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2021-05-12_REVISION - M2012032
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2021-05-12_REVISION - M2012032
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Last modified
1/19/2025 6:24:47 AM
Creation date
5/17/2021 6:08:33 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2012032
IBM Index Class Name
REVISION
Doc Date
5/12/2021
Doc Name
Adequacy Review Response
From
Ouray Silver Mines, Inc.
To
DRMS
Email Name
LJW
Media Type
D
Archive
No
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QJR4YSILVER MINES <br /> See Table 1 in TR-14. These are the maximum volumes of chemicals that will be on site at any time. <br /> Generally, chemicals are transported to the site by the chemical supplier or placed in consignment at the <br /> warehouse in the town of Ouray and stored appropriately under OSHA regulations. <br /> b. Clarify if the entire supply is stored within the Reagent Room or in various <br /> locations throughout the Revenue Mine site. <br /> The entire mine site supply will be stored within the Reagent Room. <br /> c. Volumes listed in Table 1 are generally less than a two week supply based on the <br /> total volume divided by the day tank size. Page 7 of TR-14 states "Chemicals are <br /> ordered under min/max and only a two-month supply will be available for use." <br /> TR-14 does not state how much is a two-month supply for each of the nine <br /> chemicals listed in table 1. Explicitly state the day use rate of each chemical. <br /> Reagent containment volumes are presented in Table 5 and dosage rates are found in Table 6. <br /> d. Please provide the total volume of containment of each room or area of the <br /> reagent room including the common area, as well as provide the demonstration <br /> that each area is sufficient to contain the maximum amount of chemical to be <br /> stored in each area at any given time. <br /> See Table 5 which indicates the volumes of each containment area and the volume of reagent found in <br /> each of them. The containments are concrete floors with footer walls. <br /> 3. For each of the chemicals listed in Table 1, that are stored in the 'common area' of the <br /> Reagent Room, please provide a discussion on the potential bi-products, including safety <br /> or environmental hazards, created if the chemicals were to mix. (If a multi-system loss of <br /> containment were to occur) in accordance with Rule 6.4.21(5). <br /> There are no known hazardous byproducts created from the combination of any of the 4 chemicals that <br /> are in the "common area"of the Reagent Room. SDS sheets do not indicate that it is dangerous to mix <br /> these substances together. <br /> 4. Many of the MSDS sheets are lacking sufficient information to address Rule 6.4.21(5)(a). <br /> For any chemical listed in Table 1,with a rating of a 2 or higher on the NFPA(National Fire <br /> Protection Association) Classification, or any chemical with adverse effects or no data <br /> provided forecological/environmental effects, provide supplemental documentation <br /> based on the best available science to address Rule 6.4.21(5)(a). <br /> Please see Table 4 that summarizes the information found on SDS sheets. The Oreprep F-549 SDS is <br /> lacking environmental information on their SDS sheets. Oreprep F-549 is mixed glycol ethers. To <br /> supplement this information a peer review paper— "Ethylene Glycol Ethers:An Environmental Risk <br /> Assessment"is attached, the article indicates low environmental risk for these types of chemicals. <br /> 21Page <br />
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