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Cotter Corporation (N.S.L.)'s Response <br />to December 14, 2010 Adequacy Review, Comment 1 -B -2 <br />April 28, 2011 <br />2) Rule 6.4.21(5) — Designated Chemicals Evaluation <br />In recent months new activities have occurred under Technical Revisions TR -12 <br />through TR -15, and perhaps other additional activities that might have resulted in the <br />introduction on site of designated chemicals that may not have been included in the <br />EPP that was submitted as TR -11. Please provide an updated inventory of designated <br />chemicals that takes into account the recent activities, in addition to designated <br />chemicals that would be required as part of the expansion of the water treatment <br />system to include treatment of the mine pool water. <br />Small amounts of nitric and sulfuric acid for water sample preservation are stored in the <br />water treatment building in special chemical storage cabinets that are specifically <br />designed to meet applicable safety requirements. These cabinets are located in an area of <br />the water treatment building that has secondary containment structures in place. <br />Water treatment media (resin) is housed in specially designed vessels, which are located <br />in an area of the water treatment building that has secondary containment structures in <br />place. When resin exchange becomes necessary, Water Remediation Technology, Inc. <br />(WRT) will perform the transfer of spent resin into specially designed totes in accordance <br />with procedures approved by CDPHE under radioactive materials license CO- 1177 -01. <br />Future reclamation activities are not expected to introduce any designated chemicals on <br />site. Current remedial strategy is focused on passive measures that include a temporary <br />pipeline to convey Ralston Creek past the mine. This will eliminate potential impacts to <br />water quality in the stream while long -term mitigation measures, including in -situ <br />treatment of the mine pool and removal of mine waste rock from the alluvium and fill, <br />are implemented. In the unlikely event that mine dewatering and treatment of mine water <br />were to become necessary in the future, any change in the use and storage of chemicals at <br />the site will be reported at that time. <br />