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Irerracon <br />June 25, 2009 <br />Ms. Tracey Trybom <br />Connell Resources <br />7785 Highland Meadows Parkway, Ste 100 <br />Fort Collins, CO 80528 <br />Re: SPCC Plan <br />Connell Resources, Timnath Pit <br />5150 SE Frontage Road <br />Fort Collins, Colorado <br />Terracon Project No. 20077005 <br />Dear Ms. Trybom: <br />Terracon Consultants, Inc. (Terracon) has prepared the Spill Prevention Control and <br />Countermeasures (SPCC) Plan for the Connell Resources (Connell) Timnath Pit Facility. <br />The United States Environmental Protection Agency's (EPA) SPCC regulation (40 CFR <br />112) requires certain facilities to prepare and implement an SPCC Plan. The SPCC <br />regulation has a number of other requirements (i.e., besides the preparation of an SPCC <br />Plan). The following is a summary of the general SPCC Plan requirements: <br />• Review the SPCC Plan every five years to make sure that the SPCC Plan is up- <br />to-date and the facility's SPCC provisions are in place. <br />• Update the SPCC Plan to reflect the changes to the facility within six months of <br />making the changes. <br />• Maintain a copy of the SPCC Plan on-site and to provide it to the EPA or State <br />Department of Environmental Quality personnel upon request. <br />• Periodically train relevant personnel on the applicable requirements of the SPCC <br />Plan. <br />• Train new personnel on the applicable requirements of the SPCC Plan. <br />• Periodically inspect oil storage areas, equipment, containers, pipes and transfer <br />areas, and clean up oil leaks, drips and spills. <br />More detailed information on these requirements is addressed in the SPCC Plan. <br />As a general rule, integrity testing should be performed every ten years unless <br />manufacturer's recommendations or previous integrity testing data indicate otherwise. <br />Therefore, if the tanks are over ten years old and have not been integrity tested, <br />Terracon recommends that Connell test the integrity of the tanks. If the tanks are over <br />ten years old and have been tested to determine their integrity, Terracon recommends <br />that Connell develop a schedule for future integrity testing of the tanks based on the test <br />Terracon Consultants, Inc. 301 North Howes Fort Collins, Colorado 80521 <br />P [970] 484 0359 F [970] 484 0454 terracon.com