2010-08-10_REVISION - M1977493 (7)

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Permit Amendment (AM -06) — Climax Mine • The importance of the Climax molybdenum deposit in providing a long -term source of molybdenum was well- recognized in 1977. The existing mine permit approves continued extraction of molybdenum at the Climax Mine by surface and underground mining methods. The existing permit also approves mineral processing activities necessary for continued molybdenum production; tailings storage within the Robinson, Tenmile, and Mayflower tailing storage facilities (TSF); and storage of overburden generated during ore extraction within the McNulty and North 40 (previously identified as the E and F dumps) overburden storage facilities (OSF). Although the status of mineral extraction at the Climax Mine has changed in response to varying economic conditions between 1977 and the present, CIVIC has maintained mining operations at Climax in accordance with and pursuant to the existing permit and subsequent permit amendments and technical revisions approved by the Board. Substantial planning and capital investments have occurred to facilitate mine development and the resumption of mineral extraction and production, and extensive concurrent reclamation, consistent with the mine plan, has occurred. Five permit amendments were approved by the Board between 1980 and 2005, and four of these amendments included modifications to the affected land boundary. As set forth by Colorado Hard Rock/Metal Mining Rule (HRMMR) 1.1(6), an amendment to a reclamation permit is required when a permit modification increases the affected area of the permit or has a significant effect on the approved reclamation or Environmental Protection Plan. The following tabulation summarizes previous amendments approved by the board with respect to the affected land boundary as well as the proposed boundary submitted with this amendment (AM -06). Amendment Year Approved Modification to affected land boundar AM -01 1980 Amendment consolidated individual parcels of affected land and provided for a buffer to facilitate mine development. Affected land boundary increased from 4,421 to 7,800 acres. AM -02 1989 Amendment modified affected land boundary to include only existing disturbance of 3,372 acres to facilitate reclamation financial assurance reduction. AM -03 1997 Amendment increased affected land boundary to include buffer acreage with a total area of 4,639 acres AM -04 2001 Amendment decreased, by exchange, affected land boundary slightly to 4,638.8 acres AM -05 2006 No change to affected land boundary. Confirmed active status and addressed construction of the Sludge Densification Plant. AM -06 Pending Amendment will increase affected land boundary to include 7,908 acres The existing permit has identified multiple post- mining land uses including, Rangeland, Developed Water Resources, Recreation, and Industrial /Commercial. No changes to these post- mining land uses are proposed in this amendment. 1.3 Proposed Affected Land Boundary The requested permit amendment would adjust the affected land boundary to encompass 7,908 acres, as illustrated on the Index Maps included in Exhibit B. Figure AM- 06 -13-01 (Exhibit B) presents the Index Map with site topography and Figure AM- 06 -B -02 (Exhibit B) is provided with a 2006 aerial photograph background. Climax developed the proposed affected land boundary based on an interceptor ditch to interceptor ditch approach, similar to the approach used in developing the ultimate affected area in the 1980 amendment (AM -01). Interceptor ditches are present at the perimeter of many parts of the mine to convey surface water runoff around and away from mine facilities. The interceptor ditches form a distinct boundary, or physical landmark, that encompasses major areas of mine disturbance. The interceptor ditches provide a physical boundary that Climax personnel and the Division of Reclamation, Mining and Safety (DBMS) can use to determine the affected lands authorized by the permit. Interceptor ditches are not present around all portions of the mine. In these areas, the proposed affected land boundary has • been established as much as possible to coincide with existing physical /geographic boundaries to aid Introduction 1 -3 May 2010 (Page Revised August 20 10)