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TR-34 to Permit M-1977-342 <br /> Environmental Protection Plan <br /> be regulated under CDPS Permit#CO-0000230. A renewal application for this permit has been <br /> submitted to the WQCD with modifications to include the WTP discharge. <br /> Monitoring: Monitoring will be performed to meet the requirements of the CDPS permit. <br /> 7.2.2. Designated Chemical Storage Facilities <br /> EPFs for designated chemicals at the Henderson Mill site include enclosed buildings, trailers, <br /> tanks, bins and berms, individually or in combination. The ultimate emergency EPF for all <br /> designated chemicals is the TSF/seep water collection and containment system discussed in <br /> Section 7.2.1. As stated previously, the Mill site and its ancillary facilities are located within the <br /> Ute Creek drainage. Therefore, accidental release of a designated chemical or process water at <br /> the Mill which is not captured by primary, secondary, and (in some cases) tertiary containment <br /> at the release site ultimately would be contained in the TSF. The specific EPFs for designated <br /> chemicals at the Mill are discussed below. <br /> Mill EPF 2.1 — Sodium Hydroxide Storage: Located directly adjacent and north of the Mill <br /> building,this facility was used to make liquid Nokes reagent prior to 2019.As Nokes is no longer <br /> mixed onsite, the Nokes mixing tank has been cleaned and emptied. However, liquid sodium <br /> hydroxide continues to be stored in two 12,300 gallon tanks located in this building as well as <br /> a 2,000 gallon head tank inside the Mill building. <br /> Effectiveness: The tank room within the storage building is designed with floors sloping toward <br /> a sump and secondary containment with the capacity to contain 110 percent of a release from <br /> one tank. Spilled sodium hydroxide would be pumped from the sump directly to the <br /> concentrate thickener. <br /> Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC <br /> by Mill personnel to assess effectiveness and integrity of each EPF system. The tanks are <br /> equipped with sonic level detectors and local alarms that warn of high tank levels. The Nokes <br /> building sump also contains a high-level alarm to provide warning in the event of a large <br /> release. <br /> Maintenance and/or updates to facilities, systems, equipment, or procedures are performed <br /> as needed to be protective of the environment and to prevent releases. <br /> Mill EPF 2.2 - Hydrochloric Acid Storage: Hydrochloric acid is stored in one 50,000 gallon tank <br /> located in the acid storage yard outside and just north of the Mill building. Although there are <br /> two tanks at this location, one has been decommissioned. Hydrochloric acid is introduced into <br /> the lead-leach circuit within the Mill building. <br /> Effectiveness:The area is fenced, and the tanks are surrounded by an earthen berm that has a <br /> containment capacity of 100,000 gallons. The containment is lined with a limestone bedding <br /> material that acts to absorb and neutralize spills. A collection sump captures any free liquid <br /> that might be spilled. <br /> Monitoring: Chemical storage containers are routinely inspected in accordance with the SPCC <br /> Plan by Mill personnel to assess effectiveness and integrity of each EPF system. The Mill sump <br /> also contains a high-level alarm to provide warning in the event of a large release. <br /> Climax Molybdenum Company August,2021 <br /> Henderson Operations Page 25 of 45 <br />