2012-10-05_REVISION - M1977342 (12)

Home Browse Search

TR -18 to Permit M- 1977 -342 Environmental Protection Plan 6. DESIGNATED CHEMICALS AND MATERIALS HANDLING Henderson has developed a Spill Prevention Control & Countermeasures / Materials Containment Plan (SPCC /MCP) and Incident Response Manual (IRM) to prevent unauthorized release of pollutants to the environment and meet the requirements of: • Part I.D.1 of the Colorado Department of Public Health & Environment, Water Quality Control Division, Discharge Permit issued to the Mill (CO- 0041467) (MCP Requirements); and • Federal oil pollution prevention regulations (40 CFR part 112) and the Colorado storage tank regulations (7 CCR 1101 -14) (SPCC Plan Requirements). The SPCC /MCP and IRM (Appendix A) describe procedures performed to manage, prevent, control, and mitigate releases of oil, petroleum products and other hazardous chemicals including: • Materials Handling & Containment; • Loading and Unloading; • Incident Response; • Government Agency Notifications (Verbal and Written); • Facility Monitoring (Inspections); • Employee Training; and • Recordkeeping. The SPCC /MCP and IRM also describe the petroleum and hazardous chemicals stored at the Henderson Mine and Mill. These documents identify the containment systems in place to help manage, prevent, control, and mitigate releases of petroleum products and other hazardous chemicals to the environment, including: • Containers or bulk storage used; • Secondary and /or tertiary containment features; and • Engineering controls. The SPCC /MCP has been certified by a licensed professional engineer and is reviewed annually by internal Henderson personnel and updated as necessary. As stated in Section 1.1.3, the SPCC /MCP and IRM (Appendix A) fulfills the requirement in Rule 8.3 for an Emergency Response Plan for designated chemicals used in processing at the Mill site. 6.1. Disposal, Decommissioning, Detoxification or Stabilization 6.1.1. Designated Chemicals 6.1.1.1. Temporary Cessation Mine: No designated chemicals used in processing. Mill: Under the scenario of Temporary Cessation, those designated chemicals at the Mill site would be used, removed from, or stored at the site. Mixed chemicals such as Nokes Reagent (sodium hydroxide and P2S would be used in the milling process until depletion of the supplies. The manufacturer would be contacted to assume possession of any unmixed and uncontaminated Climax Molybdenum Company Henderson Operations October, 2012 Page 12 of 40