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During active mining operations, the site activities were developed in accordance with the rules <br />and regulations of the DMG, and the ERP was the mechanism by which the DMG ensured that <br />adequate plans and controls were in place to manage potential spills associated with the mining <br />activity. The ERP as developed under DMG rules and regulations is comparable to, and <br />completely compatible with, the Spill Prevention Control and Counter Measures Plan (SPCC) as <br />defined in the rules and regulations of the Colorado Department of Public Health and Environment <br />( CDPHE). Thus, the ERP satisfies the regulatory requirements for both the DMG (Mine Permit <br />M -88 -112) and the CDPHE Colorado Discharge Permit System (CDPS No. CO- 0045675) permit <br />that was authorized for operation of the West Pit water treatment facility in December 2000. <br />Additionally, the information contained herein satisfies the requirements set forth in 29 CFR <br />1910.1200 Occupational Health and Safety Administration (OSHA) Hazard Communication <br />Standard (Workers Right to Know). <br />The ERP was revised in October 1999 to reflect changes at the mine site associated with <br />implementation of the TR -26 water management plan. The 1999 plan included a description of <br />material containment and solution management at the water treatment facility. Since late 1999, <br />the water treatment facility has been upgraded and refined to optimize the water treatment process. <br />These modifications and concomitant effects on material management are described and <br />incorporated in this update such that the ERP will also satisfy the requirement for an SPCC for the <br />water treatment facility as specified in the CDPHE permit. <br />Sections of the ERP /SPCC that pertain to activities associated with surface land reclamation (e.g., <br />fueling and lubrication of heavy equipment) have been retained, with the pre- existing emergency <br />response plans for those activities intact. <br />2.0 OBJECTIVE <br />This ERP /SPCC has been developed for the San Luis Project to address spill prevention, <br />emergency response, and materials containment using industry and regulatory approved handling, <br />storage, containment, response, and notification practices. The plan is complementary to the <br />ERP and SPCC Plans AES, Inc. <br />Battle Mountain Resources — San Luis, CO 2 April 2015 (Update) <br />