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 outfall. The complete responsibility accepted by Climax for water treatment/management within the . headwaters area of Tenmile Creek is reflected in the Water Quality Control Commission's 1987 rulemaking regarding the Climax outfall, in which the Commission stated: The evidence in these proceedings on Ten Mile Creek have shown that Ten Mile Creek for all intents and purposes begins at the Climax property boundary at a place designated as the ` Parshall Flume." It is at this point that the natural flows that are intercepted by Climax in the Ten Mile Creek Basin are channeled together and form the source of Ten Mile Creek. Hence the Commission believes Parshall Flume to be the source of the mainstem of Ten Mile Creek. Also included in this segment are all tributaries to Ten Mile Creek including those natural tributaries intercepted by Climax. (5 CCR 1002 -33.11 & 33.16) Storm water management information for the Climax Mine site is discussed throughout this EPP. Storm water is managed in accordance with Storm Water Permit COR- 040178. T -8 Water Quality Monitoring Plan As discussed previously, a Groundwater Monitoring Plan for the Climax Mine was previously submitted to DRMS as TR -08 in September 1995. That plan included monitoring locations and a monitoring schedule, which has been followed since that time. An updated Water Quality Monitoring Plan is included in the Environmental Protection Plan as Appendix T -C. This current plan expands upon the previous plan and includes additional points of compliance, identifies appropriate standards, and includes internal monitoring locations upgradient of Clinton Reservoir and Eagle Park Reservoir. This monitoring program is intended to provide data for: (1) demonstrating that EPP requirements are being met; and (2) evaluating changes in water quality that may be related to mining and milling operations at the site. It also provides a process for identifying when changes may be occurring so that appropriate actions can be taken to prevent adverse off -site impacts. T -9 Climate and Air Quality Information regarding climate as required in the EPP Rules is presented in Permit Amendment AM -06 Exhibit K — Climate Information. In addition, details regarding air emissions and the fugitive dust control plan are found in the Construction permit issued by the Air Pollution Control Division of the CDPHE. T -10 Geochemical lnformation Geochemical data, including acid /base accounting, pH data and metals data (both SPLP and total metals), have been summarized and are included as Appendix T -E. Data were collected from overburden material, road fill material, tailing material, and material from each of the TSFs. Soil samples were analyzed, as well as water samples from waste rock reactors constructed on McNulty OSF. The data are summarized in several tables identified as Tables T -E -1 through T -E -5. T -11 Construction Information Construction schedule information will be provided as new EPFs are proposed and designed. Design submittals for new EPFs will also describe the quality assurance (QA) and quality control (QC) program and measures to be employed during their construction. In general, the QA/QC program will consist of construction observation, inspection of materials for use in construction, survey control and field measurements, and appropriate field testing during construction to ensure that work is conducted and completed in accordance with the project- specific design and technical specifications. T -12 Plant Growth Media and Revegetation The Climax Mine site closure and reclamation plan is detailed in Permit Amendment AM -06, Exhibit E. Detailed soils information and maps are found in Permit Amendment AM -06, Exhibit I. EPP: Revision R1 T -32 July 2011