2021-08-17_REVISION - M1977342 (4)

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TR-34 to Permit M-1977-342 Environmental Protection Plan 1. INTRODUCTION 1.1. Purpose and Objectives The Mineral Rules and Regulations (Rule)of the Colorado Mined Land Reclamation Board (MLRB) for Hard Rock, Metal and Designated Mining Operations defines a Designated Mining Operation (DMO) as a mining operation where designated chemicals used in metallurgical processing are present on-site; toxic or acid-forming materials will be exposed or disturbed as a result of mining operations; or acid mine drainage occurs or has the potential to occur due to mining or reclamation activities. Climax Molybdenum Company, Henderson Operations (Henderson) is classified as a DMO, and as such must follow the requirements for a DMO Environmental Protection Plan (EPP) under Rule 6.4.21, Exhibit U.The purpose of this EPP is to provide a description of environmental protection facilities (EPFs) for those areas that potentially could be affected or impacted by designated chemicals, toxic or acid-forming materials or acid mine drainage. The original Henderson EPP was submitted as Technical Revision 04 (TR-04) to the existing Regular (112) Mining and Reclamation Permit, Number M-1977-342 (the "Reclamation Permit"). A revision to the original EPP was submitted as Technical Revision 18 (TR-18) in 2012, which then superseded the EPP submitted under TR-04. This Technical Revision (TR-34) now supersedes TR- 18 and, once approved,will become part of the Reclamation Permit.The objective of this revision is to update the current EPP to reflect existing conditions at the site. 1.1.1. Reference and Indexing Since Henderson is an existing active operation with an approved Reclamation Permit, much of the information and data required for the EPP has been developed previously. Where such information is already part of the public record and official Reclamation Permit files (modifications to the Reclamation Permit via Amendment (AM) or Technical Revision (TR), correspondence with DRMS, etc.), that information is referenced but not included herein. Only information that presently is not part of the public record or is required specifically under the Rule is included. 1.1.2. Changes in Referenced Information and Documents Changes in the reclamation plan or EPP can trigger the need for submittal of a formal Amendment, Technical Revision, or Modification depending upon the type of change as defined in Rule 1. Facility improvements have occurred since the last EPP revision. Please refer to Appendix A for a List of DRMS Permit Amendments and Technical Revisions. 1.1.3. Emergency Response Plan An Emergency Response Plan is required as a component of the EPP to comply with Rule 8.3 for designated chemicals. Henderson maintains Incident Response Manuals(IRMs)for both the Mine and Mill, which are included in Appendix B. Henderson also maintains Spill Prevention, Control and Countermeasure (SPCC) Plans at the Mine and Mill. These documents describe procedures to protect, prevent, control, and mitigate releases of chemicals to the environment in the unlikely Climax Molybdenum Company August,2021 Henderson Operations Page 1 of 46