2013-11-27_REVISION - M1990057 - Laserfiche WebLink

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Mr. Michael Cunningham 19 CDRMS November 26, 2013 require that all pipelines and cells be drained at all times when the site is unmanned, please provide a commitment to do so. Response: The following will be added to Section 14.6.2 in the permit: (i)Designated Chemical Handling during Temporary Cessation or Final Production UMC commits to the following procedure during periods of temporary cessation or final production. • All ore in process (from the course ore bin through thickeners and filter presses will be cleaned out. This will be accomplished per normal operation procedures. At full capacity, the mill cannot hold more than 200 tons of material. All material will report to either the concentrate room in super sacks for sale or to the TSF. • Liquid reagents in piping will be manually drained into buckets and placed back in their barrels. • Solid reagents will report, as with ore, to concentrates or the TSF. • Once all material in the system is processed, remaining process water will be pumped through the system to clean pipes, tanks, mill, float cells and thickeners, and will report to the TSF. • During temporary cessation, liquid reagents and lubricants will be kept in their original barrels /containers within overpacks, and solid reagents in their bags. All inventory will remain in the Mill Building which will be secured and /locked. There is no permanent diesel storage onsite. • During closure reagents will be either sold or properly disposed of at an EPA approved disposal facility. • Lubricants will be collected in barrels and recycled at the local landfill. 41. The Reclamation Plan states that chemicals and petroleum hydrocarbons will be removed from the site and disposed. As required by Rule 6.4.21(6)(a), describe how all designated chemicals will be disposed of and detoxified at the conclusion of operations so as to comply with all applicable environmental protection and reclamation standards of the regulations. Response: Addressed in question 40. 42. Rule 6.4.21(18)(b), requires the Applicant to describe measures to prevent wildlife from coming into contact with designated chemicals or toxic or acid forming chemicals. The TSF is the only area within the Leadville Mill where wildlife could come into contact with designated chemicals. How does the Operator intend to prevent wildlife from coming into contact with the TSF? See additional comments under Exhibit 8, No. 3.