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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Rewurces <br />1313 Sherman 5[., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />INTEROFFICE <br />MEMORANDUM <br />TO: Dan Hernandez <br />FROM: Jim St <br />SUBJECT: West Elk Mine Minnesota Creek Spill Incident <br />DATE: 9 December 2005 <br />COLORADO <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />0.ECLANATION•NINING <br />SAFETY•EI:IENCE <br />Bill Owens <br />Governor <br />Russell Geolge <br />Eaeclrtive Director <br />Ronald W. Cattany <br />Division Director <br />Nazuml Resource Trustee <br />Based on your request, I reviewed the information associated with a spill of a firefighting <br />agent into the Minnesota Creek near the West Elk Mine. The documents I reviewed <br />included the "Incident Report" from West Elk Mine, the Material Saftey Data Sheet <br />(MSDS) for the agent (SILV-EX Foam Concentrate (explained below), the 6 December <br />2005 Draft Technical Memo from HydroGeo, Inc. to Henry Barbe of Mountain Coal and <br />various technical publications including a study conducted by the USGS on SILV-EX <br />use. <br />The events of the spill incident are well documented in the Mountain Coal "Incident <br />Report" as well as the HydroGeo Draft Technical Memo so I will not go into those at this <br />point. The spill occurred on or around the morning of 12 November 2005. The impacted <br />area was sampled on 2 December 2005 and the samples were analyzed on 4 and 5 <br />December 2005. <br />A review of the MSDS Section 2, Part A, Hazazdous Ingredients, shows that there are <br />two substances in the SILV-EX that are considered "Hazardous Ingredients". The first is <br />diethylene glycol monobutyl ether (trade name Butyl Carbitol -Union Cazbide). The <br />second is ethyl alcohol (ethanol), which is common drinking alcohol so no additional <br />discussion of ethanol is warranted. It is stated on the MSDS that for Butyl Carbitol that <br />the oral LDso for rats is 6,560 mg/kg (an LDSO is the concentration at which half of the <br />test subjects died, in the case of an oral LDso, or showed the "desired effect" for other <br />forms of the LDso). The dermal (skin contact) LDSO for rabbits is 4,120 mg/kg. The LCso <br />(lethal concentration -used for solutions) for fathead minnows is >500 mg/1. <br />Based on the MCC "Incident Report", less than one gallon was spilled. For ease of <br />discussion, I have used 1 gallon in all of my discussions and calculations. 1 gallon <br />roughly translates into 4 liters of SILV-EX spilled (the specific gravity is 1.01). The <br />amount of Butyl Cazbitol contained in SILV-EX is 18% by weight (and essentially by <br />Office of Office of Colorado <br />Mined Land RE~clamation Active and Inactive Mines Geological Survey <br />