2012-10-05_REVISION - M1977342 (12)

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TR -18 to Permit M- 1977 -342 Environmental Protection Plan 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. 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.b — Flotation Chemical Storage - Orform D8 Depressant, a suppressant used in the flotation process, is stored in 450 gallon totes in the mill building. Effectiveness: As with OrePrep F -579, 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. 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. 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 2.4 - Pine Oil Storage: Pine oil, used in the flotation process, is stored in a 14,400 gallon steel tank located and contained in the oil room inside the mill building. Effectiveness: Releases in the oil room are contained by a concrete - walled secondary containment that is sloped to a system that channels the material to the mill sump system for either return to the mill circuit, or for routing to the tailings delivery line. The Mill sump also contains a high level alarm to provide warning in the event of a large release. 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. 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 2.5 - Collector Oil Storage: Collector oil is a product used in the flotation process within the mill. Vapor oil is generally used for this product, but Diesel #2 may be used as a backup. Vapor oil is stored in a 32,000 gallon steel tank contained within the oil room inside the mill building. Diesel #2 is stored in a 32,000 gallon steel tank in the oil room located within the mill building. Effectiveness: Releases in the oil room are contained by a concrete - walled secondary containment that is sloped to a system that channels the material to the mill sump system for either return to the mill circuit, or for routing to the tailings delivery line. The Mill sump also contains a high level alarm to provide warning in the event of a large release. 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. 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 2.6 — Syntex Storage: Syntex is a frothing agent used in the mill process. Syntex is a mixture of sodium lauryl sulfate (also referred to as Witconate) and hot water. It is mixed in a 5,700 gallon tank behind the regrind mills, then transferred to a 13,200 gallon storage tank. 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 22 of 40