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Mr. Dustin Czapla <br /> August 24, 2021 <br /> Page 5 <br /> controls that will prevent spilled materials from escaping the building and explain how the <br /> materials are sufficient to prevent seepage. <br /> • All spilled chemicals will be delivered to the disposal pit. (Id.) Applicant should be <br /> required to provide analysis of the interaction of process chemicals and wastes and how <br /> they might react when combined in the disposal pit. <br /> • The sump is represented as being secondary containment for all tanks and facilities used in <br /> operations. (Id.) However, the "sump area can hold about 5,000 gal of the tanks and <br /> facilities located within the mill building." 5,000 gallons is nowhere near sufficient to <br /> constitute secondary containment. Under the Clean Water Act, secondary containment <br /> must be sufficient to capture the entire capacity of the largest single container. 40 C.F.R. <br /> § 112.8(c)(2) and (11) (Spill Prevention, Control, and Countermeasures Plan <br /> requirements). Each cyanide leach tank has a capacity of 68,500 gallons. And the <br /> Applicant will operate four of those tanks. A spill from any one of the leach tanks would <br /> completely overwhelm the sump. Thus, the Mining Plan, as proposed, does not include <br /> secondary containment, yet the Applicant proposes to operate massive tanks of sodium <br /> cyanide next door to residential properties and drinking water wells. At a minimum, <br /> Applicant should be required to provide secondary containment sufficient to contain the <br /> full capacity of its largest vessel. <br /> • The Application lists multiple sumps that will be in use. (Table 4-10.) It is not clear how <br /> these sumps will be used, where they are or will be located, where they all pump to, how <br /> they are constructed, what types of materials might be captured by each sump, or whether <br /> any of these sumps are sealed. Applicant should be required to provide that information <br /> and to assure that all surfaces of every sump are sealed to prevent seepage. <br /> • The disposal pit is large enough to hold all of the process water and chemicals that would <br /> be at the Facility at any one time. So, in the event that all of the equipment and containers <br /> release their contents, the materials could be sent to the disposal pit. (Id.) However, the <br /> Mining Plan contains no demonstration that the sump is capable of pumping a release from <br /> the largest vessel, along with all the process water sent to in the normal course of <br /> operations,without overflowing. Applicant's proposed secondary and tertiary containment <br /> systems are a recipe for disaster. For this reason alone, the Application should be denied. <br /> • The Mill will have a laboratory. (Mining Plan § 4.2.3 at 4-10.) The Application does not <br /> describe how laboratory samples and chemicals will be disposed of. Presumably,they will <br /> go into the disposal pit, but there is no discussion of laboratory wastes, how they will be <br /> handled,or whether they are compatible with other wastes that will go into the disposal pit. <br /> Applicant should be required to identify the laboratory wastes and demonstrate that they <br /> are compatible for disposal in the pit with all other wastes. <br /> BURNS FIGA & WILL <br />