Bear Lodge Plan of Operations - page 77

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remove materials from that type of container, e.g., pouring, pumping, and aspirating; and less
than one-inch of material remains in the container. The order of preference for handling empty
containers is: 1) return to the vendor and reuse, 2) recycle as scrap metal, or 3) send to the off-
site Type I or II sanitary landfill as trash. OTR vendor trucks delivering the fuels and lubricants
will be equipped with hazard signs and labels appropriate for highway transportation.
5.8.3.3 Vehicle Fluids
Hydraulic oil, brake fluid, and antifreeze are needed for vehicle maintenance. These will be
shipped via truck to the Mine Area using vendor delivery or through other shipping
arrangements depending on the quantity and supplier.
Container sizes will vary but the largest is expected to be 55-gallons. The materials will be
stored in the mine shop along with the lubricants; or in cases where the container volumes are
small, storage will be in the warehouse. The warehouse will be equipped with spill response
equipment and materials. The fuel truck may carry limited amounts of these fluids for field
maintenance purposes.
These vehicle fluids may be drained from vehicles on occasion. The drained fluids will be
collected in containers, transferred as needed for on-site accumulation and storage, and the first
choice for disposal is to return them to the vendor for recycling or disposal if possible. If
recycling or returning to the vendor are not viable options, the small amounts of liquids will be
evaluated for hazardous waste characteristics, and if deemed hazardous, sent to a hazardous
waste disposal facility. Empty containers will be recycled as scrap or disposed of in an off-site
Type I or II sanitary landfill.
5.8.3.4 Air Conditioning Gases
These gases may be needed occasionally to recharge vehicle air conditioning systems. They
will be purchased as needed, in approximately 20-pound compressed gas containers which will
be returned to the vendor upon depletion. The containers will be labeled appropriately to
prevent inadvertent misuse. Only mechanics qualified to handle these refrigerants will be
allowed to use these gases. Storage will be in the warehouse or mine shop.
5.8.3.5 Solvents
Solvents will be used for degreasing parts in the parts washer in the shop and also for
degreasing equipment in the shop, or PUG Plant. The parts washer contains approximately 5
gallons of solvent that will be delivered by the vender. The spent solvents will be removed for
recycling by the vendor. Solvents used in the PUG Plant and field will be shipped to the Mine
Area in various-sized containers, usually in less than 55-gallon containers. Some of these
materials may be purchased in spray cans, but most are expected to be in liquid form that can
be applied with refillable hand-sprayers. When empty (spray cans will be emptied and
punctured), the original containers will be recycled if possible, or disposed of in the trash that
goes to the Type I or II sanitary landfill. Currently the volume of solvents expected to be on-site
is less than 100 gallons.
Efforts will be made to procure non-hazardous solvent (e.g., citrus-based) so that use of the
solvent will not result in the spent solvent being classified as Resource Conservation and
Recovery Act (RCRA) hazardous waste. If necessary, based on the virgin product selected,
spent solvent from the parts washer will be tested for hazardous waste characteristics. Although
these spent parts washer solvents will be recycled, if they are determined to be hazardous
waste, they will be tracked by the mine as generated waste volumes.
If possible, based on vendor availability and product efficacy, solvent used for degreasing in the
plant or field will also be selected that is non-hazardous. Rags used to apply the solvents and
other contaminated debris generated by the degreasing work will be evaluated for potential
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