Mill EPF 2.3.b—Depressant Chemical Storage -Orfom D8 Depressant, a suppressant used in the flotation process, is stored in 275 gallon totes in the Mill building with a maximum storage of approximately 5,400 gallons. Effectiveness: Releases of this chemical would be contained directly by the Mill sump system. The Mill sump also contains a high level alarm to provide warning in the event of a large release. Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC Plan by Mill personnel to assess effectiveness and integrity of each EPF system. Maintenance and/or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases Mill EPF 2.4- Pine Oil Storage: Pine oil, used in the flotation process, is stored in a 16,121 gallon steel tank located and contained in the oil room inside the Mill building. Effectiveness: Releases in the oil room are contained by a concrete-walled secondary containment that is sloped to a system that channels the material to the mill sump system for either return to the mill circuit, or for routing to the TDL. The Mill sump also contains a high- level alarm to provide warning in the event of a large release. Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC Plan by Mill personnel to assess effectiveness and integrity of each EPF system. Maintenance and/or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases. Mill EPF 2.5 - Collector Oil Storage: Collector oil is a product used in the flotation process within the Mill. Vapor oil (also known as Hydrocal 60 or Calumet) is generally used for this product, but Diesel #2 may be used as a backup. Vapor oil is stored in a 32,000 gallon steel tank contained within the oil room inside the Mill building. Diesel#2 is also stored in a 32,000 gallon steel tank in the oil room located within the Mill building. Effectiveness: Releases in the oil room are contained by a concrete-walled secondary containment that is sloped to a system that channels the material to the Mill sump system for either return to the Mill circuit, or for routing to the TDL. The Mill sump also contains a high- level alarm to provide warning in the event of a large release. Climax Molybdenum Company August,2021 Henderson Operations Page 26 of 45