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 T -1 Introduction T -1.1 Purpose and Objectives In April 1994, the Colorado Mined Land Reclamation Board (Board) approved and promulgated amendments to the Mineral Rules and Regulations for Hard Rock, Metal, and Designated Mining Operations (Rules) under the Colorado Mined Land Reclamation Act (Act). The most important of these changes was the classification and definition of a "Designated Mining Operation" and the addition of Section 6.4.20 Exhibit T - Designated Mining Operation Environmental Protection Plan in Rule 6 (the current amended version of the Rules, effective September 30, 2010, now address Environmental Protection Plan requirements in Section 6.4.21 — Exhibit U). A "Designated Mining Operation" (DMO) is defined as a mining operation where: • designated chemicals used in metallurgical processing are present on -site; or • 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. The Colorado Division of Reclamation, Mining and Safety (DRMS — formerly "Division of Minerals and Geology" or DMG), the agency that administers the Mineral Rules and Regulations, formally notified the Climax Mine that it was a DMO on August 3, 1994 (letter to Mr. Frank Zancanella). The Climax Mine concurred with the designation on August 31, 1994 (letter to Mr. Bruce Humphries, DRMS). Briefly, the purpose of the Environmental Protection Plan (EPP) is to define how the DMO operator will protect those areas that potentially could be affected or impacted by "designated chemicals, toxic or acid - forming materials or acid mine drainage." "Designated Chemicals" are defined in Rule 1, Section 1.1 (13) as "toxic or acidic chemicals used within the permit area in extractive metallurgical processing, the use of which, at certain concentrations, represents a potential threat to human health, property or the environment." DRMS has jurisdiction over the designated chemicals used in mineral production processes. Climax Molybdenum Company - Climax Mine (Climax) originally submitted the Climax Mine EPP as Technical Revision 7 (TR -07) to its existing Regular 112(d) Mining and Reclamation Permit (Number M- 1977 -493; "Permit') on August 11, 1995. The objective of this document is to update the EPP as Technical Revision TR -018 to reflect the current and future protective measures to be used during mining and milling operations. For purposes of the record, the Climax Mine is wholly owned and operated by the Climax Molybdenum Company (CMC), a wholly owned subsidiary of Freeport- McMoRan Copper and Gold, Inc. with headquarters in Phoenix, Arizona. T - 1.1.1 Reference and Indexing Since the Climax Mine is considered by DRMS to be an active operation with an approved life -of -mine Permit, much of the information and data required for the EPP has been developed previously. In order to create an EPP document that encompasses the current elements of the original EPP and amendments and revisions, this document is designed to supersede the existing EPP. Previously submitted information regarding design details or construction certification of EPFs is not included in this EPP, and may not be specifically referenced but is part of the public record and official Permit files. T - 1.1.2 Changes in Referenced Information and Documents Changes in the reclamation plan can trigger the need for submittal of a formal Amendment, Technical Revision, or Modification depending upon the type of change as defined in the Rules. Because the EPP references numerous public record documents and information on file with the DRMS and other state regulatory agencies, notification relative to changes, particularly minor ones, can rapidly become unwieldy for both Climax and the DRMS. Therefore, Climax proposes to handle minor changes in referenced EPP: Revision R1 T -1 July 2011