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Rob Zuber <br />December 31, 2015 <br />Page 5 <br />11. The owner of the land surrounding the truck tunnel (Dr. Corley) has raised some issues with <br />this structure: <br />• There are open holes in the concrete. <br />• Part of the roof has been removed and covered with a large piece of metal. <br />• Pipes and any other equipment in the tunnel may contain oil. <br />• The side tunnel is a hazard, and the landowner never wanted it to remain in place. <br />The first two issues were confirmed by DRMS during the inspection. These issues are the subject <br />of a discussion between EFCI and the Division. <br />RESPONSE: <br />The few open holes, minimal in size, do not impair the structural stability of the truck tunnel. These <br />holes existed for some period of time during active mining operations. The side tunnel is not a hazard, <br />it has proven its stability for 14 years and is (and always was) part of the truck tunnel structure. <br />EFCI addressed potential sources of oil in the truck tunnel while investigating what was believed to be <br />an oil spill, based on the existence of a milky colored substance under accumulated storm water, found <br />in May 2015. A contractor was immediately contacted and proceeded to remove the excess water <br />pooled in the tunnel. In addition, oil absorbent pads were placed in the tunnel and in the drainage ditch <br />downstream of the tunnel. This contractor is a licensed oil and gas driller, and is experienced in oil spill <br />mitigation. <br />Following the water removal, the entire tunnel structure was inspected for sources of oil. The <br />inspection determined that there were steel pipes (approximately 1 inch diameter) and a small oil <br />accumulator unit in the tunnel that could contain oil (hydraulic oil only). No oil was observed leaking <br />from these sources. The accumulator was removed from the site. To assure thorough drainage of the <br />pipelines, the north end of the pipes were lowered and approximately 10 gallons of hydraulic oil was <br />caught in covered containers and removed from the site by the contractor. The steel pipes were then <br />raised and reattached in their original position. <br />The contractor commented that the milky colored substance that EFCI initially believed to be old <br />oxidized hydraulic oil found laying on the bottom of the water pool in the tunnel — not floating, <br />therefore was not oil. The milky colored substance was later determined to be bird feces carried out in <br />the storm water. Laboratory analysis of water pumped from the tunnel confirmed that there was no oil <br />contamination. <br />12. Topsoil stockpiles warrant further discussion between EFCI and DRMS; a revision may be <br />needed to keep them as permanent features. <br />RESPONSE: <br />Please provide EFCI with proposed details for the content of a revision, if necessary, to address the <br />topsoil stockpiles. <br />