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LAIRAv SILVER MLNES <br /> encountered. <br /> b. The ERP specifically addresses responding to spills or fires of flammable <br /> or corrosive chemicals. No response was provided regarding the other 4 <br /> chemicals housed in the Reagent Room. <br /> c. The ERP should include cleanup/disposal measures for split liquids, and <br /> water used to fight fire or clean up afterwards that has come in contact with <br /> chemicals.Specifically the plan mentions contaminated soil clean up but <br /> not water. Any material that comes in contact with a chemical will require <br /> hazardous waste disposal. <br /> d. To aid in emergency response the Division recommends that MSDS' are <br /> stored ina location on the mine site a safe distance away from where <br /> chemicals are expected to be encountered,preferably near the entrance. For <br /> example a typical practice is to store their MSDS's and Emergency <br /> Response Plans in a mailbox at the primary site entrance in addition to <br /> muster locations. <br /> e. Upon approval of this revision (and specifically this Emergency Response <br /> Plan) commit to providing each organization listed in section 1.2.1 of the <br /> emergency response plan with a copy of said plan. <br /> Response: <br /> a. The ERP has been updated to include a list of designated chemicals that may be <br /> encountered during an emergency. <br /> b. The ERP has been updated to include emergency response procedures associated <br /> with the other 4 chemicals housed in the Reagent Room. <br /> c. The Division is incorrect in its statement that "any material that comes into <br /> contact with a chemical will require hazardous waste disposal. " The ERP will <br /> include protocols for cleaning up and disposing of spilled chemicals or water used <br /> to fight fires that comes into contact with chemicals. These materials, if <br /> encountered, will be properly characterized in accordance with the Colorado <br /> Hazardous Waste Regulations and the Resource Conservations and Recovery Act <br /> and disposed of accordingly. <br /> d. According to MSHA Hazard Communications Procedures (30CFR Part 47.54), <br /> The Operator must make MSDSs accessible to miners during each work shift for <br /> each hazardous chemical to which they may be exposed either—a) At each work <br /> area where the hazardous chemical is produced or used, or b) at an alternative <br /> location, provided that the MSDS is readily available to miners in an emergency. <br /> OSMI appreciates DRMS's suggestion for placing the SDSs in a mailbox at the <br /> entrance to the mine, but that suggestion does not comply with MSHA HazCom <br /> regulations, which explicitly state that SDSs must be available at the point of use. <br /> 151Pa , e <br />