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1 <br /> OUR4Y SILVER MINES <br /> a. In response 3(a)(i) of Adequacy Response #2 ASME Standard B31 and AWS D1.1 were <br /> referenced. Please explicitly state those standards. <br /> Response:B31 is the standard for pressure piping and AWS D1.1 is the standard for structural welding. <br /> Each standard is over 500 pages and is attached. <br /> 18. During the submittal of the as-built certifications of the reagent room, in the final overall drawings <br /> of the building please identify the location of the septic tank leach field. <br /> Response: The area that the leach field is located will be identified in as-built certifications. <br /> 19. Commit to storing containers in secondary containment for those where containers containing <br /> spilt chemicals that are to be returned to the manufacturer or awaiting results of hazardous waste <br /> determination testing be stored while waiting for off-site transport pursuant to Rule 6.4.21(6)(b)(i). <br /> Response: The mine commits to storing containers on secondary containment for containers with liquid <br /> chemicals that are to be returned to the manufacturer or are awaiting results of waste determination <br /> testing. <br /> 20. With regards to disposal of empty chemical containers.The Division has contacted CDPHE to verify <br /> OSMI's interpretation of Colorado Hazardous Waste Regulations (6 CCR 1007-3, Section 261.7). <br /> CDPHE has confirmed that with regards to chemicals used forthe purposes of beneficiation for mining <br /> that a container is considered `empty' if it contains less than 10%by volume and it may be disposed <br /> of as solid waste. It is noted that the solid waste disposal facility may still choose to reject the <br /> waste which would then require the containers to be taken to another permitted facility. In <br /> reviewing the proposed reagent list provided thus far with CDPHE, they did state that extreme <br /> precaution should be taken to ensure that containers are as empty as possible since several of the <br /> chemicals are either flammable or reactive. <br /> Further guidance from CDPHE included: <br /> a. All chemicals(pure or mixed),process water,sludges(tailings)or other solid waste generated <br /> from the milling process will require a hazardous waste determination prior to disposal. <br /> TCLP testing should be conducted on all wastes. <br /> b. Any materials that fail TCLP testing will be required to be disposed of as hazardous waste. <br /> c. Material with a pH less than 2 or greater than 12.5 that pass TCLP testing is eligible to have <br /> its pH adjusted to allow for non-hazardous waste disposal (subject to facility acceptance). <br /> d. Although it is non jurisdictional for the Division,please ensure compliance,where necessary, <br /> with SARA Title III Program with the Colorado Department of Health and Environment <br /> for reagents stored within the DRMS Permit Boundary and at the offsite storage location <br /> at OSMI's warehouse. <br /> Please note that many of the waste streams cannot be accurately determined until completion of <br /> mill commissioning and wet testing. That being said, concerns regarding disposal of chemicals (pure <br /> or mixed), process water, sludges (tailings) or other solid waste generated from the milling process <br /> will be addressed under TR-15 (Mill Certification). <br /> Response: OSMI appreciates the additional information provided by the Division. <br /> 61Page <br />