CuMo Exploration Project · CuMo Exploration Project SPCC. 24-hour contact information is provided in Table 1. CuMo Exploration Project Mining Exploration 2011 Boise National Forest

Forsgren Associates, Inc

CuMo Exploration

Spill Protection, Control, &

Countermeasure Plan

Prepared by:

415 S. 4th Street Boise, ID 83702(208) 342-3144 Page i of ii

CUMO ProjectExplorationSPCC Plan

Exploration Project


Countermeasure Plan

June 2011

Prepared for:

Mosquito Consolidated1616 West 3rd Avenue, Suite 100Vancouver, BC V6J 1K2

Date

CUMO ProjectExplorationSPCC Plan

Project


Mosquito Consolidated Gold Mines Ltd.Avenue, Suite 100

Vancouver, BC V6J 1K2

TABLE OF CONTENTS

1.0 INTRODUCTION ................................

1.1 MANAGEMENT APPROVAL1.2 PROFESSIONAL ENGINEERING APPROVAL1.3 PLAN REVIEW ................................1.4 LOCATION OF THE SPCC PLAN1.5 FACILITY RESPONSE PLAN REQUIREMENTS

2.0 GENERAL FACILITY INFORMATION

2.1 COMPANY INFORMATION2.2 CONTACT INFORMATION

3.0 SUBPART A – GENERAL REQUIREMENTS

3.1 THE FACILITY’S CONFORMANCE WITH THE REQU3.2 PHYSICAL LAYOUT OF THE FACILITY 40 CFR 13.3 DISCHARGE PREVENTION

3.3.1 EQUIPMENT ................................3.3.2 STORAGE ................................3.3.3 TRANSFER ACTIVITIES3.3.4 LEAK DETECTION ................................3.3.5 IMPACT PROTECTION3.3.6 EMERGENCY SHUT OFF

3.4 DISCHARGE OR DRAINAGE CONTROLS 40 CFR 113.5 COUNTERMEASURES FOR

(3) (IV) ................................3.5.1 DISCHARGE DISCOVERY3.5.2 NOTIFY AGENCIES VERB

3.6 METHODS OF DISPOSAL OF RECOVERED MATERIA3.7 CONTACT LIST AND PHONE NUMBERS 40 CFR 113.8 INFORMATION TO BE GIVEN TO CONTACTS 40 C3.9 PROCEDURES TO FOLLOW

3.9.1 SPILL RESPONSE MATER3.10 DIRECTION, RATE OF FLOW AND TOTAL QUANTI

(B)................................................................3.11 PREVENTION SYSTEMS: CONTAINMENT AND DIVE

UTILIZED TO PREVENT A DISCHARGE FROM REA3.12 INSPECTIONS, TESTS, AND RECORDS 40

3.12.1 DAILY EXAMINATIONS3.12.1 MONTHLY INSPECTIONS

3.13 PERSONNEL, TRAINING, FOR DISCHARGE PREVEN3.14 SECURITY 40 CFR 112.7 (G)3.15 TANK TRUCK LOADING UNLOADING AR3.16 FIELD CONSTRUCTED ASTS 40 CFR 112.7 (I)

CuMo Exploration Project

SPCC

TABLE OF CONTENTS

................................................................................................

MANAGEMENT APPROVAL ................................................................................................RING APPROVAL................................................................

................................................................................................................................PLAN ................................................................................................

AN REQUIREMENTS ................................................................

ORMATION..........................................................................................

COMPANY INFORMATION ................................................................................................................................................................................................

GENERAL REQUIREMENTS FOR ALL FACILITIES AND ALL TYPES OF OILS

RMANCE WITH THE REQUIREMENTS OF 40 CFR 112.7 (A) (1) AND (2)HE FACILITY 40 CFR 112.7 (A) (3) AND (I) ................................

DISCHARGE PREVENTION MEASURES 40 CFR 112.7 (A) (3) (II)................................................................................................................................

.............................................................................................................................TRANSFER ACTIVITIES ................................................................................................

................................................................................................IMPACT PROTECTION................................................................................................EMERGENCY SHUT OFF ................................................................................................

E CONTROLS 40 CFR 112.7 (A) (3) (III) ................................COUNTERMEASURES FOR DISCHARGE DISCOVERY, RESPONSE AND CLEANUP

................................................................................................................................DISCHARGE DISCOVERY AND REPORTING ................................................................NOTIFY AGENCIES VERBALLY ..............................................................................................

OF RECOVERED MATERIALS 40 CFR 112.7 (A) (3) (V)..........................NE NUMBERS 40 CFR 112.7 (A) (3) (VI)................................VEN TO CONTACTS 40 CFR 112.7 (A) (4) ................................

PROCEDURES TO FOLLOW IN THE EVENT OF A DISCHARGE 40 CFR 112.7 (A) (5)SPILL RESPONSE MATERIALS...............................................................................................

LOW AND TOTAL QUANTITY OF A POTENTIAL DISCHARGE 40 CFR 112.7................................................................................................CONTAINMENT AND DIVERSIONARY STRUCTURES AND EQUIPMENT

A DISCHARGE FROM REACHING WATERWAYS 40 CFR 112.7 (C)AND RECORDS 40 CFR 112.7 (E)...............................................................

DAILY EXAMINATIONS................................................................................................MONTHLY INSPECTIONS ................................................................................................

FOR DISCHARGE PREVENTION PROCEDURES 40 CFR 112.7 (F)112.7 (G) ................................................................................................

LOADING UNLOADING AREA CONTAINMENT 40 CFR 112.7 (H) ...........................TS 40 CFR 112.7 (I) ................................................................

TOC Page i


SPCC Plan

.....................................................1

........................................... 1.................................................... 2

................................ 3...................................... 3

.................................................. 3

..........................4

............................................ 4.............................................. 4

ND ALL TYPES OF OILS ...............6

12.7 (A) (1) AND (2) ... 6................................................ 6

...................................................11........................................................11

.............................12.........................................12

.................................................13..........................................13

.......................................13................................................14

RESPONSE AND CLEANUP 40 CFR 112.7 (A).........................................14

..........................................14..............................15

..........................16................................................16

..............................................1640 CFR 112.7 (A) (5)......................17

...............................18SCHARGE 40 CFR 112.7

................................................19AND EQUIPMENT

112.7 (C) ...........20...............................20

.........................................21.....................................21

112.7 (F) ...........22.........................................22

...........................23...............................................23

4.0 SUBPART B – REQUIREMENTS FOR ONS

4.1 FACILITY DRAINAGE 40 CFR 112.8 (B) (1) AN4.2 FACILITY DRAINAGE 40 CFR 112.8 (B) (3) AN4.3 BULK STORAGE CONTAIN4.4 CAPACITY OF SECONDARY CONTAINMENT AREA 44.5 METHOD TO ADDRESS PR

(C) (3)................................4.6 CATHODICALLY PROTECTED METAL UNDERGROUND

(5) ................................................................4.7 PERIODICALLY TEST THE INTEGRITY OF ABOVE4.8 LEAKAGE FROM HEATING4.9 ENGINEER OR UPDATE CONTAI4.10 OBSERVE EFFLUENT TREATMENT 40 CFR 112.84.11 PROMPTLY ADDRESS VISIBLE DISCHARGE 40 CF4.12 MOBILE OR PORTABLE STORAGE C4.13 FACILITY TRANSFER OPERATIONS 40 CFR 112.

TABLES

Table 1 – Facility Contact InformationTable 2 – On-site Oil Storage ContainersTable 3 – Emergency Call Down ListTable 4 – Scope of Monthly Inspections

FIGURES

Figure 1 – Project Vicinity Map................................Figure 2 – Waterbody Proximity MapFigure 3 –Typical Drill Pad LayoutFigure 4 – Example Overpack Container

APPENDICES

Appendix A Typical Drill Pad SiteAppendix B Spill HistoryAppendix C Monthly Inspection FormsAppendix D Discharge Notification FormsAppendix E Annual Training


SPCC

REQUIREMENTS FOR ONSHORE PETROLEUM AND NON-PETROLEUM OILS

CFR 112.8 (B) (1) AND (2) DIKED AREAS................................CFR 112.8 (B) (3) AND (4) UNDIKED AREAS................................

BULK STORAGE CONTAINERS 40 CFR 112.8 (C) (1) ................................................................Y CONTAINMENT AREA 40 CFR 112.8 (C) (2) ................................

METHOD TO ADDRESS PRECIPITATION WITHIN THE SECONDARY CONTAINMENT 40 CFR 112.8................................................................................................................................

ED METAL UNDERGROUND STORAGE TANKS 40 CFR................................................................................................E INTEGRITY OF ABOVEGROUND TANKS 40 CFR 112.8 (C) (

LEAKAGE FROM HEATING COILS 40 CFR 112.8 (C) (7) ................................................................EER OR UPDATE CONTAINERS TO AVOID DISCHARGE 40 CFR 112.8 (C)

ATMENT 40 CFR 112.8 (C) (9)...............................................................IBLE DISCHARGE 40 CFR 112.8 (C) (10) ................................TORAGE CONTAINERS 40 CFR 112.8 (C) (11) ................................

ERATIONS 40 CFR 112.8 (D)(1),(2),(3),(4) AND (5) ................................

Facility Contact Information............................................................................................site Oil Storage Containers................................................................

Emergency Call Down List .............................................................................................Scope of Monthly Inspections.......................................................................................

................................................................................................Waterbody Proximity Map.............................................................................................Typical Drill Pad Layout................................................................................................Example Overpack Container.......................................................................................

Typical Drill Pad Site Plan and Drill Pad Location Plan

Monthly Inspection FormsDischarge Notification Forms

Logs

TOC Page ii


SPCC Plan

PETROLEUM OILS........24

................................................24...........................................24

.....................................24......................................24

MENT 40 CFR 112.8...........................................24

STORAGE TANKS 40 CFR 112.8 (C) (4) AND................................................24

112.8 (C) (6)...............24................................24

(8) ....................25...............................25

...............................................25.......................................25

.................................25

PAGE

............................ 5...................................................... 11

............................. 16....................... 22

PAGE

....................................... 7............................. 8

................................. 10....................... 12

1.0 INTRODUCTION

The purpose of this Spill Prevention Control and Countermeasure (SPCC) Plan is to describemeasures implemented by Mosquito Consolidated Gold Mines Ltd. (Mosquito) to prevent oildischarges from occurring, and to prepare Mosmanner to mitigate the impacts of a discharge from drill pads associated withMolybdenum Exploration site.accordance with the SPCC requirements

The SPCC Plan is a working document designed to be a toolor minimize spills. As such, Mosquitoinformed of the provisions of the SPCC Plin minimizing a spill that occurs.establish and maintain the Spill Prevention Control & Countermeasures set forth herein.Plan shall be reviewed every fivecertified reviews shall be added as an attachment to this Plan as necessary.

This SPCC Plan is self-certified which is applicable for a Tier I qualified facility. To meetapplicability criteria, the facility must have:

a. a total aboveground oil storage capacity of 10,000 U.S. gallons or less;b. no aboveground oil storage containers with a capacity greater than 5,000 U.S.

gallons; andc. in the 3 years prior to the date

of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, orno two discharges of oil to navigable waters or adjoining shorelines eachexceeding 42 U.S. gallons within any 12

This plan has been developed for drill pad facilitiesoperational. For that reason all procedures, methods, or equipment included in the plan havebeen developed based on planned facilities and will be implThis plan can be modified as operationsconditions.

1.1 Management Approval

Mosquito is committed to preventing discharges of oil to navigable waters and the environmentthrough the implementation of this SPCC Plan. This SPCC Plan has the full approval ofmanagement. Mosquito’s management has committed the necessary resources tothe measures described in this Plan.


SPCC

The purpose of this Spill Prevention Control and Countermeasure (SPCC) Plan is to describemeasures implemented by Mosquito Consolidated Gold Mines Ltd. (Mosquito) to prevent oildischarges from occurring, and to prepare Mosquito to respond in a safe, effective, and timelymanner to mitigate the impacts of a discharge from drill pads associated with

. This SPCC Plan has been prepared and implemented inaccordance with the SPCC requirements contained in 40 CFR part 112.

The SPCC Plan is a working document designed to be a tool Mosquito uses regularly to preventMosquito shall see that its agents and employees are properly

informed of the provisions of the SPCC Plan and know their role in maintaining the SPCC Plan orin minimizing a spill that occurs. Mosquito is committed to providing the necessary resources toestablish and maintain the Spill Prevention Control & Countermeasures set forth herein.

five years or sooner if facility changes impact the Plan.certified reviews shall be added as an attachment to this Plan as necessary.

certified which is applicable for a Tier I qualified facility. To meetapplicability criteria, the facility must have:

a total aboveground oil storage capacity of 10,000 U.S. gallons or less;no aboveground oil storage containers with a capacity greater than 5,000 U.S.

in the 3 years prior to the date the SPCC Plan is certified, had no single dischargeof oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, orno two discharges of oil to navigable waters or adjoining shorelines eachexceeding 42 U.S. gallons within any 12-month period.

This plan has been developed for drill pad facilities that may not be currently constructed oroperational. For that reason all procedures, methods, or equipment included in the plan havebeen developed based on planned facilities and will be implemented at the start of operations.This plan can be modified as operations are initiated to better reflect actual operational

is committed to preventing discharges of oil to navigable waters and the environmentthrough the implementation of this SPCC Plan. This SPCC Plan has the full approval of

’s management has committed the necessary resources tothe measures described in this Plan.

Page 1


SPCC Plan

The purpose of this Spill Prevention Control and Countermeasure (SPCC) Plan is to describemeasures implemented by Mosquito Consolidated Gold Mines Ltd. (Mosquito) to prevent oil

quito to respond in a safe, effective, and timelymanner to mitigate the impacts of a discharge from drill pads associated with the CuMo

This SPCC Plan has been prepared and implemented in

uses regularly to preventshall see that its agents and employees are properlyan and know their role in maintaining the SPCC Plan or

is committed to providing the necessary resources toestablish and maintain the Spill Prevention Control & Countermeasures set forth herein. The

years or sooner if facility changes impact the Plan. Engineer

certified which is applicable for a Tier I qualified facility. To meet the Tier I

a total aboveground oil storage capacity of 10,000 U.S. gallons or less;no aboveground oil storage containers with a capacity greater than 5,000 U.S.

the SPCC Plan is certified, had no single dischargeof oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, orno two discharges of oil to navigable waters or adjoining shorelines each

currently constructed oroperational. For that reason all procedures, methods, or equipment included in the plan have

emented at the start of operations.to better reflect actual operational

is committed to preventing discharges of oil to navigable waters and the environmentthrough the implementation of this SPCC Plan. This SPCC Plan has the full approval of Mosquito

’s management has committed the necessary resources to implement

1.3 Plan Review

In accordance with 40 CFR 112.5, MosquitoSPCC Plan for any change in operations or maintenance that materially affects the site’spotential for an oil discharge. Mosquitofive years, however, since the duration of exploration is not anticipated to extend beyond fiveyears a review may not be performed.this SPCC Plan, any revisions, if needed,will implement any amendment as soon as possible, but not later than six months followingpreparation of any amendment. A registered PEPlan, as described above, in accordance with 40 CFR 112.3(d

This plan will be submitted, reviewed, and potentially amended upon the direction of the U.S.EPA Administrator in accordance with 40 CFR 112.4 if the following occur:

A single spill event occurs during which more than 1,000 gallons of oilwaters of the U.S., or

Two federally reportable spills occur within a 12water quality standards or cause a sheen upon the water.

1.4 Location of the SPCC Plan

In accordance with 40 CFR 112.3(e), andexploration phase, a complete copy of this SPCC is maintained at theclosest to the site, which is located in Garden Valley Idaho atPlan is available for the Regional Administrator to review during normal businessMonday through Friday, Mountain Time.

1.5 Facility Response Plan Requirements

A facility response plan (FRP) may be needed if the owner or operator of any nontransportation-related onshore facility that, because of its location, could reasonably beexpected to cause harm to the environment by discharging oil into or on navigable waters oradjoining shorelines. The FRP should be prepared according to 40 CFR 112.20.the following criteria, a FRP may be needed:1) The facility transfers oil over water to or from vessels and has a total oil storage capacity

greater than or equal to 42,000 gallons; or2) The facility has a total oil storage capacity greater than or equal to 1 million gallons and

other factors are applicable under

Since the CuMo Exploration Project does not meet either of the above criteria, aresponse plan has not been prepared


SPCC

In accordance with 40 CFR 112.5, Mosquito is required to periodically review andSPCC Plan for any change in operations or maintenance that materially affects the site’s

Mosquito is required to review this SPCC Plan at least once everyhowever, since the duration of exploration is not anticipated to extend beyond five

years a review may not be performed. If Mosquito deems it necessary to review and evaluateneeded, will be made within six months of the review.

will implement any amendment as soon as possible, but not later than six months followingpreparation of any amendment. A registered PE will certify any technical amendment to thePlan, as described above, in accordance with 40 CFR 112.3(d).

be submitted, reviewed, and potentially amended upon the direction of the U.S.EPA Administrator in accordance with 40 CFR 112.4 if the following occur:

A single spill event occurs during which more than 1,000 gallons of oil

Two federally reportable spills occur within a 12-month period, which violate applicablewater quality standards or cause a sheen upon the water.

Location of the SPCC Plan

In accordance with 40 CFR 112.3(e), and because various drill pads will be in use throughexploration phase, a complete copy of this SPCC is maintained at the Mosquitoclosest to the site, which is located in Garden Valley Idaho at 1069 Banks Lowman Road

le for the Regional Administrator to review during normal businessMonday through Friday, Mountain Time.

Facility Response Plan Requirements

A facility response plan (FRP) may be needed if the owner or operator of any nononshore facility that, because of its location, could reasonably be

expected to cause harm to the environment by discharging oil into or on navigable waters orThe FRP should be prepared according to 40 CFR 112.20. If a facility meets

the following criteria, a FRP may be needed:The facility transfers oil over water to or from vessels and has a total oil storage capacitygreater than or equal to 42,000 gallons; orThe facility has a total oil storage capacity greater than or equal to 1 million gallons andother factors are applicable under 40CFR112.20 (f)(ii).

Since the CuMo Exploration Project does not meet either of the above criteria, as not been prepared.

Page 3


SPCC Plan

and evaluate thisSPCC Plan for any change in operations or maintenance that materially affects the site’s

this SPCC Plan at least once everyhowever, since the duration of exploration is not anticipated to extend beyond five

If Mosquito deems it necessary to review and evaluatereview. Mosquito

will implement any amendment as soon as possible, but not later than six months followingany technical amendment to the

be submitted, reviewed, and potentially amended upon the direction of the U.S.

A single spill event occurs during which more than 1,000 gallons of oil reach navigable

month period, which violate applicable

because various drill pads will be in use throughout theMosquito field office

1069 Banks Lowman Road. Thele for the Regional Administrator to review during normal business hours,

A facility response plan (FRP) may be needed if the owner or operator of any non-onshore facility that, because of its location, could reasonably be

expected to cause harm to the environment by discharging oil into or on navigable waters orIf a facility meets

The facility transfers oil over water to or from vessels and has a total oil storage capacity

The facility has a total oil storage capacity greater than or equal to 1 million gallons and

Since the CuMo Exploration Project does not meet either of the above criteria, a facility

2.0 GENERAL FACILITY INFORMATION

2.1 Company Information

2.2 Contact Information

The designated person accountable for overall oil spill prevention and response at the facility isthe Project Coordinator, Nick Garshelis

Name of Facility:Type

Date of Initial Operation

Location

Name and Address of Owner


SPCC

ORMATION

The designated person accountable for overall oil spill prevention and response at the facility isNick Garshelis. 24-hour contact information is provided in Table 1.

CuMo Exploration ProjectMining Exploration

2011

Boise National ForestEast of USFS Road 382C

Mosquito Consolidated Gold Mines, Ltd.

Regional Field Office1069 Banks Lowman RoadGarden Valley, ID 83622

Corporate Headquarters1616 West 3rd Avenue, Suite 100Vancouver, BC V6J 1K2

Page 4


SPCC Plan

The designated person accountable for overall oil spill prevention and response at the facility ishour contact information is provided in Table 1.

Table

Name Title

Shaun Dykes Exploration Manager

Mosquito ConsolidatedGold Mines, Ltd.

Nick Garshelis Senior Geologist/ProjectCoordinator

Mosquito ConsolidatedGold Mines, Ltd.

Kyle McClay President/Manager

Kirkness DiamondDrilling


SPCC

Table 1 – Facility Contact Information

Telephone Address

Exploration Manager

Mosquito Consolidated

(604) 520.6511 (office) 1616 West 3rd

Avenue, Suite 100Vancouver, BC V6J 1

Senior Geologist/Project

Mosquito Consolidated

(208) 462-2197 (office)(208) 830-6397 (cell)

1069 Banks Lowman Road

Garden Valley, ID

/Manager

Kirkness Diamond

(208) 392-1074 (office)

(208) 392-1102 (fax)

3105 W. Dorchester

Eagle, ID 81616

Page 5


SPCC Plan

Avenue, Suite 100Vancouver, BC V6J 1K2

1069 Banks Lowman Road

Garden Valley, ID 83622

Dorchester

3.0 SUBPART A – GENERAL REQUIREMENTS

3.1 The Facility’s Conformance with the requirements of 40 CFR 112.7 (a) (1) and (2)

Mosquito has taken all reasonable steps to comply with the 40 CFR 112. The followingof exceptions and the details are noted in the applicable provisions of this SPCC Plan.

1. The drill rigs are considered(k) (1). Per 40 CFR 112.7 (k) this facilityspill contingency plan for this equipment.

2. Liquid level sensing devices are not practical for this facility due to the type ofequipment and nature of operations. During refueling, operators will readily monitorrefueling and follow refueling procedures per Section 3.3.3.

3.2 Physical Layout of the Facility 40 CFR 112.7 (a) (3) and (i)

The exploration project is generallyA vicinity map showing the CuMo


SPCC

GENERAL REQUIREMENTS FOR ALL FACILITIES AND ALL TYPES OF OILS

The Facility’s Conformance with the requirements of 40 CFR 112.7 (a) (1) and (2)

Mosquito has taken all reasonable steps to comply with the 40 CFR 112. The followingexceptions and the details are noted in the applicable provisions of this SPCC Plan.

The drill rigs are considered Qualified Oil-Filled Operational Equipment per 40 CFR 112.7(k) (1). Per 40 CFR 112.7 (k) this facility will establish inspection procedures andspill contingency plan for this equipment.Liquid level sensing devices are not practical for this facility due to the type of

and nature of operations. During refueling, operators will readily monitorrefueling and follow refueling procedures per Section 3.3.3.

Physical Layout of the Facility 40 CFR 112.7 (a) (3) and (i)

generally located about 14 miles north of Idaho City in Boise County.CuMo area in relation to nearby cities is shown below in Figure 1.

Page 6


SPCC Plan

ND ALL TYPES OF OILS

The Facility’s Conformance with the requirements of 40 CFR 112.7 (a) (1) and (2)

Mosquito has taken all reasonable steps to comply with the 40 CFR 112. The following is a listexceptions and the details are noted in the applicable provisions of this SPCC Plan.

per 40 CFR 112.7establish inspection procedures and an oil

Liquid level sensing devices are not practical for this facility due to the type ofand nature of operations. During refueling, operators will readily monitor

miles north of Idaho City in Boise County.area in relation to nearby cities is shown below in Figure 1.

The project area is located within thethe only perennially flowing named streamproximity to the exploration area to thedischarges would drain into 1st and 2nd or


SPCC

Figure 1 –

The project area is located within the Heathe only perennially flowing named streamproximity to the exploration area to the

rain into 1st and 2nd or


SPCC Plan

Heathe only perennially flowing named streamproximity to the exploration area to the

within the project area. A map showing the generalnearest waterbody is shown in Figure 2. Potential

der tributaries of Grimes Creek.

Project Vicinity Map

dwaters Grimes Creek subwatershed. Grimes Creek iswithin the project area. A map showing the general

nearest waterbody is shown in Figure 2. Potentialder tributaries of Grimes Creek.

Project Site

Page 7

dwaters Grimes Creek subwatershed. Grimes Creek iswithin the project area. A map showing the general

nearest waterbody is shown in Figure 2. Potential

Figure

Since there may be up to 137 drill pads located at the sitefour pads in operation at one timewaterways, roads, and inhabited areasdrill pad locations and temporary roadway planned for the fin Appendix A. As Mosquito approaches completion of conpads and temporary roads, the need for additional dril


SPCC

Figure 2 – Waterbody Proximit

be up to 137 drill pads located at the sitefour pads in operation at one time, site topography and twaterways, roads, and inhabited areas will be different for

locations and temporary roadway planned for the fAs Mosquito approaches completion of con

pads and temporary roads, the need for additional drill p

l


SPCC Plan

be up to 137 drill pads located at the siteite topography and t

As Mosquito approaches completion of conl p

l

Figure Source: CuMo ExplorationProject EnvironmentalAssessment, USFS Boise Nationa

Exploration

Assessment, USFS Boise Nationa

over a five year period

irst phasestruction of the first phase of drill

y Map

over a five year periodhe location of theeach drill pad. A siteirst phase of constructionstruction of the first phase of drillads and temporary roads will be

Forest, February 2011

Page 8

over a five year period, with up tohe location of the pads relative to

A site plan showingof construction is shown

struction of the first phase of drillads and temporary roads will be

evaluated and if deemed necessary, additional phases of plans will be submitted to USFS forreview and approval prior to construction. Additional figures will be added to Appendix Aexploration project proceeds and

Because the drill pads are temporary facilities, no fixed containersat the sites. A typical drill pad will be approximately 60 ft long by 25 ft wide with ends or sidescontoured into the temporary access roads. Each drill pad will have a compartmentalized mudpit so that drill fluids will be retained onsite. Drill machines, light lamps,tools and supplies will be kept at the drill pad locations. A service pickdrillers, fuel, and daily drilling consumables during operations. The mud pits will generally belocated on the drill pad site dowthe pits. A typical drill pad configuration is shown in Figure


SPCC

evaluated and if deemed necessary, additional phases of plans will be submitted to USFS forreview and approval prior to construction. Additional figures will be added to Appendix Aexploration project proceeds and new drill pad locations are identified.

the drill pads are temporary facilities, no fixed containers or equipmentA typical drill pad will be approximately 60 ft long by 25 ft wide with ends or sides

contoured into the temporary access roads. Each drill pad will have a compartmentalized mudpit so that drill fluids will be retained onsite. Drill machines, light lamps, spill kits, and ancillarytools and supplies will be kept at the drill pad locations. A service pick-up truck will transportdrillers, fuel, and daily drilling consumables during operations. The mud pits will generally belocated on the drill pad site downgradient from drilling activities to allow drill fluids to flow intothe pits. A typical drill pad configuration is shown in Figure 3.

Page 9


SPCC Plan

evaluated and if deemed necessary, additional phases of plans will be submitted to USFS forreview and approval prior to construction. Additional figures will be added to Appendix A as the

or equipment will be storedA typical drill pad will be approximately 60 ft long by 25 ft wide with ends or sides

contoured into the temporary access roads. Each drill pad will have a compartmentalized mudspill kits, and ancillary

up truck will transportdrillers, fuel, and daily drilling consumables during operations. The mud pits will generally be

ngradient from drilling activities to allow drill fluids to flow into

A


SPCC


SPCC Plan

Notes:1. Figure represents a generalized

drill pad plan. Actual dimensionswill vary and will not exceed thoseshown.

2. “Oils” kept on-site include oil andgasoline for small equipment anddrill fluid additives. Oils will bestored in 5-gal or less containersand stored in a containment area toprevent accidental release to soil orto navigable waters.

3. Stormwater BMPs to beimplemented during construction.

4. Fresh water will be delivered to theMixing Tank by hose, pumped fromthe creek or stand pipe, or hauled

and stored in a containment area toprevent accidental release to soil or

to theby hose, pumped from

Figure

list of oil storage containers greater than 55

in by truck.

Figure 3 –Typical Drill Pad Layout

storage containers greater than 55-gallons is shown in Table 2.

Page 10

Table

Type

Mobile Refueler

Drill rig fuel tank

Drill rig oil tank

Additional equipment with tank capacities less than 55 gallons includes light stands and waterpumps, which run on diesel fuel, and other miscellaneous small equipment.

Lubricating oil and other substances, such as solvents and chemicals for downhole treatment,are also stored at the drill pads, but in quantities 5threshold for SPCC applicability. These oils will be kept in acontainment area, to prevent accidental spills into the environment.

3.3 Discharge Prevention Measures 40 CFR 112.7 (a) (3) (ii)

The operation of drill rigs during the exploration project requires the use of various oils tooperate the drill equipment. Discharge prevention measures are those steps or procedurestaken to minimize the potential for a discharge of oil products at the facility.

3.3.1 EquipmentThe drill rigs contain a stdrill rig is considered aSection 112.7(k)(1). In lieu of secondary containment an established anddocumented procedure for inspections will be implemented. The procedureincludes daily informper 40 CFR 112.7 (e)

Oil Spill Contingency.immediately begin cleanup in accordance withIn addition, if operators are unable to contain the spill in the immediate area ofthe rig, any spill from the rig would be captured within the sumps which arelocated downgradient from the drill rig. Spills reaching sumps will be containedand cleaned-up per

The source water pump which may supply water to the drill pad sites is locatedadjacent to Grimes Creek. The pump has a 25 gallon fuel tank. The pump islocated within a skid mounted shed which is concontainment area to provide secondary containment in the event of anaccidental release. The lined containment area extends approximately 3 feetfrom the exterior of the


SPCC

Table 2 – On-site Oil Storage Containers

Capacity(gallons)

Product stored

Mobile Refueler 100 Diesel Fuel

Drill rig fuel tank 50 Diesel Fuel

tank 85 Hydraulic Oil

Additional equipment with tank capacities less than 55 gallons includes light stands and waterpumps, which run on diesel fuel, and other miscellaneous small equipment.

Lubricating oil and other substances, such as solvents and chemicals for downhole treatment,are also stored at the drill pads, but in quantities 5-gallons or less which is below the 55threshold for SPCC applicability. These oils will be kept in a plastic storage bin, or a similarcontainment area, to prevent accidental spills into the environment.

Discharge Prevention Measures 40 CFR 112.7 (a) (3) (ii)

The operation of drill rigs during the exploration project requires the use of various oils toDischarge prevention measures are those steps or procedures

taken to minimize the potential for a discharge of oil products at the facility.

EquipmentThe drill rigs contain a storage capacity for diesel fuel and hydraulic fdrill rig is considered a Qualified Oil-filled Operational EquipmentSection 112.7(k)(1). In lieu of secondary containment an established anddocumented procedure for inspections will be implemented. The procedure

informal inspections and monthly inspections of the equipment40 CFR 112.7 (e) of this plan.

Oil Spill Contingency. If a spill were to occur from the drill rigimmediately begin cleanup in accordance with 40 CFR 112.7 (a)(5)In addition, if operators are unable to contain the spill in the immediate area ofthe rig, any spill from the rig would be captured within the sumps which arelocated downgradient from the drill rig. Spills reaching sumps will be contained

up per 40 CFR 112.7 (a)(5) of this plan.

The source water pump which may supply water to the drill pad sites is locatedadjacent to Grimes Creek. The pump has a 25 gallon fuel tank. The pump islocated within a skid mounted shed which is contained within a linedcontainment area to provide secondary containment in the event of anaccidental release. The lined containment area extends approximately 3 feetfrom the exterior of the skid mounted shed. Any spills within the

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SPCC Plan

Additional equipment with tank capacities less than 55 gallons includes light stands and water

Lubricating oil and other substances, such as solvents and chemicals for downhole treatment,gallons or less which is below the 55-gallon

plastic storage bin, or a similar

The operation of drill rigs during the exploration project requires the use of various oils toDischarge prevention measures are those steps or procedures

and hydraulic fluid. Thefilled Operational Equipment by 40 CFR

Section 112.7(k)(1). In lieu of secondary containment an established anddocumented procedure for inspections will be implemented. The procedure

inspections of the equipment

If a spill were to occur from the drill rig, operators will40 CFR 112.7 (a)(5) of this plan.

In addition, if operators are unable to contain the spill in the immediate area ofthe rig, any spill from the rig would be captured within the sumps which arelocated downgradient from the drill rig. Spills reaching sumps will be contained

The source water pump which may supply water to the drill pad sites is locatedadjacent to Grimes Creek. The pump has a 25 gallon fuel tank. The pump is

tained within a linedcontainment area to provide secondary containment in the event of anaccidental release. The lined containment area extends approximately 3 feet

Any spills within the containment

area will be cleaned up perwithin the shed.

Mosquito is committed to supplying the proper manpower, equipment, andmaterials required to expeditiously control and remove any quantity of oildischarged that ma

3.3.2 StorageFuel and oils will be stored offdaily basis. Only enough fuel and oil required for daily use withe sites. If, during isolated instances, it is deemed necessary to transport andstore fuel or oil in 55gallon overpack drums, or similar containers, comparable to the photo shown inFigure 4. These contaiof a 55-gallon drum.

In accordance with the EA, plastic drumpallets.

3.3.3 Transfer ActivitiesDiesel fuel is transported to the site usingwhich has a capacity of 100 gallons.


SPCC

e cleaned up per 40 CFR 112.7 (a)(5) of this plan. A spill kit is located

Mosquito is committed to supplying the proper manpower, equipment, andmaterials required to expeditiously control and remove any quantity of oildischarged that may be harmful.

Fuel and oils will be stored off-site and transported to drill pad locations on adaily basis. Only enough fuel and oil required for daily use will be transported to

If, during isolated instances, it is deemed necessary to transport andstore fuel or oil in 55-gallon containers or larger, drums will be stored within 95gallon overpack drums, or similar containers, comparable to the photo shown in

These containers provide greater than 1.5 times the container volumegallon drum.

Figure 4 – Example Overpack Container

In accordance with the EA, plastic drum-contained liquids will be stored on wood

Transfer ActivitiesDiesel fuel is transported to the site using a pick-up truck mounted sliptankwhich has a capacity of 100 gallons. In order to eliminate the amount of times

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SPCC Plan

A spill kit is located

Mosquito is committed to supplying the proper manpower, equipment, andmaterials required to expeditiously control and remove any quantity of oil

and transported to drill pad locations on all be transported to

If, during isolated instances, it is deemed necessary to transport andgallon containers or larger, drums will be stored within 95-

gallon overpack drums, or similar containers, comparable to the photo shown inners provide greater than 1.5 times the container volume

contained liquids will be stored on wood

truck mounted sliptank,In order to eliminate the amount of times

fuel is transferredThe pickup truck will have a D.O.T. certified fuel cell with a retractable hose reelfor refueling the drill, light plant and other diesel equipment at the site. It isestimated that the drill will need to be refueled approximately twice during each12-hour shift, or four times daily during 24

To eliminate the transfer of hydraulic oil, oil is filtered using a kidney machineapproximately once every four months.connected to the drill rig and recycles hydraulicontaminants greater than

If a diesel pump is used for pumping fresh water from the creek to the drill padsites, fuel will be transported to the pumpsdaily.

During refueling,procedures. Operators willbeing filled prior to start of refueling.therefore operators willlevel approaches fill. Operators willcapped or emptied prior to retracting to prevent spills during retracting. Sorbentpads will be placed around tanks being

3.3.4 Leak DetectionVisual monitoring of tanks and drumsof leakage. Records of these inspectionsname of the person doing thewill be kept for three yearsAppendix C.

3.3.5 Impact ProtectionStorage of oils shall be kept in an area of the drill pad site that is not intended forvehicle traffic.

3.3.6 Emergency Shut offEmergency disconnect switchesthe transfer of fuel in the event of a spill or other emergency. All personnel shallbe trained in the appropriate shut off procedurefailure (e.g., hose break).


SPCC

fuel is transferred, diesel is directly transferred from the sliptank to the drill rig.truck will have a D.O.T. certified fuel cell with a retractable hose reel

for refueling the drill, light plant and other diesel equipment at the site. It isestimated that the drill will need to be refueled approximately twice during each

r four times daily during 24-hour drilling operations.

To eliminate the transfer of hydraulic oil, oil is filtered using a kidney machineapproximately once every four months. The kidney machine is directlyconnected to the drill rig and recycles hydraulic oil after filtering outcontaminants greater than 1 micron.

If a diesel pump is used for pumping fresh water from the creek to the drill padsites, fuel will be transported to the pumps, which will be refueled

operators will readily monitor refueling and follow refuelingOperators will verify that the hose is properly attached to that tank

being filled prior to start of refueling. Tanks are not equipped with level alarms,perators will visually observe refueling and discontinue when tank

level approaches fill. Operators will verify that the retractable hose is eithercapped or emptied prior to retracting to prevent spills during retracting. Sorbentpads will be placed around tanks being refueled to catch spills should they occur.

Leak Detectionitoring of tanks and drums will be performed monthly for visible signsRecords of these inspections will show the date of the inspection, the

name of the person doing the inspection, and any sign of leakage noted.be kept for three years, i.e., June 2014 or later; sample forms are attached

Impact ProtectionStorage of oils shall be kept in an area of the drill pad site that is not intended for

Emergency Shut offEmergency disconnect switches will be provided at prominent locations to stopthe transfer of fuel in the event of a spill or other emergency. All personnel shallbe trained in the appropriate shut off procedures in the event of equipment

hose break).

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SPCC Plan

, diesel is directly transferred from the sliptank to the drill rig.truck will have a D.O.T. certified fuel cell with a retractable hose reel

for refueling the drill, light plant and other diesel equipment at the site. It isestimated that the drill will need to be refueled approximately twice during each

hour drilling operations.

To eliminate the transfer of hydraulic oil, oil is filtered using a kidney machineThe kidney machine is directly

c oil after filtering out

If a diesel pump is used for pumping fresh water from the creek to the drill padrefueled approximately

readily monitor refueling and follow refuelingverify that the hose is properly attached to that tank

with level alarms,refueling and discontinue when tank

retractable hose is eithercapped or emptied prior to retracting to prevent spills during retracting. Sorbent

refueled to catch spills should they occur.

be performed monthly for visible signsshow the date of the inspection, the

inspection, and any sign of leakage noted. Recordssample forms are attached

Storage of oils shall be kept in an area of the drill pad site that is not intended for

be provided at prominent locations to stopthe transfer of fuel in the event of a spill or other emergency. All personnel shall

in the event of equipment

3.4 Discharge or Drainage Controls 40

Secondary containment is a requirement for all fuel and oil tanks 55the exception of mobile refueling. The volume of the secondary containment must be 1.5 timesthe volume of the largest storage container. Under typical operations,stored at drill pad locations in volumes of 55mounted sliptanks. If, during isolated instances, it is deemed necessary to transport and storefuel or oil in 55-gallon containers or ldrums, or similar containers, comparable to the photo shown in Figure

Smaller containers (5-gallons or less) of oils for production will be stored in a plastic storage bin,or similar containment area, to prevent accidental spills.

Lids or tarp covers will be in place at all times over secondary containment areas to preventprecipitation from collecting within the area.

Sumps for drilling operations will be located downgradient from drilling actiare unable to be contained immediately by operators will flow into the sump pits to contain therelease, therefore containing the release.

A bermed secondary containment system will contain an accidental release from the sourcewater pump which may supply water to the drill pad sites.

3.5 Countermeasures for Discharge Discovery, Response and Cleanup 40 CFR 112.7 (a) (3)(iv)

3.5.1 Discharge Discovery andSeveral individuals and organizations must be contacted in the event of an oildischarge. The Project Coordinatordischarge notifications have been made. All discharges should be reported to theProject Coordinatorthe information that must be provided when reporting a discharge, includingcontact lists and phone numbers.

Because of the remoteness of the site, cell phone service is notavailable at the site. Mosquito is currently evaluating options forcommunication. These options include the use of satellite or radios phones.

3.5.1.1 Verbal Notification RequirementsFor any discharge that reaches navigable waters, or threatens to rnavigable waters,


SPCC

Controls 40 CFR 112.7 (a) (3) (iii)

Secondary containment is a requirement for all fuel and oil tanks 55-gallons and above, withthe exception of mobile refueling. The volume of the secondary containment must be 1.5 timesthe volume of the largest storage container. Under typical operations, fuel and oil will not bestored at drill pad locations in volumes of 55-gallons or larger, with the exception of truckmounted sliptanks. If, during isolated instances, it is deemed necessary to transport and store

gallon containers or larger, drums will be stored within 95-gallon over packdrums, or similar containers, comparable to the photo shown in Figure 4.

gallons or less) of oils for production will be stored in a plastic storage bin,area, to prevent accidental spills.

be in place at all times over secondary containment areas to preventprecipitation from collecting within the area.

Sumps for drilling operations will be located downgradient from drilling activities. Releases thatare unable to be contained immediately by operators will flow into the sump pits to contain therelease, therefore containing the release.

secondary containment system will contain an accidental release from the sourcewater pump which may supply water to the drill pad sites.

Countermeasures for Discharge Discovery, Response and Cleanup 40 CFR 112.7 (a) (3)

Discharge Discovery and ReportingSeveral individuals and organizations must be contacted in the event of an oil

Project Coordinator is responsible for ensuring that all requireddischarge notifications have been made. All discharges should be reported to the

ct Coordinator. The form included in Appendix D of this Plan summarizesthe information that must be provided when reporting a discharge, includingcontact lists and phone numbers.

Because of the remoteness of the site, cell phone service is notavailable at the site. Mosquito is currently evaluating options forcommunication. These options include the use of satellite or radios phones.

Verbal Notification RequirementsFor any discharge that reaches navigable waters, or threatens to rnavigable waters, immediate notification must be made to the National

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SPCC Plan

gallons and above, withthe exception of mobile refueling. The volume of the secondary containment must be 1.5 times

fuel and oil will not begallons or larger, with the exception of truck

mounted sliptanks. If, during isolated instances, it is deemed necessary to transport and storegallon over pack

gallons or less) of oils for production will be stored in a plastic storage bin,

be in place at all times over secondary containment areas to prevent

vities. Releases thatare unable to be contained immediately by operators will flow into the sump pits to contain the

secondary containment system will contain an accidental release from the source

Countermeasures for Discharge Discovery, Response and Cleanup 40 CFR 112.7 (a) (3)

Several individuals and organizations must be contacted in the event of an oilis responsible for ensuring that all required

discharge notifications have been made. All discharges should be reported to theof this Plan summarizes

the information that must be provided when reporting a discharge, including

Because of the remoteness of the site, cell phone service is not currentlyavailable at the site. Mosquito is currently evaluating options forcommunication. These options include the use of satellite or radios phones.

For any discharge that reaches navigable waters, or threatens to reachnotification must be made to the National

Response Center Hotline (800Protection Agency.

In the event of a discharge that threatens to result in an emergencycondition, facility field p(911) or the Idaho Communication Center (1and in no case later thandischarge. An emergency condition is any condition that could reasbe expected to endanger the health and safety of the public; causesignificant adverse impact to the land, water, or air environment; orcause severe damage to property. This notification must be maderegardless of the amount of the discharge.

Pursuant to Idaho Code (IDAPA 58.01.02.851.01 and 04) verbalnotification must be made to the Department of Environmental Quality(208-373-0550)25 gallons, or a discharge that causes a sheen on nearbyrelease less than 25 gallons must be reported to DEQ only if cleanupcannot be accomplished within 24 hours. IDAPA 58.01.02.10.76 defines arelease as, “Any unauthorized spilling, leaking, emitting, discharging,escaping, leaching, or dis

If any of the above agencies area contacted, field personnel will alsocontact the Boise National Forest Idaho City District RangerEsperancecleanup operations.

3.5.1.2 Written Notification RequirementsA written notification will be made to EPA for any single discharge of oilto a navigable water, or for two discharges of 1 bbl (42 gallons) of oil to awaterway in any 12made within 60 days of the qualifying discharge, and a copy will be sentto the Idaho Department of Environmental Quality (DEQ). This reportingrequirement is separate and in addition to reporting under 40 CFR part110 discussed above.

3.5.2 Notify Agencies VerballySome notifications must be completedis important to immediately contact thenotifications can be made. If theCoordinator requests it, field personnel must designate one person to beginnotification. Section 3.


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Response Center Hotline (800-424-8802) and to the EnvironmentalProtection Agency.

In the event of a discharge that threatens to result in an emergencycondition, facility field personnel must verbally notify the fire department(911) or the Idaho Communication Center (1-800-632-8000) immediately,and in no case later than within one (1) hour of the discovery of thedischarge. An emergency condition is any condition that could reasbe expected to endanger the health and safety of the public; causesignificant adverse impact to the land, water, or air environment; orcause severe damage to property. This notification must be maderegardless of the amount of the discharge.

uant to Idaho Code (IDAPA 58.01.02.851.01 and 04) verbalnotification must be made to the Department of Environmental Quality

0550) within 24 hours of a release of petroleum of greater than25 gallons, or a discharge that causes a sheen on nearbyrelease less than 25 gallons must be reported to DEQ only if cleanupcannot be accomplished within 24 hours. IDAPA 58.01.02.10.76 defines arelease as, “Any unauthorized spilling, leaking, emitting, discharging,escaping, leaching, or disposing into soil, groundwater, or surface water.

If any of the above agencies area contacted, field personnel will alsocontact the Boise National Forest Idaho City District RangerEsperance (208-392-6681) to inform the USFS of the discharge andcleanup operations.

Written Notification RequirementsA written notification will be made to EPA for any single discharge of oilto a navigable water, or for two discharges of 1 bbl (42 gallons) of oil to awaterway in any 12-month period. This written notification must bemade within 60 days of the qualifying discharge, and a copy will be sentto the Idaho Department of Environmental Quality (DEQ). This reportingrequirement is separate and in addition to reporting under 40 CFR part110 discussed above.

Notify Agencies VerballySome notifications must be completed immediately upon discovering the discharge. Itis important to immediately contact the Project Coordinatornotifications can be made. If the Project Coordinator is not available,

requests it, field personnel must designate one person to beginnotification. Section 3.5.1 of this Plan describes the required notifications to

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SPCC Plan

8802) and to the Environmental

In the event of a discharge that threatens to result in an emergencyersonnel must verbally notify the fire department

8000) immediately,of the discovery of the

discharge. An emergency condition is any condition that could reasonablybe expected to endanger the health and safety of the public; causesignificant adverse impact to the land, water, or air environment; orcause severe damage to property. This notification must be made

uant to Idaho Code (IDAPA 58.01.02.851.01 and 04) verbalnotification must be made to the Department of Environmental Quality

within 24 hours of a release of petroleum of greater than25 gallons, or a discharge that causes a sheen on nearby surface water. Arelease less than 25 gallons must be reported to DEQ only if cleanupcannot be accomplished within 24 hours. IDAPA 58.01.02.10.76 defines arelease as, “Any unauthorized spilling, leaking, emitting, discharging,

posing into soil, groundwater, or surface water.”

If any of the above agencies area contacted, field personnel will alsocontact the Boise National Forest Idaho City District Ranger Ruth

) to inform the USFS of the discharge and

A written notification will be made to EPA for any single discharge of oilto a navigable water, or for two discharges of 1 bbl (42 gallons) of oil to a

tification must bemade within 60 days of the qualifying discharge, and a copy will be sentto the Idaho Department of Environmental Quality (DEQ). This reportingrequirement is separate and in addition to reporting under 40 CFR part

upon discovering the discharge. Itso that timely

is not available, or the Projectrequests it, field personnel must designate one person to begin

1 of this Plan describes the required notifications to

government agencies. Thenotifications, if needed, are submitted to the appropriate agencies.

3.6 Methods of Disposal of Recovered M

If the discharge is contained by facility personnel, the recovered material will be stored indrums. The material shall then be disposed at a licensed landfill.

If a cleanup contractor is called,recovered product, contaminated soil, contaminated materials and equipment,decontamination solutions, sorbents, and spent chemicals collected during a response to adischarge incident.

The Idaho DEQ website maintains a list of Environmental Contractors and can be found at;http://www.deq.idaho.gov/multimedia_assistance/Clean_Up/contractors.cfm

If Mosquito responds to a discharge without involvement of a cleanup contractor, Mosquito willcontract a licensed transportation/disposal company to dispose of waste according toregulatory requirements. The Project Coordinatorthe use of certified waste containers.

3.7 Contact List and Phone N

A table showing an emergency contact list is shown in Table 3.

Table

AgencyMosquito/NickProject Coordinator

Local PoliceFire DepartmentMedical Emergency

National Response Center

Idaho Communication Center

EPA Region 10

Idaho Department of EnvironmentalQuality

Boise National ForestDistrict Ranger Ruth Esperance

3.8 Information to be Given to

The Project Coordinator will ensure that thenotifications have been made to the appropriate authorities. The


SPCC

government agencies. The Project Coordinator must also ensure that writtennotifications, if needed, are submitted to the appropriate agencies.

Methods of Disposal of Recovered Materials 40 CFR 112.7 (a) (3) (v)

If the discharge is contained by facility personnel, the recovered material will be stored inall then be disposed at a licensed landfill.

, they will be responsible for handling the properrecovered product, contaminated soil, contaminated materials and equipment,

sorbents, and spent chemicals collected during a response to a

The Idaho DEQ website maintains a list of Environmental Contractors and can be found at;http://www.deq.idaho.gov/multimedia_assistance/Clean_Up/contractors.cfm

If Mosquito responds to a discharge without involvement of a cleanup contractor, Mosquito willcontract a licensed transportation/disposal company to dispose of waste according to

Project Coordinator will characterize the waste and arrange forthe use of certified waste containers.

Contact List and Phone Numbers 40 CFR 112.7 (a) (3) (vi)

A table showing an emergency contact list is shown in Table 3.

Table 3 – Emergency Call Down List

Phone Number

Project Coordinator(208) 462-2197 (office)(208) 830-6397 (cell)

Medical Emergency

911

National Response Center (800) 424-8802

Idaho Communication Center 1-800-632-8000

(206) 553-1263

Idaho Department of Environmental (208) 373-0550

Boise National Forest Idaho CityRuth Esperance

(208) 392-6681

iven to Contacts 40 CFR 112.7 (a) (4)

will ensure that the Discharge Notification Form is filled out and thatnotifications have been made to the appropriate authorities. The Project Coordinator

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SPCC Plan

must also ensure that written

If the discharge is contained by facility personnel, the recovered material will be stored in

proper disposal of anyrecovered product, contaminated soil, contaminated materials and equipment,

sorbents, and spent chemicals collected during a response to a

The Idaho DEQ website maintains a list of Environmental Contractors and can be found at;

If Mosquito responds to a discharge without involvement of a cleanup contractor, Mosquito willcontract a licensed transportation/disposal company to dispose of waste according to

characterize the waste and arrange for

is filled out and thatProject Coordinator may ask

http://www.deq.idaho.gov/multimedia_assistance/Clean_Up/contractors.cfm

for assistance in gathering the spill information oappendix) of this Plan:

Reporter’s name

Exact location of the spill

Date and time of spill discharge

Material spilled (e.g., oil, produced water containing a reportable quantity of oil)

Total volume spilled and totaladjoining shorelines

Source of spill

Cause of spill

Actions being taken to stop, remove, and mitigate the effects of the discharge

Whether an evacuation may be needed

Spill impacts (injuries; damage; envi

Names of individuals and/or organizations who have also been contacted

3.9 Procedures to Follow in the Event of a D

The following is a summary of actions that must be taken in thsummarizes the distribution of responsibilities among individuals and describes procedures tofollow in the event of a discharge.

In the event of a discharge, Mosquito or contractor field personnel and theshall be responsible for the following:

1. Shut Off Ignition Sources.motors, electrical circuits, and open flames.

2. Stop Oil/Fuel Flow. Field personnel should determine the source of thesafe to do so, immediately shut off the source of the discharge.

3. Stop the Spread of Oil/Fuel and Call thepersonnel must use resources available at the facility to stop the spilled material frospreading. Measures that may be implemented, depending on the location and size ofthe discharge, include placing sorbent material or other barriers in the path of thedischarge (e.g., sand bags), or constructing earthen berms or trenches.

In the event of a significant discharge, field personnel must immediately contact theCoordinator, who may obtain assistance from authorized company contractors and direct theresponse and cleanup activities. Should a discharge reach Grimes Creek, only physicaland countermeasures should be employed, such as the construction of underflow dams,installation of hard boom and sorbent boom, use of sorbent pads, and use of vacuum trucks torecover oil and oily water from the creek. If water flow is low in thunderflow dam downstream and ahead of the spill flow may be advantageous. Sorbent


SPCC

for assistance in gathering the spill information on the Discharge Notification Form

Exact location of the spill

Date and time of spill discharge


Total volume spilled and total volume reaching or threatening navigable waters or


Whether an evacuation may be needed

Spill impacts (injuries; damage; environmental media, e.g., air, waterway, groundwater)


Procedures to Follow in the Event of a Discharge 40 CFR 112.7 (a) (5)

The following is a summary of actions that must be taken in the event of a discharge. Itsummarizes the distribution of responsibilities among individuals and describes procedures tofollow in the event of a discharge.

In the event of a discharge, Mosquito or contractor field personnel and the Project Coordinatorshall be responsible for the following:

Shut Off Ignition Sources. Field personnel must shut off all ignition sources, includingmotors, electrical circuits, and open flames.

Field personnel should determine the source of thesafe to do so, immediately shut off the source of the discharge.Stop the Spread of Oil/Fuel and Call the Exploration Manager. If safe to do so, fieldpersonnel must use resources available at the facility to stop the spilled material frospreading. Measures that may be implemented, depending on the location and size ofthe discharge, include placing sorbent material or other barriers in the path of thedischarge (e.g., sand bags), or constructing earthen berms or trenches.

of a significant discharge, field personnel must immediately contact the, who may obtain assistance from authorized company contractors and direct the

response and cleanup activities. Should a discharge reach Grimes Creek, only physicaland countermeasures should be employed, such as the construction of underflow dams,installation of hard boom and sorbent boom, use of sorbent pads, and use of vacuum trucks torecover oil and oily water from the creek. If water flow is low in the creek, construction of anunderflow dam downstream and ahead of the spill flow may be advantageous. Sorbent

Page 17


SPCC Plan

Discharge Notification Form (see


volume reaching or threatening navigable waters or


ronmental media, e.g., air, waterway, groundwater)


e event of a discharge. Itsummarizes the distribution of responsibilities among individuals and describes procedures to

Project Coordinator

must shut off all ignition sources, including

Field personnel should determine the source of the discharge, and if

Manager. If safe to do so, fieldpersonnel must use resources available at the facility to stop the spilled material fromspreading. Measures that may be implemented, depending on the location and size ofthe discharge, include placing sorbent material or other barriers in the path of the

of a significant discharge, field personnel must immediately contact the Project, who may obtain assistance from authorized company contractors and direct the

response and cleanup activities. Should a discharge reach Grimes Creek, only physical responseand countermeasures should be employed, such as the construction of underflow dams,installation of hard boom and sorbent boom, use of sorbent pads, and use of vacuum trucks to

e creek, construction of anunderflow dam downstream and ahead of the spill flow may be advantageous. Sorbent

material and/or boom may be placed immediately downstream of the dam to recover anysheen from the water. If water flow is normal in the creek, flwill be deployed. Vacuum trucks will then be utilized to remove oil and oily water at dams andother access points. Crews mayplace them in bags for later disposal. Amay be flushed with water to remove free oil and help it flow down to dams and other accesspoints where it can be recovered by vacuum truck. At no timeor other chemicals be used to remove oil from the creek.

In accordance with IDAPA 58.01.02 Section 852.02 abatement measuresminimum, the following:

1. Remove as much of the petroleum from the leaking system as is necessary to preventfurther release to the environment;

2. Visually inspect any above ground releases or exposed below ground releases andprevent further migration of the released substance into surrounding soils, surfacewater and ground water;

3. Continue to monitor and mitigate any additional fior free product that have migrated from the site and entered into subsurface structuressuch as sewers or basements;

4. Remedy hazards posed by contaminated soils that are excavated or exposed as a resultof release confirmation, site investigation, abatement, or corrective action activities. Ifthese remedies include treatment or disposal of soils, the owner and operator shallcomply with applicable state and local requirements.

3.9.1 Spill Response MaterialsBoom, sorbent, apad site. The response equipment inventory at each site includes a 65 Gal. AIREOil Spill Kit, or similar, which contains:

1 65 US Gallon Over Pack50 17”x19” Sorbent Pads16 3” x 4’ Sorbent Socks1 3” x 10’ Sorbent Sock8 18”x18” Sorbent Pillows100 4”x4” Sorbent Wipes1 Pair Anti-1 Pair Nitrile Gloves5 Disposal Bags1 Emergency Response Book


SPCC

be placed immediately downstream of the dam to recover anysheen from the water. If water flow is normal in the creek, floating booms and sorbent boomwill be deployed. Vacuum trucks will then be utilized to remove oil and oily water at dams and

remove oiled vegetation and debris from the creek banks andplace them in bags for later disposal. After removal of contaminated vegetation, creek banks

be flushed with water to remove free oil and help it flow down to dams and other accesspoints where it can be recovered by vacuum truck. At no time will any surfactants, dispersants,

als be used to remove oil from the creek.

In accordance with IDAPA 58.01.02 Section 852.02 abatement measures may

Remove as much of the petroleum from the leaking system as is necessary to preventthe environment;

Visually inspect any above ground releases or exposed below ground releases andprevent further migration of the released substance into surrounding soils, surfacewater and ground water;Continue to monitor and mitigate any additional fire and safety hazards posed by vaporsor free product that have migrated from the site and entered into subsurface structuressuch as sewers or basements;Remedy hazards posed by contaminated soils that are excavated or exposed as a result

irmation, site investigation, abatement, or corrective action activities. Ifthese remedies include treatment or disposal of soils, the owner and operator shallcomply with applicable state and local requirements.

Spill Response MaterialsBoom, sorbent, and other spill response materials are stored at each active drillpad site. The response equipment inventory at each site includes a 65 Gal. AIREOil Spill Kit, or similar, which contains:

65 US Gallon Over Pack17”x19” Sorbent Pads

Sorbent Socks3” x 10’ Sorbent Sock18”x18” Sorbent Pillows4”x4” Sorbent Wipes

-fog GogglesPair Nitrile Gloves – LargeDisposal Bags – YellowEmergency Response Book

Page 18


SPCC Plan

be placed immediately downstream of the dam to recover anyoating booms and sorbent boom

will be deployed. Vacuum trucks will then be utilized to remove oil and oily water at dams andremove oiled vegetation and debris from the creek banks and

fter removal of contaminated vegetation, creek banksbe flushed with water to remove free oil and help it flow down to dams and other access

any surfactants, dispersants,

may include, at a

Remove as much of the petroleum from the leaking system as is necessary to prevent

Visually inspect any above ground releases or exposed below ground releases andprevent further migration of the released substance into surrounding soils, surface

re and safety hazards posed by vaporsor free product that have migrated from the site and entered into subsurface structures

Remedy hazards posed by contaminated soils that are excavated or exposed as a resultirmation, site investigation, abatement, or corrective action activities. If

these remedies include treatment or disposal of soils, the owner and operator shall

nd other spill response materials are stored at each active drillpad site. The response equipment inventory at each site includes a 65 Gal. AIRE

Additional equipment and material are also kept at the fis checked annually by Kirkness field operations personnel to ensure that usedmaterial is replenished. Supplies and equipment may be ordered from AIREIndustrial Products in Meridian ID (208) 514

3.10 Direction, Rate of Flow and Total Quantity of a Potential Discharge 40 CFR 112.7 (b)

The potential oil spill sources at each drill pad site consist of drill rig storage or hose failure andstorage in 55-gallon drums. Other oil storage tanks are below the 55Mobile refuelers are exempt from secondary containment (40 CFR §

The maximum potential spill sources are described below:

Type of Event:Estimated Total Quantity of Spill:

Direction of Flow:Rate of Flow:

Containment:


Direction of Flow:Rate of Flow:Containment:

Type of Event:Estimated Total Quantity of Spill:Direction of Flow:Rate of Flow:Containment:



SPCC

Additional equipment and material are also kept at the field office. The inventoryis checked annually by Kirkness field operations personnel to ensure that usedmaterial is replenished. Supplies and equipment may be ordered from AIRE

ucts in Meridian ID (208) 514-4040 or a similar business.

ection, Rate of Flow and Total Quantity of a Potential Discharge 40 CFR 112.7 (b)

The potential oil spill sources at each drill pad site consist of drill rig storage or hose failure andgallon drums. Other oil storage tanks are below the 55-gallon SPCCC threshold.

Mobile refuelers are exempt from secondary containment (40 CFR § 112.8 c.2).

The maximum potential spill sources are described below:

Drill rig hose break (i.e., hydraulic fluid or fuel)Spill: The total quantity is dependent upon the length of time

the hose is flowing. Maximum potential spill is 85gallons.Depends on drill pad locationDepends on which hose breaks and how the rig is inoperationThe area beneath the drill rig will be lined with a plasticliner or sorbent materials. Oil spill contingency for thisequipment is listed in Section 3.3.1.

Refueling Overflow (e.g., drill rig, light plant,Total Quantity of Spill: The total quantity is dependent upon the length o

the tank is overflowingDepends on drill pad locationDepends on filling rateOperators performing the refueling will visuallylevel of the tank and stop refueling as tank reachescapacity. The area beneath the tank being refueled willbe lined with sorbent materials.

Drum Rupture (if drums are stored on site)Estimated Total Quantity of Spill: 55-gallons

Depends on drill pad locationDepends on how the tank is ruptured55-gallon tanks containing hydraulic fluid, oil, or anypetroleum products will be secondary contained onsitewithin 95-gallon overpack containers.

Drum OverflowEstimated Total Quantity of Spill: The total quantity is dependent upon the length of time

the drum is overflowing

Page 19


SPCC Plan

ield office. The inventoryis checked annually by Kirkness field operations personnel to ensure that usedmaterial is replenished. Supplies and equipment may be ordered from AIRE

similar business.

ection, Rate of Flow and Total Quantity of a Potential Discharge 40 CFR 112.7 (b)

The potential oil spill sources at each drill pad site consist of drill rig storage or hose failure andgallon SPCCC threshold.

hydraulic fluid or fuel)The total quantity is dependent upon the length of timethe hose is flowing. Maximum potential spill is 85

and how the rig is in

The area beneath the drill rig will be lined with a plasticOil spill contingency for this

rig, light plant, etc.)The total quantity is dependent upon the length of time

Operators performing the refueling will visually verify thelevel of the tank and stop refueling as tank reachescapacity. The area beneath the tank being refueled will

(if drums are stored on site)

gallon tanks containing hydraulic fluid, oil, or anypetroleum products will be secondary contained onsite

The total quantity is dependent upon the length of time




Type of Event:Estimated Total Quantity of Spill:Direction of Flow:Rate of Flow:Containment:

3.11 Prevention Systems: Containment and Diversionary Structures and Equipment Uto Prevent a Discharge from

The following means have been evaluated for the containment or diversion of a potentialdischarge:

1. Dikes, berms, containment areas sufficiently impervious to contain the product.2. Sumps and collection systems.3. Sorbent materials.

The facility makes use of berms andpotential discharge. In additionand divert a potential release. Thecontain a potential release.

3.12 Inspections, Tests, and Records 40

This Plan outlines procedures for inspecting the equipment in accordance with SPCCrequirements. Records of inspections performed as described in this Plan and signed by theappropriate supervisor are a part of this Plan, and are maintained with this PlanValley field office for a minimum of three yearsdescription of the inspection procedure, the date of inspection, whether drainage ofaccumulated rainwater was required, and the inspector’s si


SPCC

Depends on drill pad locationDepends on filling rate55-gallon drums, if filled onsite, will be first placed intothe secondary containment container area prior to filling

Kidney Machine FailureEstimated Total Quantity of Spill: The total quantity is dependent upon the length of time

the kidney machine fails before the machine is stoppedMaximum spill quantity is 85 gallonsDepends on drill pad locationDepends on kidney machine operationSpill would be contained by operators using sorbentmaterials.

Water Source Pump FailureEstimated Total Quantity of Spill: Maximum spill quantity is 25 gallons

Depends on location of pumDepends on pump operationThe pump will be contained within a constructed berm tocontain an accidental release.

Systems: Containment and Diversionary Structures and Equipment Uischarge from Reaching Waterways 40 CFR 112.7 (c)

The following means have been evaluated for the containment or diversion of a potential

Dikes, berms, containment areas sufficiently impervious to contain the product.Sumps and collection systems.

berms and secondary containment drums or bins to contain apotential discharge. In addition each drill pad site is equipped with sorbent materials to containand divert a potential release. The drill pad sites will also retain spills within the sumps to

Inspections, Tests, and Records 40 CFR 112.7 (e)

This Plan outlines procedures for inspecting the equipment in accordance with SPCCrequirements. Records of inspections performed as described in this Plan and signed by theappropriate supervisor are a part of this Plan, and are maintained with this Plan

field office for a minimum of three years, i.e., June 2014, or later. The reports include adescription of the inspection procedure, the date of inspection, whether drainage ofaccumulated rainwater was required, and the inspector’s signature.

Page 20


SPCC Plan

gallon drums, if filled onsite, will be first placed intocontainer area prior to filling

The total quantity is dependent upon the length of timekidney machine fails before the machine is stopped

Spill would be contained by operators using sorbent

The pump will be contained within a constructed berm to

Systems: Containment and Diversionary Structures and Equipment Utilized

The following means have been evaluated for the containment or diversion of a potential

Dikes, berms, containment areas sufficiently impervious to contain the product.

secondary containment drums or bins to contain ais equipped with sorbent materials to contain

pills within the sumps to

This Plan outlines procedures for inspecting the equipment in accordance with SPCCrequirements. Records of inspections performed as described in this Plan and signed by theappropriate supervisor are a part of this Plan, and are maintained with this Plan at the Garden

. The reports include adescription of the inspection procedure, the date of inspection, whether drainage of

The CuMo Exploration inspection program is comprisedmonthly scheduled inspectionswhenever an operation alert, malfunction, shell or deck leak, or potenreported following a scheduled examination. Written examination/inspection procedures andmonthly examination/inspection reports are signed by the field inspector and are maintained atthe field office for a period of at least three yea

3.12.1 Daily ExaminationsThe facility will beexamination consists of aField operations personnel check theleaks and proper operation. Personnel inspect pumps to verify proper functionand check for damage and leakage. They look for accumulation of wateroil within bermskept.

3.12.1 Monthly InspectionsThe monthly inspection is aimed at identifying signs of deterioration andmaintenance needs, including the foundation and support of each container. Anyleak from tank seams, gaskets, rivets, and bolts is promptly corrected.

The monthly inspection covers theare inspected for signs of deterioration, leaks, or accumulation of oil inside thecontainment area, or other signs that maintenance or repairs are needed. Thesecondary containmevidence of oil, or signs of leakage. The monthly inspection also involves visuallyinspecting all aboveground valves and pipelines and noting the general conditionof items such as transfer hosebodies, catch pans, pipeline supports, pumping well pumping rod stuffing boxes,bleeder and gauge valves, locking of valves, and metal surfaces.containment areas

Table 4 lists the scope of monthly inspections and aAppendix C.


SPCC

inspection program is comprised of informal daily examinations andmonthly scheduled inspections. Additional inspections and/or examinations are performedwhenever an operation alert, malfunction, shell or deck leak, or potential bottom leak isreported following a scheduled examination. Written examination/inspection procedures andmonthly examination/inspection reports are signed by the field inspector and are maintained atthe field office for a period of at least three years.

Daily Examinationswill be visited daily by field operations personnel. The daily visual

examination consists of a walkthrough of the drill pad sites and pump locationsField operations personnel check the berms, tanks, drums, andleaks and proper operation. Personnel inspect pumps to verify proper functionand check for damage and leakage. They look for accumulation of water

within berms and secondary containments. Daily records do not need to be

Monthly InspectionsThe monthly inspection is aimed at identifying signs of deterioration andmaintenance needs, including the foundation and support of each container. Anyleak from tank seams, gaskets, rivets, and bolts is promptly corrected.

The monthly inspection covers the drill pads and all equipment.are inspected for signs of deterioration, leaks, or accumulation of oil inside thecontainment area, or other signs that maintenance or repairs are needed. Thesecondary containment area is checked for proper drainage, general conditions,evidence of oil, or signs of leakage. The monthly inspection also involves visuallyinspecting all aboveground valves and pipelines and noting the general conditionof items such as transfer hoses, flange joints, expansion joints, valve glands andbodies, catch pans, pipeline supports, pumping well pumping rod stuffing boxes,bleeder and gauge valves, locking of valves, and metal surfaces.containment areas are also inspected for cracks

lists the scope of monthly inspections and a checklist provided in

Page 21


SPCC Plan

of informal daily examinations and. Additional inspections and/or examinations are performed

tial bottom leak isreported following a scheduled examination. Written examination/inspection procedures andmonthly examination/inspection reports are signed by the field inspector and are maintained at

visited daily by field operations personnel. The daily visualand pump locations.

tanks, drums, and equipment forleaks and proper operation. Personnel inspect pumps to verify proper functionand check for damage and leakage. They look for accumulation of water, fuel, or

Daily records do not need to be

The monthly inspection is aimed at identifying signs of deterioration andmaintenance needs, including the foundation and support of each container. Anyleak from tank seams, gaskets, rivets, and bolts is promptly corrected.

equipment. Storage tanksare inspected for signs of deterioration, leaks, or accumulation of oil inside thecontainment area, or other signs that maintenance or repairs are needed. The

ent area is checked for proper drainage, general conditions,evidence of oil, or signs of leakage. The monthly inspection also involves visuallyinspecting all aboveground valves and pipelines and noting the general condition

s, flange joints, expansion joints, valve glands andbodies, catch pans, pipeline supports, pumping well pumping rod stuffing boxes,bleeder and gauge valves, locking of valves, and metal surfaces. Secondary

checklist provided in

Table

Inspection AreaStorage tanks

General Area

Production equipment

Pumps

3.13 Personnel, Training, for Discharge Prevention Procedures 40

The person designated to be accountable for discharge prevention and who reports tomanagement is the Project Coordinator.incorporated. The Project Coordinatorensure adequate understanding and effective implementation of this SPCC plan.describe spill events or failures,precautionary measures.

Personnel are instructed in operation and maintenance of equipment to prevent the dischargeof oil, and in applicable federal, state, and local pollution laws, rules, and regulationand other personnel have an opportunity during the briefings to share recommendationsconcerning health, safety, and environmental issues encountered during operations.

3.14 Security 40 CFR 112.7 (g)

Access to the drill pads will be limited to Moonly. Access to the sites will be restricted to the public with the installation of security gateslocated at the beginning of construction of temporary roads off of existing USFS roads.fencing will be installed around the site.


SPCC

Table 4 – Scope of Monthly Inspections

Inspection ItemLeakage, gaskets, hatchesTank liquid level checkedOverflow linesPiping, valves, and bull plugsCorrosion, paint conditionPressure / level safety devicesGeneral housekeepingBerm and curbingPresence of contaminated/stained soilEquipment protectors and signsEngine drip pans and sumpsGeneral housekeeping

Production equipment Gauges (pressure, temperature, and liquid level)Pressure / level safety devicesEmergency shut-down system(s)Pressure relief valvesLeakage, gaskets, hatchesPiping and valvesContainment bermsPresence of contaminated/stained soil

Personnel, Training, for Discharge Prevention Procedures 40 CFR 112.7 (f)

The person designated to be accountable for discharge prevention and who reports tomanagement is the Project Coordinator. With this plan a SPCC briefing program will be

Project Coordinator will conduct an annual discharge preventionensure adequate understanding and effective implementation of this SPCC plan.describe spill events or failures, malfunctioning components, and recently developed

Personnel are instructed in operation and maintenance of equipment to prevent the dischargeof oil, and in applicable federal, state, and local pollution laws, rules, and regulationand other personnel have an opportunity during the briefings to share recommendationsconcerning health, safety, and environmental issues encountered during operations.

112.7 (g)

Access to the drill pads will be limited to Mosquito-authorized personnel and USFS authoritiesonly. Access to the sites will be restricted to the public with the installation of security gateslocated at the beginning of construction of temporary roads off of existing USFS roads.

installed around the site.

Page 22


SPCC Plan

112.7 (f)

The person designated to be accountable for discharge prevention and who reports tobriefing program will be

discharge prevention briefing toensure adequate understanding and effective implementation of this SPCC plan. These briefings

malfunctioning components, and recently developed

Personnel are instructed in operation and maintenance of equipment to prevent the dischargeof oil, and in applicable federal, state, and local pollution laws, rules, and regulations. Operatorsand other personnel have an opportunity during the briefings to share recommendationsconcerning health, safety, and environmental issues encountered during operations.

personnel and USFS authoritiesonly. Access to the sites will be restricted to the public with the installation of security gateslocated at the beginning of construction of temporary roads off of existing USFS roads. No

Security lighting is not appropriate for this installation since the site is very remote and the riskof vandalism is low. In addition, Mosquito anticipates a 24drill pads are never anticipated to beseason (April 15 –December 15).

3.15 Tank Truck Loading Unloading Area Containment 40

The drill pad sites will not have a loading rack and thus a secondary containment for a tanktruck unloading area is not required.

3.16 Field Constructed ASTs 40

The ASTs at the drill pad sites will


SPCC

Security lighting is not appropriate for this installation since the site is very remote and the riskof vandalism is low. In addition, Mosquito anticipates a 24-hour drilling operation

ed to be unstaffed by Mosquito personnel during the operating.

Tank Truck Loading Unloading Area Containment 40 CFR 112.7 (h)

not have a loading rack and thus a secondary containment for a tanktruck unloading area is not required.

40 CFR 112.7 (i)

will not be field constructed.

Page 23


SPCC Plan

Security lighting is not appropriate for this installation since the site is very remote and the riskhour drilling operation; therefore

during the operating

not have a loading rack and thus a secondary containment for a tank

4.0 SUBPART B – REQUIREMENTS FOR ONS

Mosquito shall operate in compliance with the requirements of Section 112.7, as outlined inthis SPCC Plan, and the specific discharge prevention and containment procedures listed inSection112.8 as set forth below.

4.1 Facility Drainage 40 CFR 112.8 (b) (1) and (2) Diked Areas

There are no diked areas at the drill pad sites.

4.2 Facility Drainage 40 CFR 112.8 (b) (3) and (4) Undiked Areas

As shown in Figure 3, surface drainagethe edge of the drill pads. The sumps will contain an accidental release from leaving the site.

4.3 Bulk Storage Containers 40 CFR 112.8 (c) (1)

Bulk storage containers will not used at this facility.

4.4 Capacity of Secondary Containment Area 40 CFR

Any secondary containment area must have the capacity to contain one and a half times thevolume of the largest tank or drum. This is addressed within th

4.5 Method to Address Precipitation within the Second(3)

This is addressed within this Plan at 40 CFR 112.7 (a)(3)(iii).

4.6 Cathodically Protected Metal Underground Storage Tanks 40 CFR 112.8 (c) (4) and (5)

There will be no underground storage takes at this facility.

4.7 Periodically Test the Integrity of Aboveground Tanks 40 CFR 112.8 (c) (6)

This is addressed within this Plan at 40 CFR 112.7 (e).

4.8 Leakage From Heating Coils 40 CFR 112.8 (c) (7)

Heating coils will not be used at this facility.


SPCC

REQUIREMENTS FOR ONSHORE PETROLEUM AND NON-PETROLEUM OILS

Mosquito shall operate in compliance with the requirements of Section 112.7, as outlined inthis SPCC Plan, and the specific discharge prevention and containment procedures listed inSection112.8 as set forth below.

ity Drainage 40 CFR 112.8 (b) (1) and (2) Diked Areas

There are no diked areas at the drill pad sites.

Facility Drainage 40 CFR 112.8 (b) (3) and (4) Undiked Areas

rainage at drill pad sites will be directed towards thethe edge of the drill pads. The sumps will contain an accidental release from leaving the site.

Bulk Storage Containers 40 CFR 112.8 (c) (1)

not used at this facility.

Capacity of Secondary Containment Area 40 CFR 112.8 (c) (2)

secondary containment area must have the capacity to contain one and a half times thevolume of the largest tank or drum. This is addressed within this Plan at 40 CFR 112.7 (a)(3)(iii).

Method to Address Precipitation within the Secondary Containment 40 CFR 112.8 (c)

Plan at 40 CFR 112.7 (a)(3)(iii).

Cathodically Protected Metal Underground Storage Tanks 40 CFR 112.8 (c) (4) and (5)

no underground storage takes at this facility.

Periodically Test the Integrity of Aboveground Tanks 40 CFR 112.8 (c) (6)

This is addressed within this Plan at 40 CFR 112.7 (e).

Leakage From Heating Coils 40 CFR 112.8 (c) (7)

used at this facility.

Page 24


SPCC Plan

PETROLEUM OILS

Mosquito shall operate in compliance with the requirements of Section 112.7, as outlined inthis SPCC Plan, and the specific discharge prevention and containment procedures listed in

at drill pad sites will be directed towards the sumps atthe edge of the drill pads. The sumps will contain an accidental release from leaving the site.

secondary containment area must have the capacity to contain one and a half times thePlan at 40 CFR 112.7 (a)(3)(iii).

ary Containment 40 CFR 112.8 (c)

Cathodically Protected Metal Underground Storage Tanks 40 CFR 112.8 (c) (4) and (5)

Periodically Test the Integrity of Aboveground Tanks 40 CFR 112.8 (c) (6)

4.9 Engineer or Update Containers to Avoid Discharge 40 CFR 112.8 (c) (8)

Liquid level sensing devices are not practical for this facility due to the type of equipment andnature of operations. During refueling, operators will readily monitor refueling and followingrefueling procedures per Section 3.3.3.

4.10 Observe Effluent Treatment 40 CFR 112.8 (c) (9)

Mosquito will not use an effluent treatment system.

4.11 Promptly Address Visible Discharge 40 CFR 112.8 (c) (10)

This is addressed within this Plan at

4.12 Mobile or Portable Storage Containers 40 CFR 112.8 (c) (11)

Mobile or portable storage containers will be located on the drill pad sites so that accidentalrelease will be contained. See Figure 3 of the Plan.

4.13 Facility Transfer Operations 40 CFR 112.8 (d)(1),(2),(3),(4) and (5)

These items are addressed within this Plan at 40 CFR 112.7 (a)


SPCC

Containers to Avoid Discharge 40 CFR 112.8 (c) (8)

Liquid level sensing devices are not practical for this facility due to the type of equipment andnature of operations. During refueling, operators will readily monitor refueling and following

procedures per Section 3.3.3.

Observe Effluent Treatment 40 CFR 112.8 (c) (9)

use an effluent treatment system.

Promptly Address Visible Discharge 40 CFR 112.8 (c) (10)

This is addressed within this Plan at 40 CFR 112.7 (a) (5) and 40 CFR 112.7 (e).

Mobile or Portable Storage Containers 40 CFR 112.8 (c) (11)

Mobile or portable storage containers will be located on the drill pad sites so that accidentalrelease will be contained. See Figure 3 of the Plan.

Operations 40 CFR 112.8 (d)(1),(2),(3),(4) and (5)

These items are addressed within this Plan at 40 CFR 112.7 (a)(3)(ii).

Page 25


SPCC Plan

Liquid level sensing devices are not practical for this facility due to the type of equipment andnature of operations. During refueling, operators will readily monitor refueling and following

Mobile or portable storage containers will be located on the drill pad sites so that accidental


SPCC

Appendix A

Drill Pad Location Figures

Appendix


SPCC Plan

Appendix A

Location Figures


SPCC

Appendix B

Spill History

Appendix


SPCC Plan

Appendix B

Spill History


SPCC

Appendix C

Monthly Inspection Forms

Appendix


SPCC Plan

Appendix C

Monthly Inspection Forms

Monthly Inspection ChecklistFurther description and comments, if needed, should be provided on a separate sheet of paper andattached to this sheet. Any item answered “Yes” needs to be promptly reported, repaired,as it may result in non-compliance with regulatory requirements. Records are maintained with the SPCCPlan at the Garden Valley field office.

Date_____________________________Signature:___________________________________________

Storage tanks

Tank surfaces show signs of leakage

Tanks show signs of damage, rust, or deterioration

Bolts, rivets or seams are damaged

Aboveground tank supports are deteriorated orbuckled

Gaskets are leaking

Vents are obstructed

Thief hatch and vent valve does not seal air tight

Containment berm shows discoloration or stains

Berm is breached or eroded or has vegetation

Berm drainage valves are open/broken

Tank area clear of trash and vegetation

Equipment protectors, labels, or signs are missing

Piping/Flowlines and Related Equipment

Valve seals or gaskets are leaking.

Pipelines or supports are damaged or deteriorated


Buried pipelines are exposed

Transfer equipment

Loading/unloading lines are damaged ordeteriorated

Connections are not capped or blank

Secondary containment is damaged or stained

Response Kit Inventory

Discharge response material is missingor needs replacement


SPCC

Monthly Inspection Checklistdescription and comments, if needed, should be provided on a separate sheet of paper and

attached to this sheet. Any item answered “Yes” needs to be promptly reported, repaired,compliance with regulatory requirements. Records are maintained with the SPCC

Plan at the Garden Valley field office.

Date_____________________________Signature:___________________________________________

Yes No N/ADescription & Comments(Note tank/equipment ID)

Tank surfaces show signs of leakage

Tanks show signs of damage, rust, or deterioration

Aboveground tank supports are deteriorated or

Thief hatch and vent valve does not seal air tight

Containment berm shows discoloration or stains


Berm drainage valves are open/broken

Tank area clear of trash and vegetation

Equipment protectors, labels, or signs are missing

Piping/Flowlines and Related Equipment

Pipelines or supports are damaged or deteriorated

or eroded or has vegetation

Loading/unloading lines are damaged or

Connections are not capped or blank-flanged

Secondary containment is damaged or stained

Discharge response material is missing or damaged

Make copies of this form as needed

Appendix


SPCC Plan

Monthly Inspection Checklistdescription and comments, if needed, should be provided on a separate sheet of paper and

attached to this sheet. Any item answered “Yes” needs to be promptly reported, repaired, or replaced,compliance with regulatory requirements. Records are maintained with the SPCC

Date_____________________________Signature:___________________________________________

Description & Comments(Note tank/equipment ID)


Discharge Notification


SPCC

Appendix

Discharge Notification

Appendix


SPCC Plan

Appendix D

Discharge Notification Forms

Discharge Notification FormDischarge Information

General information when reporting aName:

Address:

Telephone:Owner/Operator:

Primary Contact:Work:Cell (24 hrs):

Type of oil:

Quantity released:

Quantity released to a waterbody:

Location/Source:

Actions taken to stop, remove, and mitigate impacts of the discharge:

Affected media□ air□ water□ soil

Notification person:

Nature of discharge, environmental/health effects, and damages:

Injuries, fatalities or evacuation required?


SPCC

Discharge Notification Form

General information when reporting a spill to outside authorities

Discharge Date and Time:

Discovery Date and Time:

Quantity released to a waterbody: Discharge Duration:

Actions taken to stop, remove, and mitigate impacts of the discharge:

□ storm water sewer/POTW□ dike/berm/oil-water separator□ other:

Telephone contact:Business:24-hr:

Nature of discharge, environmental/health effects, and damages:

Injuries, fatalities or evacuation required?


Appendix


SPCC Plan



SPCC

Appendix

Annual Training

Appendix


SPCC Plan

Appendix E

Annual Training Logs

Documents

CuMo Exploration Project · CuMo Exploration Project SPCC. 24-hour contact information is provided in Table 1. CuMo Exploration Project Mining Exploration 2011 Boise National Forest