2009-09-25_PERMIT FILE - M2009076 (22)

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• these operating conditions (pH range of 7.5-9) as shown in the attached A Water Handbook for Metal Mining Operations, by Thomas R. Wildeman. Storage of lubricants, oils, and greases may be as follows: • Any 55 gal. drums may be stored outside, on wooden pallets to prevent rusting of steel bottoms. Drum openings shall be protected from rain with appropriate caps/plugs or a hand pump device installed. • Any 5 gal. plastic buckets may be stored outside. Spouts shall have appropriate caps in place when not in use. • Any quart containers, cartridges, or blocks shall be stored inside trailers. In the event of spills of any of the above liquid chemicals (excluding water), absorbent cloths shall be used to collect the liquids. Cloths containing flammable liquids shall be placed in an approved receptacle for such disposal, located in the Ball Mill Trailer. Cloths containing non-flammable liquids can be disposed of in municipal waste receptacles. Special disposal and handling methods of any particular material shall conform to those enumerated in the specific Material Safety Data Sheet. A current collection of these documents shall be located next to the First Aid kit located in the Ball Mill Trailer. There are NO designated chemicals used in this proposed mining operation, therefore no special emergency response plan is necessary. In the event that there is a spill of feedstock (waste rock and/or ore), the operators are instructed to STOP the activity and assess the situation. Once the source and cause of the spill have been determined, a plan shall be devised to prevent any further spillage. After the source has been stopped, the spill may be cleaned up. Cleanup shall include using machinery (loader, excavator, etc.) or manual tools (shovel, buckets, etc.) to scoop up the • material and return it to an appropriate place. An appropriate place is either the original point source, Crusher Feed Pile or whichever conveyor or feeder mechanism the material has spilled from originally. This will place the spilled material back into the regulated process stream. 6.3.3(2)(b) The processing plant facilities have been described at length in 6.3.3(l)(e) and 6.33(1)(m). The processed tailings produced are inorganic, consisting of silica & alumino silicate minerals, which are inert and meet SPLP standards for RCRA metals as shown in the attached lab results for waste stream characterization. This waste is water carried via pipeline to a settling impoundment. There is zero water discharge and the water and any leachate is nearly 100% recycled back to the mill as process water. A laboratory analysis of the tailings (solid and liquid constituents) are attached to the end of this Exhibit C to demonstrate the inert qualities and the fact that the tailings quality greatly exceed ambient and pre-existing conditions. Because of this, a liner will not be necessary for the Tailings Impoundment. The EPA recognized this, and in the cleanup methodology in their ROD R08-88/019 concerning the waste rock problem in this vicinity: "REPROCESSING ALTERNATIVE: THE REPROCESSING ALTERNATIVE CONSIDERS THE TAILINGS AND WASTE ROCK PILES AS AN ECONOMIC RESOURCE AND RECOVERS THE INHERENT MONETARY VALUE WHILE GENERATING A WASTE WHICH MAY NOT BE DETRIMENTAL TO THE ENVIRONMENT." "REPROCESSING WOULD BE A PERMANENT SOLUTION THAT ELIMINATED COLLAPSE OF THE TAILINGS AND WASTE ROCK PILES. A NEW WASTE TAILINGS IS PRODUCED. LEACHING TESTS SHOW THAT THE NEW TAILINGS CANBE DISPOSED INA MUNICIPAL • LANDFILL. (emphasis added)" 11