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 2.7 - Sodium Lauryl Sulfate Storage: Witconate is a precursor to the frothing agent Syntex that is mixed with hot water in the mill process. It is stored inside the mill building in 200 pound drums. Maximum storage quantity at the Henderson Mill is 50 drums. 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. 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 2.8 - Tergitol NP -9/9N9 Surfactant Storage: NP -9/9N9 is a surfactant used in the lead leach circuit in the mill process to prevent "lumping" of concentrate. It is stored as a liquid in a storage tank with a capacity of 9,400 gallons. Prior to its addition into the mill circuit, NP -9/9N9 is pumped to a gravity feed tank with a 500 gallon capacity. 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. 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 2.9 — Coherex Storage: Coherex is a hydrocarbon based chemical used for dust suppression and has a proven record as an effective dust suppressant in the mining industry and elsewhere. Its use at Henderson to suppress the release of airborne particulates from the beach area of the tailings storage facility has also been highly effective. Coherex is stored in two 10,000 gallon tanks near the tailings storage facility maintenance building. It is a biodegradable, hydrocarbon based suppressant which consists of 50 percent petroleum resins and 40 percent wetting solution. The solution is mixed at a ratio of 1 part Coherex to 5 parts water and is applied with a 3,000 gallon capacity TRYCO balloon -tired vehicle, a 2,800 gallon Terragator vehicle, and is also delivered via helicopter in the spring. Coherex is applied to the entire beach area in the spring season. Spot applications are made periodically during the remainder of the snow -free season as conditions dictate. Effectiveness: These tanks are dual - walled and are located within the process seep water area, providing tertiary containment. Climax Molybdenum Company Henderson Operations October, 2012 Page 23 of 40