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9. Spill notification (Appendix F). Update spill prevention control plan for notification of <br />BLM hazardous material coordinator (Alan Kraus) of all reportable quantity spills <br />within 24 hours (see stipulation on Whirlwind NOI modification). <br />An updated Material Containment and Spill Prevention, Control and Countermeasure <br />(MC/SPCC) Plan will be developed for the site based on diesel tanks, generators, and <br />water treatment chemicals recently purchased for the site. This SPCC Plan will include <br />notification to the BLM hazardous material coordinator in the event of a spill of a <br />reportable quantity of a petroleum product, water treatment chemical, or other chemicals <br />found on site (e.g., antifreeze). The updated plan will replace the preliminary plan in <br />Appendix F of the Plan of Operations. <br />10. Page 5-12: Will roads be graveled? Any seasonal or weather restrictions? <br />Energy Fuels recently acquired surface alteration permits with Mesa County for John <br />Brown Road and 5/10 Road. These permits, which are renewed annually, allow Energy <br />Fuels to maintain these roads in the winter including snow removal and placement of <br />road base in icy or soft areas. Sumner maintenance on these roads will continue to be <br />performed by the county; however, Energy Fuels has permission on 5/10 Road to upgrade <br />drainage through the installation of culverts and ditches, add road base and gravel as <br />needed, and perform supplemental grading (the County grades 5/10 Road only twice a <br />year). Mesa County currently applies magnesium chloride on John Brown Road in late <br />spring /early summer from Highway 141 to the cattle guard just below the turn off to <br />5/10 Road. Energy Fuels has agreed to have a contractor apply magnesium chloride from <br />the cattle guard to the mine at the same time plus have additional applications of the dust <br />suppressant applied from Highway 141 to the Whirlwind Mine during the summer if road <br />conditions warrant. Depending on use levels, up to two additional applications may be <br />required per year. <br />Access roads within the mine area will be constructed of dirt or waste rock and will be <br />treated with magnesium chloride and water sprays, as necessary, to control dust. Gravel <br />sections will likely be limited to the main parking area and the main entrance road to the <br />Whirlwind Mine facilities. <br />Ore haulage will not be conducted when inclement weather results in unsafe road <br />conditions or where heavy truck traffic could significantly damage the county roads. The <br />Whirlwind Mine Superintendent and the ore haulage contractor will make the decision <br />whether to temporarily suspend ore haulage operations on a case-by-case basis. <br />Normally, this would occur after a heavy precipitation event. <br />Mesa County planning personnel are requesting that ore haulage operations be limited to <br />Monday through Friday during the warmer months (i.e., April 15 to October 15) to <br />reduce potential impacts on recreational activities in the area. This seasonal restriction on <br />ore haulage will be discussed during the Mesa County Planning Commission's upcoming <br />~i~~r~~~ }"c~c~;; lf.~:~;~~!~,-~.•.°~; ~'~~.~,c~~~<,ti~,77~ -'~~ t1F~i~~r~ If~y~7~~-~~ttc1. ~iul~c~ f~t.1t1 4 <br />