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<br />3.0 REGULATORY REQUIREMENTS <br />Upon startup of the Yankee Gulch Sodium Minerals Project (Yankee Gulch Project), a <br />final Response Plan will be completed. Rather than have a separate document for each <br />of the response plans that will be required by several regulatory agencies, this Response <br />Plan will be a single document. This one-document approach to satisfy multiple <br />environmental, safety, and other requirements will simplify the response measures and <br />reduce the duplication of information. Presented herein is the preliminary Response <br />Plan, which is intended to be a representation of the final Response Plan. Due to the <br />fact that certain final engineering design details and data have yet to be developed and <br />plant supervisory personnel are not yet employed, the final Response Plan will need to <br />be developed at a later date. However, it will be developed before startup of <br />commercial operations. This preliminary Response Plan is intended to be used to <br />address the current requests obtained during the public comment period of the BLM <br />EIS process. This document primarily focuses on spill response and provides less detail <br />on items such as fire protection, bomb threat response, and severe weather planning. <br />More information on these items will be provided in the final Response Plan. It is <br />important to note that development of many of the environmental and safety plans is <br />not required until project startup or up to 6 months after startup. <br />Response plans and response-related reporting requirements that are generally <br />associated with facilities similar to the Yankee Gulch Project facilities are listed below. <br />Plan or Reporting Requirement Name <br />1. Stormwater Pollution Prevention Plan (SPPP) <br />2. Resource Conservation and Recovery Act (RCRA) <br />Preparedness, Prevention, and Contingency Plan <br />3. Spill Prevention Control and Countermeasures <br />(SPCC) Plan <br />4. Occupational Safety and Health Administration <br />(OSHA) Emergency and Fire Prevention Plan <br />5. OSHA Hazard Communication Plan (HazCom) <br />6. Emergency Planning and Community Right-to- <br />Know Act (EPCRA) reporting <br />Regulatory Reference <br />40CFR Part 122 <br />40CFR Part 265 <br />40CFR Part 112 <br />29CFR Part 1910.38 <br />29CFR Part 1910.1200 <br />40CFR Parts 370, 372 <br />3 <br />Prelimmarv Response Plan <br />Yankee Gulch Sudmm Minerals Pru~ect <br />American Soda, L.L.P. <br />