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mined materials. The report does acknowledge that at least one substance observed — a copper <br /> based solution — is "designed for high performance metallization in the printed circuit board <br /> industry." <br /> 42. RFES' milling equipment can be and is used to process innumerable products in <br /> RFES' recycling and manufacturing operations including, but not limited to, solar panel glass, <br /> computer boards, and consumer and industrial electronics. The refining process uses many <br /> different chemicals and reagents depending on the type of job RFES is performing for different <br /> clients. DRMS inspectors did not ask the RFES representatives present any questions about how <br /> the observed equipment was used or the purpose of any chemicals or substances stored on site. <br /> 43. DRMS' inspection report indicates that DRMS observed cyanide agitator tanks <br /> running at the time of inspection in a "secondary room" within the Facility's main building. The <br /> inspection report does not contain any description of how these agitator tanks are used in any <br /> purported mining operation. <br /> 44. Many different recyclables can be leached using agitator tanks from a diverse array <br /> of products, including but not limited to, electronics, scrap jewelry, and industrial metal. DRMS <br /> inspectors did not ask the RFES representatives present any questions about how the observed <br /> agitator tanks were being used. <br /> 45. DRMS' inspection report opines,without explanation,that the secondary room was <br /> being used as a "laboratory." Because refining and recycling operations require the use of filter <br /> presses and filtration, the room about which DRMS made this observation contains filtration <br /> glassware. The room is not used as a laboratory. DRMS inspectors did not ask the RFES <br /> representatives present any questions about purpose or function of the glassware observed in the <br /> secondary room. <br /> 46. DRMS' inspection report indicates that the inspectors "did not observe spill <br /> containment equipment or products, ventilation hoods, first aid stations, eye wash stations, or <br /> emergency showers"at the Facility,which the report contends"would be standard safety measures <br /> in a permitted or regulated mill facility of this sort." <br /> 47. Based on the locations the DRMS representatives purport to have inspected, the <br /> inspectors would have had to walk past at least three eye-washing stations that are present within <br /> the Facility. The Facility also contains a ventilation hood, first aid stations, and two showers on <br /> site. DRMS inspectors did not ask the RFES representatives present any questions about safety <br /> equipment on site. RFES' Facility has passed all safety inspections that federal labor safety <br /> regulators conducted. <br /> 48. DRMS' inspection report asserts that,because there was no secondary containment <br /> for any of the equipment or chemicals stored within the main building, there was the potential for <br /> processing solution to "flow out of the building and/or possibly into existing floor drains." <br /> 49. Not only are the Facility's rooms themselves containment facilities, each of the <br /> spaces where fluids are handled contain collection areas with sump pumps. Plastic spill <br /> - 7 - <br /> 4884-8560-1078.2 <br />