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energy ftiels coal, inc. <br />sMOdNid MMM . post office box 459 • ft www, a *wado 87226 • (719) 784-6395 <br />January 14, 2016 <br />Mr. Rob Zuber, P.E., Environmental Reclamation Specialist <br />Division of Reclamation, Mining, and Safety <br />1313 Sherman ST, Room. 215 <br />Denver, CO 80203 <br />Re: Oil Removal Procedure - Southfield Truck Manuel <br />Southfield Mine (Permit No. C-1981-014) <br />Dear Mr. Zuber: <br />The following information was taken from field notes documented by George Patterson during the <br />process of removing all remaining hydraulic oil, and potential sources of oil, from the truck tunnel. <br />George Patterson of Energy Fuels Coal, Inc. (EFQ observed (5-13-15) what was thought to be <br />hydraulic oil in the water flowing at the NE end of the truck tunnel On further inspection the next day <br />(5-14-15), it was determined that the milky colored substance in the water was from an extensive <br />accumulation ofpigeon excrement that was carried out in the rising water level in the tunnel and <br />carried out in some of the stormwater flow There had been several days of continuous heavy rainfall. <br />George Patterson called the Javernic Oil Co crew who arrived at the site at 2: 00 pm, 5-13-15, and <br />immediately placed oil absorbent pads at the mouth of the truck tunnel and in the drainage ditch <br />leading to Pond 5 as a safety precaution. No oil sheen was observed on the water neither in the <br />drainage ditch, nor at the Pond 5 inlet or on the pond surface. As a further precaution, a small earthen <br />berm was placed at the mouth of the truck tunnel to stop further water discharge from the tunnel until <br />further inspections could be conducted The Javernic crew determined that hydraulic oil had dripped <br />down the west wall of the tunnel from a hydraulic accumulator cylinder that had previously been used <br />to control the hydraulic gates under the former coal stockpile above the tunnel. The cylinder being <br />approximately 8 inches diameter by 30 inches long had a capacityfor hydraulic oil of 4 or 5 gallons. <br />No steel pipe lines for the hydraulic oil on the west wall of the tunnel were 1 inch diameter by about <br />100 feet long with a capacity of about 8 gallons. The crew determined that oil had dripped from the <br />pipe line. <br />The vacuum trucks pumped the water out of the tunnel and the Javernic crew (5-14-15) removed the <br />hydraulic accumulator from the tunnel and drained the hydraulic pipe lines on the wall of the tunnel. <br />The pipe lines were drained by lowering one end of the lines and draining the remaining hydraulic oil <br />into two 5 gallon buckets. A total of approximately 10 gallons of hydraulic oil was drained from the <br />pipe lines. Oil absorbent pads were placed at the site of the draining process, the pipes were recapped <br />and replaced back onto the tunnel wall. (Note: The referenced hydraulic accumulator cylinder and the <br />5 gallon buckets of oil were removed for disposal by Javernick Oil Co. The oil absorbent pads in the <br />tunnel were later removed for disposal by Kessler Reclamation Co.) <br />