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TR -18 to Permit M- 1977 -342 <br />Environmental Protection Plan <br />Two formal site inspections (one in the spring and one in the fall) are performed and documented <br />to satisfy annual reporting requirements. These inspections are conducted by the site personnel <br />and include a review of: <br />• All disturbed areas; <br />• Areas used for material storage or handling that are exposed to precipitation; and <br />• Other areas with potential sources of pollution. <br />The inspections: <br />• Look for evidence of, or the potential for, pollutants entering the drainage system; <br />• Review the adequacy and upkeep of storm water management measures, sediment and <br />erosion control measures, and other BMPs identified in section 5.0 of the SWMP <br />(Appendix B); and <br />• Include a visual inspection of equipment needed to implement the plan, such as spill <br />response equipment. <br />Conditions not conforming to the SWMP (Appendix B) are proactively managed and corrected. <br />If revision of the SWMP (Appendix B) is required, such revisions are made and implemented <br />promptly. <br />Preventive maintenance tasks associated with the Henderson Operations are managed through a <br />computer based work order system. Required maintenance has been identified and established <br />for on -site equipment and processes. When new equipment is brought on -site, additional <br />maintenance tasks are identified as required. Any deficiencies in preventive maintenance are <br />identified during routine inspections performed by area workers and through regular area <br />inspections performed by members of the environmental department. When issues are identified, <br />they are brought to the attention of area supervisors and immediately addressed. Additional <br />tasks may be added to the work order system, as needed. <br />Climax Molybdenum Company <br />Henderson Operations <br />October, 2012 <br />Page 30 of 40 <br />