What changed in this filing

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Item 1B. Unresolved Staff Comments

2022-03-31 compared with 2021-03-31 · 142 added, 254 removed, 25 unchanged (94% of the section changed)

Item 1B Unresolved Staff Comments

Not Applicable

Item 2 Description of Properties

ANTIMONY DIVISION

antimony smelter and precious metals plant is located in the Burns

Mining District, Sanders County, Montana, approximately 14 miles

west of Thompson Falls on Montana Highway 471.

This highway is

asphalt, and the property is accessed by cars and trucks.

property includes two five-acre patented mill sites that are owned

in fee-simple by us.

Our antimony smelter and precious metals plant is located in the Burns Mining District, Sanders County, Montana, approximately 14 miles west of Thompson Falls on Montana Highway 471.

This highway is asphalt, and the property is accessed by cars and trucks.

The property includes two five-acre patented mill sites that are owned in fee-simple by us.

The claims are U.

2 unchanged sentences

Antimony Mill Site No.

Survey 10953).

We also own five acre Black Jack

Antimony Mill Sites were used to run a flotation mill and

processing plant for antimony that we mined on adjacent claims that

have been sold.

Presently, we run a smelter that includes furnaces

of a proprietary design to produce antimony metal, antimony oxide,

and various other products.

2 (Mineral Survey 10953).

We also own five-acre Black Jack millsite.

Antimony Mill Sites were used to run a flotation mill and processing plant for antimony that we mined on adjacent claims that have been sold.

Presently, we run a smelter that includes furnaces of a proprietary design to produce antimony metal, antimony oxide, and various other products.

We also run a precious metals plant.

The facility includes 6 buildings and our main office.

plans to resume mining on the claims that have been sold or

abandoned, although the mineral rights have been retained on many

of the patented mining claims.

Forest Service and Montana

Department of Environmental Quality have told us that the

resumption of mining would require an Environmental Impact

Statement, massive cash bonding, and would be followed by years of

The mill site is serviced with three-phase electricity

from Northwest Power, and water is pumped from a well.

claim no reserves on any of these properties.

mining and milling operations in the U.S.

were curtailed during

1983 due to continued declines in the price of antimony.

currently purchasing foreign raw antimony materials and producing

our own raw materials from our properties in Mexico.

We continue to

produce antimony metal, oxide, sodium antimonite, and precious

metals from our processing facility near Thompson Falls,

There are no plans to resume mining on the claims that have been sold or abandoned, although the mineral rights have been retained on many of the patented mining claims.

Forest Service and Montana Department of Environmental Quality have told us that the resumption of mining would require an Environmental Impact Statement, massive cash bonding, and would be followed by years of lawsuits.

The mill site is serviced with three-phase electricity from Northwest Power, and water is pumped from a well.

We claim no reserves nor mineral resources on any of these properties.

Antimony mining and milling operations in the U.S.

were curtailed during 1983 due to continued declines in the price of antimony.

We are currently purchasing foreign raw antimony materials and producing our own raw materials from our properties in Mexico.

We continue to produce antimony metal, oxide, sodium antimonite, antimony trisulfide, and precious metals from our processing facility near Thompson Falls, Montana.

ANTIMONY MINERAL PROPERTIES

Los Juarez Group

properties that are collectively called the “Los

Juarez”

property, in Queretaro, as follows:

mineral rights for the concessions San Miguel I and II were

purchased by a USAC subsidiary, Antimonio de Mexico, S.

(AM), for $1,480,500, which was paid in full as of December 31,

As of December 31, 2020, we have paid for the property and

have incurred significant permitting costs.

The property consists

of 40 hectares (100 acres)

San Juan I and II

are concessions owned by AM and include 466 hectares (1,152

San Juan III is

held by a lease agreement by AM in which we will pay a 10% royalty,

based on the net smelter returns from another USAC Mexican

subsidiary, named United States Antimony Mexico, S.

We hold properties that are collectively called the “Los Juarez” property, in Queretaro, as follows:

San Miguel I and II were purchased by a USAC subsidiary, Antimonio de Mexico, S.

V (ADM), for $1,480,500, which was paid in full as of December 31, 2018.

As of December 31, 2020, we have paid for the property and have incurred significant permitting costs.

The property consists of 40 hectares (100 acres)

San Juan I and II are concessions owned by ADM and include 466 hectares (1,152 acres)

San Juan III is held by a lease agreement by ADM in which we will pay a 10% royalty, based on the net smelter returns from another USAC Mexican subsidiary, named United States Antimony Mexico, S.

It consists of 214 hectares (529 acres).

concessions collectively constitute 720 hectares (1,780 acres).

claims are accessed by roads that lead to highways.

the USAC Mexican property, including San Miguel I, II and part of

San Juan III, was originally drilled by the Penoles Company in

1970, when antimony metal prices were high.

They did not proceed

with the property, due to the complex metallurgy of antimony.

Subsequently, the Mexican Government did additional work and

reported a deposit of mineralized material of 1,000,000 metric tons

(mt) grading 1.8% antimony and 8.1 ounces of silver per metric ton

(opmt) in Consejo de Recursos  Minerales (Publicacion

Such a report does not qualify as a comprehensive

evaluation, such as a final or bankable feasibility study that

concludes legal and technical viability, and economic feasibility.

The Securities and Exchange Commission does not recognize this

report, and we claim no reserves.

mineralized zone is a classic jasperoid-type deposit in the

Cretaceous El Doctor Limestone.

The mineralization is confined to

silicified jasperoid pipes intruded upwards into limestone.

zone strikes north 70 degrees west.

The dimension of the deposit is

still conjectural.

However, the strike length of the jasperoid is

more than 3,500 meters. 

mineralization is typically very fine-grained stibnite with silver

and gold.  It is primarily sulfide in nature due to its

encapsulation in silica.

The mining for many years will be by open

The concessions collectively constitute 720 hectares (1,780 acres).

The claims are accessed by roads that lead to highways.

Part of the USAC Mexican property, including San Miguel I, II and part of San Juan III, was originally drilled by the Penoles Company in 1970, when antimony metal prices were high.

They did not proceed with the property, due to the complex metallurgy of antimony.

Subsequently, the Mexican Government did additional work and reported a deposit of mineralized material of 1,000,000 metric tons (mt) grading 1.8% antimony and 8.1 ounces of silver per metric ton (opmt) in Consejo de Recursos Minerales (Publicacion M-4e).

Such a report does not qualify as a comprehensive evaluation, such as a final or bankable feasibility study that concludes legal and technical viability, and economic feasibility.

The Securities and Exchange Commission does not recognize this report, and we claim no reserves.

The mineralized zone is a classic jasperoid-type deposit in the Cretaceous El Doctor Limestone.

The mineralization is confined to silicified jasperoid pipes intruded upwards into limestone.

The zone strikes north 70 degrees west.

The dimension of the deposit is still conjectural.

However, the strike length of the jasperoid is more than 3,500 meters.

The mineralization is typically very fine-grained stibnite with silver and gold.

It is primarily sulfide in nature due to its encapsulation in silica.

The mining for many years will be by open pit methods.

Eventually it will be by underground methods.

present time, mining has included hauling dump rock and rock from

USAMSA Puerto Blanco Flotation Mill, Guanajuato,

flotation plant has a capacity of 100 metric tons per day.

includes a 30”

jaw crusher, a 4’x 8’

double-deck screen, a 36”

cone crusher, an 8’x

Harding type ball mill, and eight No.

24 Denver sub A

type flotation machines, an 8’

disc filter, front end

loaders, tools and other equipment.

The flotation circuit is used

for the processing of rock from Los Juarez and other properties.

oxide circuit was added to the plant in 2013 and 2014 to mill oxide

ores from Los Juarez and other properties.

It includes a vertical

shaft impactor, 3 ore bins, 8 conveyors, a 4’

frequency screen, jig, 8 standard concentrating tables, 5 pumps,

sand screw and two buildings.

The capacity of the oxide circuit is

50 tons per day.

We have installed a cyanide leach circuit and

settling pond that will be used to recover precious metals from our

Los Juarez mine.

USAMSA Madero Smelter, Estacion Madero, Parras De La Fuente,

Coahuila, Mexico

through its wholly owned subsidiary, USAMSA, owns and operates a

smelting facility at Estacion Madero, in the Municipio of Parras de

la Fuente, Coahuila, Mexico.

The property includes 13.48 hectares

Seventeen small rotating furnaces (SRF’s) and

four large rotating furnaces (LRF) with an associated stack and

Other equipment includes cooling ducting, dust

collectors, scrubber, laboratory, warehouse, slag vault, stack, jaw

crusher, screen, hammer mill, and a 3.5’

The plant has a feed capacity of twenty to thirty metric tons of

direct shipping ore or concentrates per day, depending on the

quality of the feedstock.

If the feedstock is in the range of 45%

antimony, the smelter could produce as much as 10MM pounds of

contained antimony annually.

Concentrates from our flotation plant,

and hand-sorted ore from Mexico sources and other areas, are being

In 2019, we completed the installation of a leach

circuit to process concentrates from the Puerto Blanco cyanide

leach plant containing precious metals from our Los Juarez Mining

The Madero production is either sold as metal or finished

oxide directly to customers or shipped to our Montana plant to

produce finished Antimony products and precious metals.

the plant is by road and railroad.

Set forth below are location

At the present time, mining has included hauling dump rock and rock from mine faces.

In October 2020, a 1000 meter initial drill program was conducted on the property with a total of 25 holes.

The drilling was completed November 2020 and used a reverse-circulation drill rig.

Samples were sent to a certified lab in Mexico for analysis.

Drill hole location, depth, and angle were selected near mined pit areas and along suspected fault zones.

A summary of the drill program was published in a news release of November 30, 2020 and subsequent news releases.

This initial program was performed without the aid of a geophysical study.

In 2022, the Company is engaged in a formal geological, geochemical, and geophysical study to help obtain subsurface mineralization data and better understand the system with an objective of partnering with a junior mining company with expertise in exploration/drilling.

USAMSA Puerto Blanco Flotation Mill, Guanajuato, Mexico

The flotation plant has a capacity of 100 metric tons per day.

It includes a 30” x 42” jaw crusher, a 4’x 8’ double-deck screen, a 36” cone crusher, an 8’x 36” Harding type ball mill, and eight No.

24 Denver sub A type flotation machines, an 8’ disc filter, front end loaders, tools and other equipment.

The flotation circuit is used for the processing of rock from Los Juarez and other properties.

The crushing equipment currently in place is adequate for both flotation mills.

An oxide circuit was added to the plant in 2013 and 2014 to mill oxide ores from Los Juarez and other properties.

It includes a vertical shaft impactor, 3 ore bins, 8 conveyors, a 4’ x 6’ high frequency screen, jig, 8 standard concentrating tables, 5 pumps, sand screw and two buildings.

The capacity of the oxide circuit is 50 tons per day.

We have installed a cyanide leach circuit and settling pond that will be used to recover precious metals from our Los Juarez mine.

In 2019 a cyanide leach circuit for recovery of gold was built and permits were obtained for this circuit.

Test batches of Los Juarez antimony concentrates containing precious metals have been processed through the cyanide leach system and the processing of 2,000 tons of mined rock from Los Juarez is underway.

One of three batches of gold-bearing carbon (the end product of the cyanide leach) have been saturated and awaits separation and analysis.

Preliminary results are that the gold-recovery is acceptable.

USAMSA Madero Smelter, Estacion Madero, Parras De La Fuente, Coahuila, Mexico

USAC, through its wholly owned subsidiary, USAMSA, owns and operates a smelting facility at Estacion Madero, in the Municipio of Parras de la Fuente, Coahuila, Mexico.

The property includes 13.48 hectares (30 acres).

Seventeen small rotating furnaces (SRF’s) and four large rotating furnaces (LRF) with an associated stack and scrubbers.

Other equipment includes cooling ducting, dust collectors, scrubber, laboratory, warehouse, slag vault, stack, jaw crusher, screen, hammer mill, and a 3.5’ x 8’ rod mill.

The plant has a feed capacity of 14-25 metric tons of direct shipping ore per day, depending on the grade of the feedstock.

If the feedstock is in the range of 45% antimony or higher, the smelter could produce as much as 10MM pounds of contained antimony annually.

Concentrates from our flotation plant, and hand-sorted ore from Mexico sources and other areas, are being processed.

In 2019, we completed the installation of a caustic leach circuit to process concentrates from the Puerto Blanco cyanide leach plant containing precious metals from our Los Juarez Mining property.

The Madero production is either sold as metal to customers directly or crude oxide shipped to our Montana plant to produce finished antimony products and precious metals.

Plans to dramatically improve and update the infrastructure at the Madero Smelter include erecting a building around all the furnaces to aid in the control, consistency, and quality of product and ease of processing.

Additionally, the Company is considering producing finished antimony oxide with this control and purchasing quality-control instrumentation for the option of selling all finished antimony products from Madero just as we currently do in Montana.

We intend to use part of our 2021 capital raise for the buildings, improving equipment, relining furnaces, purchase of newer forklifts, scales, and general improvement.

Access to the plant is by road and railroad.

Set forth below are location maps:

ZEOLITE DIVISION

property is located in the southeast corner of Idaho, approximately

seven miles east of Preston, Idaho, 34 miles north of Logan, Utah,

79 miles south of Pocatello, Idaho, and 100 miles north of

Salt Lake City, Utah.

mine is located in the N ½

of section 10 and the W ½

section 2, section 3, and the E ½

section 4, Township 15,

Range 40 East of the Boise Meridian, Franklin County, Idaho.

plant and the initial pit are located on the Webster Farm, L.L.C.,

which is private land.

This property is located in the southeast corner of Idaho, approximately seven miles east of Preston, Idaho, 34 miles north of Logan, Utah, 79 miles south of Pocatello, Idaho, and 100 miles north of Salt Lake City, Utah.

The mine is located in the N ½ of section 10 and the W ½ of section 2, section 3, and the E ½ section 4, Township 15, Range 40 East of the Boise Meridian, Franklin County, Idaho.

The plant and the initial pit are located on the Webster Farm, L.L.C., which is private land.

Transportation

property is accessed by seven miles of paved road and about l mile

of gravel road from Preston, Idaho.

Preston is near the major

north-south Interstate Highway 15 to Salt Lake City or

Union Pacific rail sidings may be available to the mine.

approximately 25 miles west of the mine and includes acreage out of

town where bulk rock could be stored, possibly in existing silos or

on the ground.

Three-phase power is installed at this abandoned

site.  Finished goods can also be shipped from the

Franklin County Grain Growers feed mill in the town of Preston on

the Union Pacific Railroad.

Burlington Northern Railroad can be accessed at Logan,

 Location

The property is accessed by seven miles of paved road and about l mile of gravel road from Preston, Idaho.

Preston is near the major north-south Interstate Highway 15 to Salt Lake City or Pocatello.

Several Union Pacific rail sidings may be available to the mine.

Bonida is approximately 25 miles west of the mine and includes acreage out of town where bulk rock could be stored, possibly in existing silos or on the ground.

Three-phase power is installed at this abandoned site.

Finished goods can also be shipped from the Franklin County Grain Growers feed mill in the town of Preston on the Union Pacific Railroad.

The Burlington Northern Railroad can be accessed at Logan, Utah.

Property and Ownership

leases 320 acres from the Webster Farm, L.L.C.

The term of the

lease is 15 years and it began on March 1, 2010.

This includes the

mill site and zeolite in the area of the open pit.

The property is

the NW ¼

of the SW ¼

of section 3 and the N

of the W ¼

of section 10, Township 15 South, Range 40

East of the Boise Meridian, Franklin County, Idaho.

requires a payment of $10.00 per ton plus an additional annual

payment of $10,000 on March 1st of each year.

In addition, there

are two other royalty holders.

Nick Raymond and the estate of

George Desborough each have a graduated royalty of $1.00 per ton to

$5.00 per ton, depending on the sale price.

balance of the property is on Bureau of Land Management property

and includes 480 acres held by 24, 20-acre Placer claims.

drop our lease with Webster Farms LLC., we will retain these placer

deposit is a very thick, sedimentary deposit of zeolitized volcanic

ash of Tertiary age known as the Salt Lake Formation.

sedimentary interval in which the clinoptilolite occurs is more

than 1000 feet thick in the area.

Thick intervals of the zeolite

are separated by thin limestone and sandstone beds deposited in the

freshwater lake where the volcanic ash accumulated.

deposit includes an 800- foot mountain.

Zeolite can be sampled over

a vertical extent of 800 feet on more than 700 acres.

pit covers more than 3 acres.  Despite the

apparent size of the deposit, we claim no

BRZ leases 320 acres from the Webster Farm, L.L.C.

The term of the lease is 15 years and it began on March 1, 2010.

This includes the mill site and zeolite in the area of the open pit.

The property is the NW ¼ and W ½ of the SW ¼ of section 3 and the N ½ of the W ¼ of section 10, Township 15 South, Range 40 East of the Boise Meridian, Franklin County, Idaho.

The lease requires a payment of $10.00 per ton plus an additional annual payment of $10,000 on March 1st of each year.

In addition, there are two other royalty holders.

Nick Raymond and the estate of George Desborough each have a graduated royalty of $1.00 per ton to $5.00 per ton, depending on the sale price.

In early 2021, Joe Bardswhich, a director and geologist, was able to renegotiate one of the royalty payments so that escalation due to the CPI that existed in the original contract was removed.

The balance of the property is on Bureau of Land Management property and includes 480 acres held by 24, 20-acre Placer claims.

Should we drop our lease with Webster Farms LLC., we will retain these placer claims.

The deposit is a very thick, sedimentary deposit of zeolitized volcanic ash of Tertiary age known as the Salt Lake Formation.

The sedimentary interval in which the clinoptilolite occurs is more than 1000 feet thick in the area.

Thick intervals of the zeolite are separated by thin limestone and sandstone beds deposited in the freshwater lake where the volcanic ash accumulated.

The deposit includes an 800- foot mountain.

Zeolite can be sampled over a vertical extent of 800 feet on more than 700 acres.

The current pit covers more than 3 acres.

Despite the apparent size of the deposit, we claim no reserves.

Exploration, Development, and Mining

has been limited to the examination and sampling of surface

outcrops and mine faces.

Exploration has been limited to the examination and sampling of surface outcrops and mine faces.

Mining Methods

on the location, the zeolite is overlain by 1 to 12 feet of

zeolite-rich soil.

On the ridges, the cover is very little, and in

the draws the soil is thicker.

The overburden is stripped using a

tractor dozer, currently a Caterpillar D-8K.

It is moved to the toe

of the pit, and will eventually be dozed back over the pit for

near-surface rock is easily ripped, it is more economical to drill

and blast it.

Depending on the location, the zeolite is overlain by 1 to 12 feet of zeolite-rich soil.

On the ridges, the cover is very little, and in the draws the soil is thicker.

The overburden is stripped using a tractor dozer, currently a Caterpillar D-8K.

It is moved to the toe of the pit, and will eventually be dozed back over the pit for reclamation.

Although near-surface rock is easily ripped, it is more economical to drill and blast it.

Breakage is generally good.

Initial benches are 20

feet high, and each bench is accessed by a road.

is over approximately 4,000 feet of road on an uphill grade of 2.5%

On higher benches, the grade will eventually be

Initial benches are 20 feet high, and each bench is accessed by a road.

Haulage is over approximately 4,000 feet of road on an uphill grade of 2.5% to the mill.

On higher benches, the grade will eventually be downhill.

Caterpillar 769 B rock trucks are being used.

18 to 20 tons per load, and the cycle time is about 30

the trucks and the other existing equipment, the mine is capable of

producing 80 tons per hour. 

They haul 18 to 20 tons per load, and the cycle time is about 30 minutes.

In 2021, we experimented with the idea of mining principally by ripping using the Caterpillar D-9.

This method worked but rendered rock that sometimes had to be drilled and broken in order to fit in the jaw crusher bin at the mill.

Consequently, the Company is certain that blasting is the preferred method of mining.

We may elect to supplement mining production by updating our D-9 with a secondary ripper.

With the trucks and the other existing equipment, the mine is capable of producing 80 tons per hour.

Primary Crusher

primary crushing circuit is a conventional closed circuit,

utilizing a Stephens-Adamson 42”

apron feeder,

Pioneer 30”

jaw crusher, Nordberg standard

cone crusher, a 5’

by 12’  double

deck Kohlberg screen, and has a self-cleaning dust collector.

rock is crushed to minus 1 inch and the circuit has a rated

capacity of more than 50 tons per hour.

are two dryer circuits, one for lines one and two, and one for the

Raymond mill.

The dryer circuits include one 50 ton feed bin, and

each dryer has a conveyor bypass around each dryer, a bucket

elevator, and a dry rock bin.

The dryers are 25 feet long, 5 feet

in diameter and are fired with propane burners rated at 750,000

The primary crushing circuit is a conventional closed circuit, utilizing a Stephens-Adamson 42” x 12’ apron feeder, Pioneer 30” x 42” jaw crusher, Nordberg standard 3’ cone crusher, a 5’ by 12’ double deck Kohlberg screen, and has a self-cleaning dust collector.

The rock is crushed to minus 1 inch and the circuit has a rated capacity of more than 50 tons per hour.

There are two dryer circuits, one for lines one and two, and one for the Raymond mill.

The dryer circuits include one 50 ton feed bin, and each dryer has a conveyor bypass around each dryer, a bucket elevator, and a dry rock bin.

The dryers are 25 feet long, 5 feet in diameter and are fired with propane burners rated at 750,000 BTUs.

One self-cleaning bag house services both dryers.

on the wetness of the feed rock, the capacity is in the range of 10

tons per hour per dryer.

During most of the year, the dryers are

Depending on the wetness of the feed rock, the capacity is in the range of 10 tons per hour per dryer.

During most of the year, the dryers are not run.

Coarse Products Circuit

are two lines to produce coarse products:

 Line 1 is a

closed circuit with a 100 HP vertical shaft impactor and a 5 deck

Midwestern Multi Vibe high frequency screen.

Line 2 includes a

Jeffries 30”

by 24”

60 HP hammer mill in a closed

circuit with two 5’

triple deck Midwestern Multi

Vibe high frequency screens.

The circuits also include bucket

elevators, (3) 125 ton capacity product silos, a 6 ton capacity

Crust Buster blender, augers, Sweco screens, and dust

In Oct/Nov 2021 the primary jaw crusher pitman arm broke due to incorrect greasing procedures.

A replacement jaw crusher was purchased, delivered, installed and began operations 1.5 months after delivery.

A delivery chute was designed and fabricated along with necessary bins and skirting.

The new jaw crusher was outfitted with a hydraulic hand-pump greaser for the main pitman-arm assembly and the correct grease and greasing procedure has been implemented.

Plans to fix or replace the old jaw crusher exist but require a major refit.

The Company was able to repair the engine on its crane, a Linkbelt 3-stage boom crane of about 50 ton nameplate capacity.

The transmission is now being repaired.

With this crane, the Company will pull the old jaw crusher and determine if it is salvageable.

In any case, the Company has earmarked that location for an entirely new and secondary jaw crusher in the event that bulk zeolite purchase opportunities increase.

There are two lines to produce coarse products:

Line 1 is a closed circuit with a 100 HP hammer mill (that replaced the old vertical shaft impactor) and a 5 deck Midwestern Multi Vibe high frequency screen.

The replacement of the VSI with the hammermill, also outfitted with a variable frequency drive has increased production over the VSI by about 50% so far and we are continuing to test feeds and speeds to enhance this production rate.

Line 2 includes a Jeffries 30” by 24” 60 HP hammer mill in a closed circuit with two 5’ x 12’ triple deck Midwestern Multi Vibe high frequency screens.

The circuits also include bucket elevators, (3) 125-ton capacity product silos, a 6 ton capacity Crust Buster blender, augers, Sweco screens, and dust collectors.

Fine Products Circuit

fine products circuit is in one building and it includes (2)

x 10.5’

Derrick 2 deck high frequency (3450 RPM)

screens and various bucket elevators, augers, bins, and Sweco

screens for handling product.

Depending on the screening sizes, the

plants can generate approximately 150 tons of granules and 125 tons

of fines per 24-hour day.

The fine products circuit is in one building and it includes (2) 3.5’ x 10.5’ Derrick 2 deck high frequency (3450 RPM) screens and various bucket elevators, augers, bins, and Sweco screens for handling product.

Depending on the screening sizes, the plants can generate approximately 150 tons of granules and 125 tons of fines per 24-hour day.

Raymond Mill Circuit

Raymond mill circuit includes a 6058 high-side Raymond mill with a

double whizzer, dust collector, two 100 ton product silos, feed

bin, conveyors, air slide, bucket elevators, and control booth.

Raymond mill has a rated capacity of more than 10 tons per

The Raymond mill circuit includes a 6058 high-side Raymond mill with a double whizzer, dust collector, two 100 ton product silos, feed bin, conveyors, air slide, bucket elevators, and control booth.

The Raymond mill has a rated capacity of more than 10 tons per hour.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments