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 19
In addition, to address redundant containment at each of these Environmental
Protection Facilities, Wildcat will modify the Containment Facility Adequacy section at
Pages 10 to 11 of Exhibit U, as follows:
DEN 97,599,531v1 9 -9 -11
In addition, Wildcat has employed certain measures to
achieve redundant containment.
At the Base of Operations Affected Area, designated
chemicals are stored in enclosed zircon containers, which are
located within lined secondary containment berms. Diesel
fuel and gasoline are stored in above ground storage tanks,
which are located within lined secondary containment berms.
Each of these facilities is located at the southern boundary of
the Base of Operations and along CR -124. In order to
prevent run -on from drainage at CR -124, Wildcat has also
elected to install a berm for run -on control, noise control and
visual screening between CR -124 and the zircon containers
and above ground storage tanks. (See Figure C6.11). This
berm creates additional redundancy by preventing any spill
from mixing with water running onto the Base of Operations.
At the May Day No. 1 Affected Area, designated chemicals
are stored in enclosed zircon containers, which are located
within lined secondary containment berms capable of
containing twice the amount of materials that could be
stored within the zircon containers. Diesel fuel and
gasoline are stored in above ground storage tanks, which are
located within lined secondary containment berms. In
addition, the mill, filter press and recycled water storage tank
are all located in enclosed structures with stem walls for
secondary containment. Wildcat will implement the work
plan presented infra in Section 6.4.21(10) of Exhibit U to
evaluate the concrete floor, stem wall and roof of the mill
building and Filter Press Building, which also contains the
recycled process water storage tanks, for leaks or cracks,
design a method to seal any leaks and cracks, implement a
scope of work to seal any leaks or cracks, and obtain a
licensed professional engineer certification of mill
building as Environmental Protection Facility. Tailings
from the processing unit will be conveyed from the mill in
4 inch, heated, dual walled HDPE pipe to the
filter /vacuum press. The filter /vacuum press will be
located less than 50 feet from the mill. (See Attachment
GREENBERG TRAURIG, LLP • ATTORNEYS AT LAW • WWW.GTLAW.COM