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4.0 Water Treatment Operations <br />At the request of Energy Fuels, Lyntek prepared an Operations and Maintenance (O&M) Manual <br />for the Whirlwind Treatment Plant. This manual includes: <br />1. Instructions for operating the plant including a spread sheet for calculating chemical mix <br />ratios. <br />2. Drawings of the plant and flow sheet. <br />3. Cut sheets and O&M information for the various plant components including the flow <br />meter, metering pumps, Webmaster system, mixers, reagent and reactor tanks, safety <br />equipment, and electrical panels and heaters. <br />4. MSDS sheets for the treatment chemicals. <br />The O&M Manual is to be considered a dynamic document that should be updated as the <br />treatment system is modified to improve performance. Cut sheets and O&M information for any <br />new equipment, including pumps, should be added to three-ring binder as they are purchased and <br />installed. <br />A preliminary Material Containment and Spill Prevention, Control, and Countermeasure <br />(MC/SPCC) Plan was prepared for the facility as part of the environmental permitting effort. <br />This plan, which is included as Attachment D, should be revised to reflect as-built conditions <br />within the first 30 days of operation. MSDS sheets and other information needed to respond to a <br />chemical spill must be included in the plan. A copy of the plan is to be provided to the Colorado <br />Division of Water Quality Control in accordance with the provisions of the facility's discharge <br />permit. Periodic plan reviews and updates are recommended on an annual basis and after any <br />significant changes in the treatment system. <br />At the time of inspection, an automatic shutoff had not yet been installed on the mine pump, as a <br />permanent underground pumping station cannot be set up until the water is pumped down <br />sufficiently to allow cleaning and rehabbing of the mine sump area. Until this safeguard can be <br />installed, pumping will only occur when treatment personnel are on site to monitor water levels. <br />During exploration activities the freeboard on the tanks should be maintained at 3 inches or more <br />5 <br />