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2015-06-02_REVISION - M2014045 (8)
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2015-06-02_REVISION - M2014045 (8)
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Last modified
6/15/2021 6:00:28 PM
Creation date
6/4/2015 8:15:51 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2014045
IBM Index Class Name
REVISION
Doc Date
6/2/2015
Doc Name
Responses to 6/2/2015 Comments CN01
From
Braun Environmental, Inc.
To
DRMS
Type & Sequence
CN1
Email Name
TC1
Media Type
D
Archive
No
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be found to exist in greater concentrations than those found in regulatory standards, then <br />these designated chemicals remaining within the permitted area would be removed and <br />returned to the manufacturer or disposed of offsite according to the manufacturer's <br />recommendations and Federal, State, and local regulations. Any naturally occurring <br />compounds would be handled as per applicable to State and Federal standards. <br />Although not a designated chemical per Rule DRMS 1.1(13), but important from an <br />environmental stewardship perspective, an above ground fuel storage tank will be located <br />within the permit area. The tank(s) will have secondary containment as defined in, but not <br />required by 40CRF Part 112. Quantities of any other lubricants or additives that might be used <br />as part of the operation are anticipated to be in quantities below the volume threshold dictated <br />by the regulations. Spills and drips from compounds sourced from these fixed storage <br />containers that reach the ground surface are to be cleaned up and removed as rapidly as <br />possible after they are discovered. <br />7 FACILITIES EVALUATION <br />Per testing and previous evaluations of the permit area, there are no geological or geochemical <br />conditions or anticipated alterations to these conditions by any future operation that might <br />require any specific environmental protection including acid rock generation, acid mine <br />drainage, or designated chemical use. As a result, there are no outside environmental <br />protection facilities currently required or associated with the permit area, thus none to <br />evaluate. The petrology and mineralogy of materials that might be exposed to the environment <br />as part of the project are to be monitored by a QP, with the monitoring to be conducted on a <br />regular basis, and as part of the general operation. If evidence of rock having net acid <br />generating potential is found, or if low pH groundwater should ever be encountered, then <br />appropriate standard of the industry testing and evaluation will be conducted; first to show the <br />actual presence of acid generation, or of potential acid containing materials, and then to <br />determine the amount of risk and to develop requirements for their proper segregation and <br />isolation. Any and all testing and evaluation is to be performed by, or under the specific <br />direction of a QP. <br />DRMS personnel, in a June 2, 2015 review, demanded that measures be in put in place to <br />separate potential acid generating material, even though none has ever been found to exist. In <br />compliance with that order a plan is as follows. In the event some potential acid generating <br />material is ever identified, it will be retained and stored inside the mine so as to keep it <br />separated from outside weather and precipitation. For purposes of discussion, and assuming <br />that any is found, it would be expected to occur in small quantities, and if moved would most <br />4 <br />
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