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C~ • TRAPPER MINING INC. SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN To meet the requirements of Federal Regulation, Title 40, Protection of the Environment, Chapter 1 (Environmental Protection Agency), Subchapter D (Water Program); Part 112 (Oil Pollution Prevention), Trapper Mining Inc. prepared a Spill Prevention Control and Countermeasure Plan in 1981. That SPCC plan has been modified in 1987,1990, and again in 1993, to reflect the changes in the facilities at Trapper covered by these regulations. The following paragraph headings refer to the guidelines set forth in Section 1127 of the above- mentioned regulations. 1127 (a) This facility experienced no spill events within the 12 months prior to the effective date of this part (January 10,1974). (b) The following table is an estimate of the predicted directions, rates of flow, and total quantity of oils which could be spilled from this facility as a result of a surface tank failure, based on a one-hour time interval to drain the tank (see attached maps for site locations): SITE# DIRECTION OF F•Y,oW RATE OF FY.oW TOTAL 1 Southwest 333 gpm 20,000 gal 2 Southwest 1,667 gpm 100,1x10 gal 3 South 250 gpm 15,000 gat 4 South 4.2 gpm 250 gal 5 Southwest 8.3 gpm 500 gal 6 Northeast 300 gpm 18,035 gal 7 Northeast 167 gpm 10,000 gal (c) All tank sites except #4 and #5, which are sufficiently small and of sufficient distance from the others to be exempt from this plan, are surrounded with compacted earthen dikes designed to contain the entire volume of the largest single tank with additional volume added to allow for storm water. The banks of the dikes are sloped to minimize erosion. Site #11 is a waste accumulation site. Small quantities of waste are stored in 55-gallon drums and include waste gear oil, waste grease, waste solvents, etc., and a 15,000-gallon waste antifreeze tank. All containers are appropriately marked. This site is a 70'x70'x8" concrete pad enclosed by a 12"x8" concrete stem wall. A six- foot-high chain-link fence surrounds the storage area controlling access to the area. (e)(1)(i) Normal storm water or snowmelt accumulation within the earthen dikes normally either evaporates or percolates. Should excessive water accumulate or should a tank fail, portable pumps stored on the property would be used to drain the area. Records of all drainages will be kept at least three years. The record form for all drainages from diked areas is shown as Attachment A. (e)(2)(i) The construction of and material used in all storage tanks at the facility are compatible with the material stored in them.