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A490t., <br /> CAL'R4}'SILVER NIAES <br /> returned to the milling process by design. OSMI has responded to each of your <br /> specific questions below. <br /> a. 40 CFR Part 261.4(a)(17) specifically excludes materials within the primary <br /> mineral processing industry,from which minerals, acids, cyanides, water or other <br /> values are recovered, from the definition of a solid waste and therefore this <br /> material is not considered a hazardous waste. 40 CFR Part 261.4(a)(17)(iii)goes <br /> on to state that these materials may be stored within tanks, containers or buildings <br /> provided such buildings are designed, constructed and operated to prevent <br /> significant release to the environment. <br /> The mine's SPCC plan defines a spill as something that escapes into the <br /> environment. Since the material is not leaving secondary containment, it is not <br /> considered a spill. It is also not being returned to the original container. Rather <br /> this material is collected in sumps and is put back into the mill process. The sumps <br /> within the mill and reagent buildings are incorporated as part of the overall <br /> concentrating process by design to capture both ore and process water and return <br /> to the milling process to enhance recovery. <br /> b. See response to Comment I5.a. <br /> C. <br /> i. Thank you for pointing out this discrepancy. The flocculant sump reports <br /> to the flocculant mixing tank and the lime sump reports to the tailing <br /> thickener tank as an industry standard design, which was completed by <br /> Barr Engineering. <br /> ii. Water and residual materials remaining in tanks during final reclamation <br /> will be tested and disposed of in accordance with 40 CFR 261 (RCRA <br /> Regulations) and Colorado Hazardous Waste Regulations. <br /> d. The sump located in the lime containment area is for lime. Outside of the <br /> designated containment areas the floor of the reagent room is sloped to have a low <br /> point in the middle as shown on drawing 700-GA-001. A floor sump will be used <br /> to collect material in this area. Depending on the chemical and nature of the <br /> material, the sump will report back to the mixing tank and be reintroduced to the <br /> process. <br /> e. Drawing 500-PI-001 is attached and shows the lime sump reporting to the Tailings <br /> Thickener Tanks. <br /> 16. Please indicate the anticipated total volume of processed water to be stored on <br /> site at any given time pursuant to Rule 6.4.21(6)(b)(i). Is there a storage tank <br /> location or is the total volume stored throughout the piping of the facility and the <br /> various equipment? <br /> 11 Pae <br />