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 documents and information by establishing a central file for the reclamation plan and associated EPP information and documents at the Climax Mine environmental office. Climax will conduct periodic reviews of the EPP to identify where changes have occurred and where changes may occur during subsequent years. T - 1.1.3 Emergency Response Plan for Designated Chemicals An Emergency Response Plan for designated chemicals is required as a component of the EPP to comply with Sections 34 -32 -103 (4.9) and 34 -32- 116.5(5), C.R.S 1984 and Section 8.3 of the Mineral Rules and Regulations of the Colorado Mined Land Reclamation Board for Hard Rock, Metal and Designated Mining Operations (Rules). An Emergency Response Plan for Designated Chemicals at Climax is included as Appendix T -A. Climax also maintains a required Spill Prevention Control and Countermeasures (SPCC) Plan and a Materials Containment Plan (MCP). These documents describe procedures to prevent, control, and mitigate releases of chemicals to the environment and provide supplemental information pertaining to emergency response for designated chemicals. Copies of the SPCC /MCP are kept at the Climax Mine environmental office. T - 1.2 Description of Site The Climax Mine is an open pit and former underground mining operation that extracts, crushes, and processes molybdenite ore from the base of Bartlett Mountain and produces concentrate at the adjacent mill site. The final product is molybdenum disulfide (MoS2) concentrate that is transported out of the state for final processing. The Climax Mine, mill, and ancillary facilities are located near the summit of Fremont Pass (elevation 11,318 feet) where Colorado State Highway 91 crosses the Continental Divide. The mine is located approximately 12 miles south of 1 -70 at Copper Mountain, Colorado and 13 miles north of Leadville, Colorado. The site is located within the headwaters of three drainages on both sides of the Continental Divide and encompasses the upper reaches of the Arkansas River, East Fork of the Eagle River, and Tenmile Creek. Acreage affected by mine and mill operations lie within a contiguous 14,300 acre land block owned by the Climax Molybdenum Company. Site maps and maps of affected acreages are located in Exhibit C of Permit Amendment Application AM -06. The Climax boundary and affected areas also are included on Figure AM- 06 -T -01. The Climax Mine began underground operations in 1917 and operated intermittently until the 1920s when continuous mining and milling commenced. When Climax was originally permitted under the Colorado Mined Land Reclamation Act in 1977, production from the mine was approximately 50,000 tons per day from both underground and open pit operations. The estimated mine life at that time anticipated exhaustion of ore reserves in the year 2015. However, when the world market for molybdenum declined dramatically in the early to mid- 1980s, economics forced Climax to curtail mineral production and development substantially. In 1989, the reclamation permit was amended (AM -03) to better reflect the realities of long -term limited production at that time. This amendment addressed the role of Climax as a "swing producer" with limited and declining underground production and the ability to produce from the open pit in the future. Amendment AM -05 (July 2005) briefly discussed business plans for the Climax Molybdenum Company, recognized that the concept of "swing - producer" had become obsolete, and confirmed the active status of the operation. In 2007, Climax Molybdenum Company announced its intent to return Climax to production in 2010. Production would come from the open pit and processing would occur in a new, modem mill facility located adjacent to the pit. Old and obsolete infrastructure would be removed from the site. Demolition of unneeded site structures began in 2006 and continued through 2008. Climax initiated construction of new processing facilities in April 2008. In 2008, due to economic considerations, Climax temporarily slowed these construction activities associated with the restart of mineral extraction and production at the Climax Mine. Currently Climax is continuing to finalize plans and is constructing key infrastructure to enable the facility to resume production when the economic climate dictates. EPP: Version R2 T -4 December 2011