2012-03-07_REVISION - M1983194 - Laserfiche WebLink

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will be disposed of in an appropriate and approved method and in accordance with all applicable rules and regulations. NSI has procedures in place to reduce or eliminate the possibility of spills. These procedures include locked -out / tagged -out valves, multiple daily inspections (well checks by operators), continuous monitoring (pressure, temperature, flow rates and water levels), with alarms, of operations and processes, periodic maintenance, periodic pressure testing, and procedural review. (7) Facilities Evaluation NSI's operation is regulated by multiple agencies. NSI has operated in compliance for over 20 years and is dedicated to maintaining compliance in the future. Because of NSI's continuing efforts to reduce emissions and use of best management practices (BMP), in 2011 the CDPHE changed NSI's emission classification from Synthetic Minor Emitter to Minor Emitter. This classification change was a direct result of NSI's ongoing commitment to reduce emissions and protect the environment at every phase of their operation. NSI's processing plant and related structures are engineered structures. All processing equipment meets or exceeds all applicable engineering standards. One of NSI's business strategies is to process 100% of the mined sodium bicarbonate resource into finished product. The process plant was designed with this strategy in mind. Any potential spills within or around this zero waste process plant would typically involve aqueous process fluid, generally containing higher concentrations of sodium bicarbonate (baking soda) or product at or near a finished state (baking soda). Any potential spills within the process building will drain to a containment sump where the material would typically be pumped to the barren liquor tank for reinjection to the operating wells. If this containment sump should fill, a 6 -inch overflow pipe that gravity drains to the 3 acre process pond will handle any excess. This 3 acre process pond recycles material into the process stream. A tank farm is located near and southeast of the processing building. The tank farm contains 5 tanks which hold either auxiliary water or process brines. These tanks have a total maximum capacity of 300,000 gallons, and are located in a 50,000 gallon concrete containment structure. This concrete containment structure gravity drains through a 6 -inch drain to the 3 acre process pond. Two cooling tower pumps are also within a concrete containment structure of 1,570 gallons. The cooling towers have a capacity of 1,850 gallons of water. This concrete containment drains to the 7 acre evaporation pond. NSI's product storage consists of a warehouse, silos and a storage dome. The warehouse is 7,334 square feet and is attached to the process building. The finished product (baking soda) is temporarily stored in the warehouse in 50 pound, paper sacks and 2,000 pound super- sacks. Paper sacked product is palletized and shrink wrapped. Product is loaded into 18 -wheel tractor /trailer units for shipment to end users. It should be noted that MSDS indicate zero to minimal concerns regarding sodium bicarbonate (baking soda) with respect to transportation, human health or environmental concerns. The plant warehouse is enclosed. Any product buildup is swept and removed where applicable. Any spill at the plant warehouse would be converted into feed /industrial grade whenever possible or placed in the dumpster if not salvageable. NSI Process pond information may be found in the Natural Soda 2010 Mine Plan, Volume 4, Section 7.7.9. Mining Activity Monitoring Systems information may be found in the Natural Soda 2010 Mine Plan, Volume 4, Section 6.6.5. The ponds are visually inspected during shiftwise operator well checks, and as needed, to maintain the waterfowl deterrent devices. Daub & Associates, Inc. NSI 2012 EPP Page 7