2011-12-15_REVISION - M1977493 (2)

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Technical Revision (TR -18) Climax Molybdenum Company Environmental Protection Plan Permit No. M- 1977 -493 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 Information 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. T -13 Wildlife Protection Since the initial planning process for the Climax Mine Mining and Reclamation Permit in the early 1970s, wildlife resources have been important to, and recognized by, Climax. Colorado Division of Wildlife (CDOW) personnel have been involved in the review of permit applications and in planning assistance with various mitigation projects such as in stream habitat improvement in the upper Arkansas River. Information and data developed during permit planning are included in Permit Amendment AM -06, Exhibit H — Wildlife Information. Although wildlife issues at Climax have not been significant, Climax has maintained excellent communications throughout the years with both the regional CDOW office personnel and the local District Wildlife Manager. As described to DRMS (then DMG) in 2005, Climax has implemented a program to observe and report any wildlife related problems or concems. Employees undergo annual refresher training which discusses observations of site water bodies on a daily basis, how to report concerns if observed, and the importance of reporting observations promptly. This program has been in place for many years and will continue through renewed operations. As part of this program, Climax has worked with local CDOW personnel as necessary. All designated chemicals will be properly stored inside of structures to eliminate exposure to wildlife. Climax process water with high or low pH or elevated metals has not been identified as a problem for wildlife. Wildlife species, including large mammals, waterfowl, and shorebirds are commonly observed using the various water bodies throughout the property without apparent harm. Ongoing reclamation activities decrease the area of process water that wildlife may access, and staged water treatment between the SDP, Tenmile TSF and Mayflower TSF improve water quality in downstream areas, further minimizing potential impacts. Reclamation and reduction of those areas where wildlife may contact process water are continuing activities that serve to minimize potential impacts. Information regarding threatened or endangered species is also included in Permit Amendment AM -06 Exhibit H. EPP: Version R2 T -37 December 2011