2011-08-08_REVISION - M1977493 (33)

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• • • Technical Revision (TR -18) Climax Molybdenum Company Environmental Protection Plan Permit No. M- 1977 -493 wildlife and waterfowl species. In addition, previously constructed infrastructure at the Robinson TSF, including the existing East Side Channel and 2 Dam Spillway will allow the established pond on the Robinson TSF to be utilized for detention storage capacity at closure. Final reclamation of the OSFs, also described in Permit Amendment AM -06 Exhibit E — Reclamation Plan, will involve regrading of the overburden material to the final closure grades as determined through the ongoing geotechnical stability evaluations and placement of a soil cover and revegetation. T -5 Climax Mine Environmental Protection Facilities An "Environmental Protection Facility" (EPF) is defined in Section 1.1(15) of the Rules as "...a structure which is identified in the "Environmental Protection Plan" as designed, constructed and operated for control or containment of designated chemicals..., acid mine drainage, or toxic or acid - forming materials that will be exposed or disturbed as a result of mining or reclamation operations." Except where noted, the EPFs as defined are present and operational at Climax. Some of the EPFs identified and described herein are under construction or planned for future construction. Because of Climax's unique geographic position affecting both sides of the Continental Divide and three distinct and major watersheds (Arkansas River, Eagle River, and Tenmile Creek), the following discussion of EPFs and controls is organized by watershed. Within the three watersheds, defined EPFs involve (in no particular order): • Control of run -off that contacts potentially contaminated material; • The process water circuit, which includes process water reclaimed from the TSFs for use in the mill process, the TSFs and seepwater control systems; • Mine water drainage and control systems; • Storage and containment facilities for designated chemicals used in the milling process; and • Facilities associated with the water management and treatment system. The EPFs discussed throughout this EPP are shown on Figures AM- 06 -T -01 through AM- 06 -T -07. In addition to these EPFs, a number of internal systems also exist to provide additional control. The internal systems are classified separately to identify those systems that while serving an important function at the Site, are not absolutely necessary for the control, and prevention of a release, of acid mine drainage, or toxic or acid - forming materials. The EPFs and internal controls are listed in Table T -3 and detailed descriptions of all systems are provided in subsequent subsections, organized by watershed. An extensive clean water interceptor system has been established at the Climax Mine to convey un- impacted storm water around the process facilities and TSFs and to limit the amount of water to be treated and discharged. These systems, constructed primarily in the 1970s prior to the enactment of the DMO regulations, do not have specific, approved designs associated with them. Climax recognizes their importance to the overall water management system, but notes that the clean water interceptors do not appear to meet the definition of an EPF since they carry only un- impacted water around the Site and do not contain or control designated chemicals or process solutions. As agreed upon with DRMS, although these systems are considered to be pre -EPF systems and do not contain or control designated chemicals or process solutions, they will be managed by Climax as internal EPFs. The interceptor systems are closely monitored, inspected and maintained as part of routine site monitoring activities. Other than repair and maintenance, any future expansion or modifications of the interceptors will be subject to review by DRMS, consistent with Section 6.4.21(10)(a)(ii) of the Rules. EPP: Revision R1 T -13 July 2011