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• Schwartzwalder Mine property each day, including 18-22 heav~~ <br />duty ore trucks, may carry hazardous materials adhering to <br />tires, wheels, undercarriage, and bodies. In the absence of <br />sufficient controls and an effective removal program, con- <br />taminated carryout may be routinely deposited on nearby <br />public roadways and rights-of-way, thereby exposing highway <br />users and maintenance personnel to above background levels of <br />radiation. We would like the Department of Health to provide <br />assurance that long-term carryout will not eventually result: <br />in a public health hazard. <br />Response <br />No response required. <br />f.nmmant <br />13-1-2. UNRECOGNIZED OR NON-DETECTED MINOR SPILLS - All crushed ore <br />from the sorter is presumably washed to eliminate dust, silt., <br />and fines. However, small particles from the 25 mesh scalping <br />screen and suspended solids from the dry pad are combined with See Attachment <br />the concentrated ore for shipment to the Canon City mill. P,lso <br />sludge from the holding ponds, mentioned on page 3-8, is <br />• periodically transported to the mill. Other than covering <br />loads with tarps, the document does not discuss the procedures <br />which have been established to assure that small particles, <br />sludge, or contaminated water do not escape in transit. We <br />request assurance that the long-term cumulative effect from <br />minor spills of these materials will not constitute a hazarc <br />to the highway user or maintenance personnel and will not <br />inadvertently contaminate public roads and rights-of-way. <br />Res onse <br />The Colorado Department of Health collected samples from <br />roadways along the route used by the trucks and found the <br />concentrations of uranium within the average for the Front <br />Range of Colorado. <br />Comment <br />13-1-3. SAFETY PROCEDURES FOR MAJOR SPILLS - In order to provide <br />a more complete discussion of safety plans which have been See Sec. 5.3 <br />developed, we would suggest that the following items be <br />addressed in the emergency response procedures for an <br />accident involving ore hauling trucks (pages 5-4 and 5-5): <br />What range in response time would be expected before <br />trained personnel were at the spill site? <br />• What special training or experience do drivers and <br />clean-up personnel have that may reduce the hazard <br />to the public? <br />rnu ~ <br />