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Scott, Eric <br />From: Lazuk, Raymond [Raymond_Lazuk @FMI.com) <br />Sent: Wednesday, June 27, 2012 10:05 AM <br />To: Scott, Eric M " 3 <br />Subject: Reagent testing at Climax Mill oc <br />i�Jl <br />Eric, ® ak.k, M, � l <br />This email is to follow up on our phone discussion of yesterday morning in which we discussed upcoming reagent testing at <br />Climax. Climax has been experiencing mixed results with molybdenum recovery using the mill reagents we selected during the <br />design phase of the project. We anticipated the potential need to make adjustments in our reagent type /usage during the start- <br />up of Climax and included language in our EPP to account for potential changes: <br />From Section T -3; Designated Chemicals of the EPP: " The information provided regarding designated chemicals is presented as <br />the best information currently available. These chemicals, quantities, and concentrations may vary based upon production <br />needs and processes. For example, brand name chemicals such as (but not limited to) Nalco 9741 may be changed out for <br />different brands of similar chemicals based on factors such as cost, effectiveness, material handling requirements related to <br />safety, or environmental reasons. Changes in brand and reagent usage are a part of the production process and are not <br />considered to be grounds for notification to the DRMS. However, notification to the DRMS will be made per the <br />review /reporting discussed in Section T -1.1.2 in the event that: 1) new types of chemicals, not discussed herein, are added to <br />the process; 2) the storage location of a designated chemical is changed; or 3) the specific containment facility for a designated <br />chemical must be modified." <br />To improve concentrator performance and recovery, we are reevaluating our collectors and frothers. To do this we need to run <br />some short -term, plant -scale tests. Our plan is to immediately begin testing the use of Calumet Hydrocal 60 as a collector. This <br />testing could potentially last up to 10 days, during which we would consume in the range of 150 gal /day. <br />In addition, we will be testing defoamers and frother replacements. The frothers will be focused on those in the alcohol family <br />and would be tested in quantities of 55 gal drums. Each test is likely to consume a full drum, if successful. If unsuccessful, the <br />test will be halted and the remainder of the material will be returned to the manufacturer. <br />Based on the results of the testing we would determine which reagents may be needed for longer -term usage at Climax. Upon <br />this determination we understand there are requirements to incorporate certain information into the Emergency Response Plan <br />(per Rule 8.3) and the EPP (per Rule 6.4.21.(5)). We would make the necessary revisions to our plans and submit these as a <br />Technical Revision to our Reclamation Permit. If we choose to utilize petroleum -based reagents, we also will include the <br />necessary containment information and emergency response in our SPCC Plan and site -wide Emergency Response Action Plan. <br />Please let me know if you need any further information on the testing. <br />Thank you, <br />- Ray <br />Raymond Lazuk <br />Environmental Manager <br />Climax Molybdenum Company, Climax Mine <br />HWY 91 - Freemont Pass <br />Climax, CO 80429 <br />Office: 719 - 486 -7584 <br />Cell: 719 - 201 -1282 <br />raymond lazuk @fmi.com <br />