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DMG feels that tarping of ores should be a necessary and prudent practice to be regularly implemented. If the <br />operator feels that this assessment has been made in error, please provide a rationale. <br />Item #2 -Hydrocarbon Storage <br />Mr. Barker's letter stated that all items (hydrocarbons and batteries) were moved offsite in November. Mr. <br />Abraham's letter commits Au Mining to remove the items or store them in impermeable secondary containment. <br />These statements constitute an adequate response. This problem is considered to be corrected. <br />Concerning the issue of storage and handling of fuel and hydrocarbons, the operator is referred to the EPP, which <br />states that there "will be no bulk fuel storage" and "diligence will be exercised to contain al] spills." Depending on <br />the total volume of fuels, hydrocarbons and other fluids stored at the site, the operator may have to request a <br />revision to the EPP. For a limited volume, filing a revision might not be required. However, this office requires all <br />operators, DMO and otherwise, to provide impermeable secondary containment for all hydrocarbons and other <br />liquid contaminants. The number of separate containers and vessels observed at this site, and their combined <br />volume, could be given adequate secondary containment in a steel stock tank, for example. The capacity of the <br />tank must be such that it holds al] spilled fluids plus 20 percent. The tank could be easily transported to and from <br />the site, and fairly easily covered from the weather (significant precipitation reduces the capacity of the tank). This <br />is an option for storing a limited volume of fluids, without undergoing a rigorous engineering design and <br />construction certification of an EPF (Environmental Protection Facility, see Rule 7.3.1). <br />I3esides leaks, this office is also concerned about ongoing ground and water contamination from fuel spills during <br />handling. There is a small amount ofhydrocarbon-contaminated material on the pad. It should be fully excavated <br />and spread in a thin layer on the pad surface. Natural weathering of this layer will gradually neutralize it. In the <br />future, if careful handling could be performed, sufficient to eliminate spills, this office will not require a lined <br />fueling location as part of the EPP. <br />Pdlr. Barker's letter also asked about the use of Biodiesel on the site, and whether it would be considered a <br />krydrocarbon. There are numerous products that are currently manufactured and marketed under the name <br />Biodiesel, though they vary somewhat between brands. The market name Biodiesel is usually given to a group of <br />specific mixtures consisting of plant-based oils and regular diesel fuel. In most all cases, the diesel fuel accounts <br />for 80 to 95 percent of the fuel. It often performs better than straight diesel (burns cleaner and quieter), and is close <br />to the same price. <br />There are some who state that a form of Biodiesel made from 100% plant-based oil may be used as a substitute for <br />diesel, though it often consists solely of used vegetable oil. It may be cheap but it is not recommended by diesel <br />mechanics due to its inherent instability (it breaks down into polymers, gels at low temperatures, fouls fuel filters <br />more quickly, and suffers from accelerated bacterial growth when stored for long periods) and does not perform as <br />well as regular diesel. It is not recommended for diesel vehicles or equipment, but that is the owner's choice. My <br />understanding of Mr. Bazker's question, is that for the commercially-available type(s) of Biodiesel (5 to 20% plant- <br />based oils in the formulation), it would still constitute a hydrocarbon and require the same care in storage and <br />handling as regular diesel fuel. I suggest looking on the web, at: www.QObluesun.com for further information. <br />Item #3 -Unstable Cutslope above Borrow Area <br />Mr. Barker's letter states that since it is inside the permit boundary, no work will be done to correct this condition. <br />Pvlr. Abraham's letter commits Au Mining to correct the problem through backfilling or other earthwork sufficient <br />to stabilize the feature against potential offsite damage from sloughing. He states that this work will be done by <br />X4/30/06. This office feels that some remedial work is necessary, but that ground conditions may not be suitable <br />until later in the season. This office will extend the date to complete the earthwork until 6/30/06. <br />"this feature is considered important since it has the potential for damage outside the permit boundary. It is noted as <br />a problem now, however, to call the operator's attention to stabilizing it while it is still inside the boundary. The <br />operator is reminded that this type of unstable feature is a problem (PB) while it is inside the boundary. If damage <br />