2012-10-05_REVISION - M1977342 (12)

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TR -18 to Permit M- 1977 -342 Environmental Protection Plan and (in some cases) tertiary containment at the release site ultimately would be contained at the tailings storage facility. The specific EPFs for designated chemicals at the Mill are discussed below, and in more detail in the SPCC /MCP (Appendix A). Mill EPF 2.1 — Nokes Building: Liquid sodium hydroxide is stored in two 12,300 gallon tanks located in the fully enclosed Nokes building directly adjacent and north of the mill building. Dry P is stored in 4,000 pound aluminum tote bins in the Nokes building. Storage capacity is 80,000 pounds. As discussed previously, P is mixed with sodium hydroxide in a 10,500 gallon tank to make Nokes reagent. Once mixed, Nokes reagent is pumped to a 21,800 gallon storage tank within the mill building. Effectiveness: The tank room is designed with floors sloping toward a sump and secondary containment with capacity to contain 110 percent of the release from one tank. Spilled material would be pumped from the sump directly to the concentrate thickener. Nokes reagent is transferred to a 21,800 gallon tank within the mill building where releases would be fully contained. Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC /MCP (Appendix A) by Mill personnel to assess effectiveness and integrity of each EPF system. The tanks are equipped with sonic level detectors and local alarms that warn of high tank levels. The Mill sump also contains a high level alarm to provide warning in the event of a large release. Tank integrity testing is performed in accordance with the SPCC /MCP, currently every ten years. Maintenance and /or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases. Mill EPF 2.2 - Hydrochloric Acid Storage: Hydrochloric acid is stored in one 50,000 gallon tank located in the acid storage yard outside and just north of the mill building. Two tanks reside at this location, one of which has been decommissioned. Hydrochloric acid is introduced into the lead -leach circuit within the mill building. Effectiveness: The area is fenced, and the tanks are surrounded by an earthen berm that has a containment capacity of 84,000 gallons. The berm is lined with limestone. A collection sump captures any free liquid that might be spilled. Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC /MCP (Appendix A) by Mill personnel to assess effectiveness and integrity of each EPF system. The Mill sump also contains a high level alarm to provide warning in the event of a large release. Integrity testing is performed in accordance with the SPCC /MCP, currently every ten years. Maintenance and /or updates to facilities, systems, equipment, or procedures are performed as needed to be protective of the environment and to prevent releases. Mill EPF 2.3.a — Flotation Chemical Storage - OrePrep F -579, a frothing agent used in the flotation process, is stored in 250 gallon totes in the mill building. Effectiveness: Releases of this chemical would be contained directly by the mill sump system. The Mill sump also contains a high level alarm to provide warning in the event of a large release. Climax Molybdenum Company Henderson Operations October, 2012 Page 21 of 40