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• • <br />As a result of numerous spills, WRN has submitted (January 20, 1999) an action <br />plan to address remediation of spill areas, but in order to eliminate spills, WRN <br />will develop written operational procedures for start-up and shut-down of wash <br />water system. A check list will be a mandatory requirement for use of the wash <br />water system. Also as part of the check list, a map of all valves associated with <br />the system will be utilized to ensure water is supplied only to desired location, <br />and just as important, the system is shut down after use and all lines are drained <br />to plant or wellhead. Each time a recovery well is shut down and there is a need <br />to prevent scaling a contractor will be used to haul fresh water to recovery well. <br />If dilution water is necessary during well field operations the wash water system <br />will be utilized after management approval and utilizing a check list which <br />requires a step by step sequence for start-up and shut-down. Other actions <br />planned include re-establish 1 A-SHR mud pit capacity; and after an outage or <br />start-up of the well field, an inspection of the well field will be required to verify <br />there is no leakage of the wash water or process lines. <br />In summary, WRN and IMC corporate level management are aware of excessive <br />spillage history and have made a commitment that the above action will be <br />performed. As result of your letter dated 2-5-99, a check for $300.00 will be <br />submitted to cover this technical revision ($150.00) and the requested action plan <br />($150.00), in separate correspondence prior to March 1, 1999. Notification to <br />the State WQCD and BLM is also required as a result of leakage off the pad and <br />into a dry streambed. <br />If there are any questions please call Bob Warneke or myself. <br />Sincerely, <br />~~~~--~. <br />Ed Baker ,REM <br />Environmental/Safety Manager <br />cc: BLM <br />WQCD <br />Bob Warneke <br />