2011-09-09_REVISION - M1981185 ‎(43)‎

• Permit No: M1981185
• IBM Index Class Name: REVISION
• Doc Date: 9/9/2011
• Doc Name: Response to Fifth Adequacy Letter
• From: R Squared, Inc.
• To: DRMS
• Type & Sequence: CN1
• Media Type: D
• Archive: No

Mr. Wallace H. Erickson
Response to Fifth Adequacy
September 9, 2011
Page 13
DEN 97,599,531v1 9 -9 -11
Environmental Protection Facilities. Wildcat has presented a conceptual
design for construction of a lined containment berm to provide secondary
containment for these zircon containers and the gasoline and diesel storage
tanks in Attachment D -2, Figure D -1 capable of containing twice the amount
of materials that could be stored within the structurezircon containers.
Wildcat has also specified that each zircon container will have steel doors
with locking capabilities.
o Wildcat has shown the zircon containers and gasoline and diesel storage
tanks at the Base of Operations on maps at Exhibit U, Figure D -1
(Environmental Protection Plan); and, Attachment D -1, Sheet C6.10 (Base of
Operations Site Plan) and C6.11 (Base of Operations Grading Plain). There
are three zircon containers at the Base of Operations. Wildcat has indicated
on Attachment D -1, Sheet C6.10 and Sheet C6.11, that one of these zircon
containers —the western -most zircon container —does not contain toxic
chemicals or acid forming materials, and therefore is not Environmental
Protection Facility. The two eastern-most zircon containers are designated
Environmental Protection Facilities. Wildcat has presented a conceptual
design for construction of a lined containment berm to provide secondary
containment for these zircon containers and the gasoline and diesel storage
tanks in Attachment D -1, Sheet C6.10 and Sheet C6.11 capable of containing
twice the amount of materials that could be stored within the zircon
containers. Wildcat has also specified that each zircon container will have
steel doors with locking capabilities.
o Wildcat will modify the Design Specifications, Designated Chemical
Storage, May Day No. 1 Affected Area section at Pages 18 and 19 of Exhibit
U, and Design Specifications, Designated Chemical Storage, Base of
Operations Affected Area section at Page 18 of Exhibit U, by adding the
following language to the end of the "Zircon storage sheds," "Diesel Fuel
Tank," and "Gasoline Fuel Tank" bullets:
• Wildcat will implement the following work plan to develop design
specifications, to construct and to obtain licensed professional engineer
certification of the zircon containers southwest of the mill building at the
May Day No. 1, the two eastern-most zircon containers at the Base of
Operations, and the gasoline and diesel storage tanks at both the May Day
No. 1 and Base of Operations, as Environmental Protection Facilities:
• Following construction of a lined secondary containment berm for
zircon containers and gasoline and diesel storage tanks, and
installation of zircon containers and tanks, inspect floor, and roof in
zircon containers, and secondary containment berms and liners, for
cracks or leaks;
GREENBERG TRAURIG, LLP • ATTORNEYS AT LAW m WWW.GTLAW.COM