wasatch environmental, inc. environmental science …

WASATCH ENVIRONMENTAL, INC.

ENVIRONMENTAL SCIENCE AND ENGINEERING

2410 WEST CALIFORNIA AVENUE SALT LAKE CITY, UTAH 84104

PHONE (801) 972-8400 FAX (801) 972-8459

e-mail: [email protected] www.wasatch-environmental.com

CHIEF CONSOLIDATED MINE SITES - TINTIC OPERATIONS STATUS REPORT

PERMIT NO.: M/049/0062 UTAH COUNTY

APPROXIMATELY 3 MILES SOUTHEAST OF EUREKA, UTAH

Project No. 2224-001

Prepared for:

Division of Oil, Gas, and Mining Ms. Dana Dean, Associate Director

1594 West North Temple, Suite 1210 P.O. Box 145801

Salt Lake City, Utah 84114-5801

AND

Mr. Timothy Buchanan Chief Consolidated Mining Company

7703 Ralston Road Arvada, Colorado 80002

April 17, 2017

Prepared by:

Wasatch Environmental, Inc. 2410 West California Avenue

Salt Lake City, Utah 84104

emilyberry

New Stamp

Chief Consolidated Mine Sites – Tintic Operations Status Report Chief Consolidated Mine Sites

Wasatch Environmental, Inc. Table of Contents Page i

TABLE OF CONTENTS Section Page No.

1.0 INTRODUCTION ..................................................................................................................................... 1

2.0 BACKGROUND ...................................................................................................................................... 1

3.0 OBJECTIVES .......................................................................................................................................... 1

4.0 METHODS .............................................................................................................................................. 1 4.1 Hazardous Material and Petroleum Product Inventory .............................................................. 1 4.2 Preliminary Structural Integrity Survey and Pre-Demolition Asbestos Sampling....................... 2 4.3 Trixie Borehole Mine Gas Sampling .......................................................................................... 2 4.4 Unlabeled Transformer Sampling .............................................................................................. 2 4.5 Soil Sampling ............................................................................................................................. 2

5.0 RESULTS ................................................................................................................................................ 2 5.1 Hazardous Material and Petroleum Product Inventory Results ................................................. 2

5.1.1 Burgin 1 ...................................................................................................................... 3 5.1.2 Burgin 2 ...................................................................................................................... 3 5.1.3 Apex 2 ........................................................................................................................ 3 5.1.4 Trixie .......................................................................................................................... 4

5.2 Preliminary Structural Integrity Survey and Pre-Demolition Asbestos Results.......................... 4 5.2.1 Burgin 1 ...................................................................................................................... 4 5.2.2 Burgin 2 ...................................................................................................................... 4 5.2.3 Apex 2 ........................................................................................................................ 4 5.2.4 Trixie .......................................................................................................................... 4 5.2.5 Trixie Borehole ........................................................................................................... 5

5.3 Trixie Borehole Mine Gas Results ............................................................................................. 5 5.4 Unlabeled Transformer Results ................................................................................................. 5

5.4.1 Burgin 1 ...................................................................................................................... 5 5.4.2 Apex 2 ........................................................................................................................ 5

5.5 Soil Analytical Results ................................................................................................................ 5 5.5.1 Burgin 1 ...................................................................................................................... 5 5.5.2 Burgin 2 ...................................................................................................................... 5 5.5.3 Trixie .......................................................................................................................... 6

6.0 CONCLUSIONS AND RECCOMMENDATIONS .................................................................................... 6 TABLES

Table 1 – Hazardous Material and Petroleum Product Inventory Table 2 – Oil/Soil Analytical Data – PCBs FIGURES Figure 1 – Vicinity and Mine Site Location Map Figure 2 – Burgin 1 Mine Site Materials and Building Location Map Figure 3 – Burgin 2 Mine Site Materials and Building Location Map Figure 4 – Apex Mine Site PCB Sample and Building Location Map Figure 5 – Trixie Mine Site PCB Sample and Building Location Map Figure 6 – Trixie Borehole Mine Site Materials and Building Location Map Figure 7 – Burgin 1 Mine Site PCB Sample Location Map Figure 8 – Burgin 1 Mine Site PCB Sample Location Map


Wasatch Environmental, Inc. Table of Contents Page ii

APPENDICES

Appendix A – Asbestos Reports Appendix B – Oil/Soil Laboratory Analytical Report


Wasatch Environmental, Inc. 1

Chief Consolidated Mine Sites - Tintic Operations Status Report

Permit No.: M/049/0062 Utah County

Approximately 3 miles southeast of Eureka, Utah

1.0 INTRODUCTION Wasatch Environmental, Inc., (Wasatch) is pleased to present our findings regarding our initial site visit, sampling activities, and hazardous material and petroleum product inventory conducted at the Chief Consolidated Mining Company (Chief) Tintic Operations (permit number M/049/0062) consisting of the following mine sites: Burgin 1, Burgin 2 Disturbance (Burgin 2), Apex 2, Trixie, and Trixie Borehole. All the mine sites are now referred to as the Chief facility. See Figure 1 for a map of the general location of the site. These mines are located approximately three miles southeast of Eureka, Utah. The scope of work included a hazardous material and petroleum product inventory at each mine, visual survey for apparent structural integrity of all buildings at the mines, pre-demolition asbestos sampling of buildings appearing to be structurally unsound, sampling of mine gas escaping from the Trixie Borehole mine, sampling unlabeled polychlorinated biphenyl (PCB)-containing transformers, and sampling of stained soil for PCBs near any transformer that appeared to have had a release. 2.0 BACKGROUND Chief contacted Wasatch to provide environmental services at the site regarding specific concerns documented in a “Stipulation and Agreement,” (SA) issued by the Utah Division of Oil, Gas, and Mining (DOGM) dated February 21, 2017. A timeline to complete several of the environmental issues were documented in the SA. In addition, DOGM and Chief reported to Wasatch that a noxious gas was escaping from the Trixie Borehole. DOGM requested a sample of the escaping mine gas be collected, and Chief requested that Wasatch collect the mine gas sample at the time of our site visit. 3.0 OBJECTIVES The purpose of Wasatch’s activities was to inventory the type and volume of hazardous materials and petroleum products present at the site to facilitate proper off-site disposal, collect asbestos samples from structurally unsound structures at the site to facilitate demolition, collect a mine gas sample from the reported noxious gas escaping the Trixie Borehole, sample unlabeled suspected PCB-containing transformers, and sample the near surface soils at suspected PCB releases. 4.0 METHODS 4.1 Hazardous Material and Petroleum Product Inventory The interiors of each building located at each mine site were carefully inspected and all containers and drums were noted with content (based on visible labels), estimated volume, and the location mapped within the building. Additionally, the entire disturbed area of each mine site was also inspected and all containers, drums, and aboveground storage tanks (ASTs) were noted as discussed; however, several containers located outside were surveyed with a global positioning system (GPS). Several containers with unknown contents were observed throughout the site and were noted and mapped as such. See Table 1 for a list of hazardous materials and petroleum products identified for each mine site. See Figures 2 through 6 for maps of hazardous materials, petroleum products, and building locations.



4.2 Preliminary Structural Integrity Survey and Pre-Demolition Asbestos Sampling At each mine site a visual inspection of the interior/exterior walls, roofing material, and support load beams (where possible) were completed for each building. Any obvious structural defects (disconnected, bent, or broken support beams) were noted. Where a building was obviously structurally unsound, and would warrant demolition, asbestos samples were collected by a certified asbestos pre-demolition inspector. See the Asbestos Survey Reports in Appendix A for methodology regarding the asbestos sampling. 4.3 Trixie Borehole Mine Gas Sampling On March 31, 2017, Wasatch collected one grab sample (AS-1) of the noxious mine gas escaping the Trixie Borehole mine. Initially, a long piece of plastic tubing was lowered into the opening of the shaft, and a four-gas meter was used to screen for hydrogen sulfide and purge the tubing of ambient air. Once the tubing was purged, it was connected to a laboratory-supplied, 6-liter, lined Summa canister. The canister valve was then opened and the mine gas sample was collected. Once a sufficient volume of mine gas had been collected the canister valve was shut off and a brass dust cap was placed on the inlet of the canister. The sample was delivered under chain-of-custody protocol to ALS Environmental (ALS), for analysis of sulfur gases using a gas chromatograph sulfur gases scan. 4.4 Unlabeled Transformer Sampling On March 31, 2017, all transformers located at each of the mine sites were inspected to identify the PCB contents of each transformer. Two transformers observed at the site were not labeled with their respective PCB contents and were identified as possible PCB containing transformers: one at the Burgin 1 substation and one at the Apex substation. At both locations, a sample of the transformer oil was collected from the sample ports located on each of the transformers. The oil samples were dispensed into two unpreserved 40-milliliter glass VOAs and immediately placed on ice. The samples were delivered under chain-of-custody protocol to American Western Analytical Laboratories (AWAL), a Utah-Certified analytical laboratory, for analysis of PCBs using U.S. Environmental Protection Agency (EPA) Method 8082A. See Figures 4 and 7 for PCB oil sample locations. 4.5 Soil Sampling Where soil staining was observed exceeding apparent de minimis conditions (based on our professional opinions) near transformers located at the site, near surface soil samples were collected to characterize the release. Thirteen PCB soil samples were collected throughout the site by Project Environmental Scientist Audra Heinzel and Project Hydrogeologist Blake Downey, P.G., on March 31, 2017. Six soil samples were collected at the Trixie mine (Trixie-TF-1 through Trixie-TF-5, and Trixie-Black-1), two soil samples were collected at the Burgin 1 mine (Burgin-TF-1 and Burgin-TF-2), and five soil samples were collected at the Burgin 2 mine (Burgin2-TF-1 through Burgin2-TF-5). See Figures 5, 7, and 8 for PCB soil sample locations.

Soil Samples collected for analysis of PCBs were collected into 2-ounce glass jars with gloved hands. Soil samples were immediately placed on ice in a sample cooler and delivered under chain-of-custody protocol to AWAL, for analysis of PCBs using U.S. EPA Method 8082A. 5.0 RESULTS 5.1 Hazardous Material and Petroleum Product Inventory Results Numerous containers, drums, and ASTs were observed throughout the Chief facility. Various oils, solvents, cleaners, paints, thinners, epoxies, automotive fluids grease, batteries, peroxides, acids, and some mercury containing bulbs were observed throughout the mine sites. All containers and drums located within structures where staining was observed, did not appear to impact soils beneath the



structures due to competent concrete flooring present within the structures. However, the cable engines located at the Burgin 1 mine site appeared to have oil and water located within the concrete trenches of the engine. Wasatch was unable to see the bottom of these trenches to determine if the concrete was in good condition. See Table 1 for a list of all hazardous materials and petroleum products identified and their locations throughout the site. Only hazardous materials and petroleum products located outside of site buildings are depicted on the applicable figures. Refer to the labeled buildings on the figures to locate chemicals identified within the building. Hazardous materials and petroleum products observed outside of buildings are further discussed below.

5.1.1 Burgin 1 All containers, drums, or ASTs located outside of the structures at the Burgin 1 mine appeared to

be in good condition and no staining was observed near the containers, drums, or ASTs. Two 500-gallon empty ASTs located just south of the guard shack building were located within a plastic membrane being used for secondary containment. The AST secondary containments were full of water at the time of our site visit. One 250-gallon AST (filled with a white liquid) was observed south of the Concentrator Building, and one 1,000-gallon empty AST was observed just south of the Maintenance Building. One area of soil staining was observed just north of the Maintenance Building, but no drums or containers were present at that time. The stain appeared to be an oil-based material. Five pieces of PCB-containing equipment (transformers, electrical box, and one drum) were observed throughout the Burgin 1 mine (see Figure 2 for PCB equipment locations). All PCB-containing equipment was labeled as less than 50 parts per million (ppm) PCBs except for one unlabeled, 900-gallon transformer located in the substation area. See Sections 5.4.1 and 5.5.1 for additional discussion. All other containers were observed within the structures located at that mine.

5.1.2 Burgin 2

One unknown drum located in the Burgin 2 Drum Shed appeared to be bulging and oil staining

was observed on the concrete floor. The floor appeared to be in good condition. West of the Burgin 2 drum shed, eight drums were observed in a field with significant soil staining present. Five of the drums were empty and three contained oil. Additionally, one of the drums appeared to be bulging and was leaking oil. One large AST was observed on Burgin 2 and was labeled as burner oil. Significant soil staining was observed near the port on the south side of the AST. Additionally, a sheen was present on the puddled water located within the stained area. Approximately 150 feet of asbestos-containing transite pipe was observed throughout the Burgin 2 Dump Area (see Figure 3). Several other containers of grease, oils, solvents, and some ballast lights were observed with minor staining within the Dump Area. Nine pieces of suspected PCB-containing equipment (transformers) were observed throughout the Burgin 2 mine (see Figure 3 for PCB equipment locations). All PCB-containing equipment was labeled as less than 50 ppm PCBs, except for one 1,000-gallon transformer that was labeled as containing 50 to 500 ppm PCBs. See Section 5.5.2 for additional discussion. All other containers were observed within the structures located at the mine. See Figure 3 for the locations of the observed impacts at Burgin 2. 5.1.3 Apex 2

One 5-gallon container and one ½-gallon container of unknown liquids were observed near the

head frame at the Apex 2 mine. No staining was observed near the containers. Six pieces of suspected PCB-containing equipment (transformers and electrical boxes) were observed throughout the Apex mine (see Figure 4 for PCB equipment locations). All PCB-containing equipment was labeled as less than 50 ppm PCBs except for one, unlabeled, 2,500-gallon transformer located in the substation area. See Section 5.4.2 for additional discussion. All other containers were observed within the structures located at that mine.



5.1.4 Trixie Several drums of oil were observed near the empty AST located on the western portion of the

Trixie mine and several drums were observed on the southeastern portion of the Trixie mine. Some soil staining was observed near the drums located on the southeastern portion of the mine. The AST was located within a plastic membrane being used for secondary containment. The secondary containment was full of water. Ten pieces of suspected PCB-containing equipment (transformers and electrical boxes) were observed throughout the Trixie mine (see Figure 5 for PCB equipment locations). All PCB-containing equipment was labeled as less than 50 ppm PCBs. See Section 5.5.3 for additional discussion. All other containers were observed within the structures located at that mine.

5.1.5 Trixie Borehole

No containers, drums, or ASTs of hazardous materials or petroleum products were observed at

the Trixie Borehole Mine other than one electrical box. The PCB-oil in the box is labeled as less than 50 ppm.

5.2 Preliminary Structural Integrity Survey and Pre-Demolition Asbestos Results

5.2.1 Burgin 1 It is our opinion based on a cursory visual inspection, that the structures located on the Burgin 1

mine site appear to be structurally in good condition. There are minor cosmetic issues on the exterior of the buildings, such as exterior metal siding in poor condition. However, the cosmetic issues do not appear to warrant the demolition of any of the structures.

5.2.2 Burgin 2

It is our opinion, based on a cursory visual inspection, that all but two of the structures located on

the Burgin 2 mine site appear to be structurally sound. Damage to the structural members of the Wheelhouse and Concrete Mix Buildings (see Figure 3) appear to warrant demolition of the structures. Again, there are minor cosmetic issues on the exterior of the buildings which do not warrant the demolition of the remaining structures. Wasatch performed pre-demolition asbestos surveys for the Wheelhouse and Concrete Mix Buildings, which are presented in Appendix A. No asbestos content was detected in any of the samples collected.

5.2.3 Apex 2

It is our opinion, based on a cursory visual inspection, that the three structures at the Apex 2 mine

appear to be structurally sound and demolition is not warranted.

5.2.4 Trixie It is our opinion, based on a cursory visual inspection, that three of the four structures at the Trixie

mine appear to be structurally sound. The supporting frame of the Wheelhouse is significantly damaged and may warrant demolition of the building. Wasatch performed a pre-demolition asbestos survey of the Wheelhouse Building which is presented in Appendix A. No asbestos content was detected in any of the samples collected.



5.2.5 Trixie Borehole It is our opinion, based on a cursory visual inspection, that the two structures at the Trixie

Borehole mine appear to be structurally sound and do not warrant demolition. 5.3 Trixie Borehole Mine Gas Results The mine gas escaping the Trixie borehole exuded a very strong odor that smelled acidic. Additionally, the mine shaft doors at the Trixie borehole appeared to be significantly more corroded than all other shaft doors located at the site. Mine gas sample AS-1 exhibited a carbon disulfide concentration of 0.0045 ppm or 14.01 micrograms per cubic meter (µp/m3). This concentration is well below the U.S. EPA Industrial Air concentration of 3,100 µg/ m3 and the National Institute of Occupational Safety and Health (NIOSH) time weighted average (TWA) of 1 ppm. No other sulfur gas analytes were detected in the sample. 5.4 Unlabeled Transformer Results Transformer PCB oil analytical data is summarized in Table 2. The laboratory analytical report is presented in Appendix B.

5.4.1 Burgin 1

The unlabeled transformer located at the Burgin 1 substation (Burgin-Sub-1) exhibited a Aroclor

1260 concentration of 18,200 micrograms per kilogram (µg/kg). This concentration is equivalent to 18.2 ppm of PCBs. The Toxic Substance Control Act (TSCA) states that if PCB oil contains greater than 50 ppm PCBs, the oil is to be incinerated when discarded. No other PCBs were detected in this sample.

5.4.2 Apex 2

The unlabeled transformer located at the Apex 2 substation (Apex-T1) exhibited a Aroclor 1260

concentration of 25,300 µg/kg, and a Aroclor 1016 concentration of 1,080 µg/kg. These concentrations are equivalent to 27.1 ppm of PCBs. No other PCBs were detected in this sample.

5.5 Soil Analytical Results

Analyte concentrations in soil were compared to U.S. EPA Regional Screening Levels (RSLs) for Industrial Soil and Residential Soil. Soil analytical data for PCBs is summarized in Table 2. The laboratory analytical report is presented in Appendix B. PCBs consist of several different Aroclor’s

5.5.1 Burgin 1

Soil sample Burgin-TF-2 exhibited an Aroclor 1260 concentration of 2,120 µg/kg. This

concentration exceeds the U.S. EPA RSL for Industrial Soil for Aroclor 1260 of 990 µg/kg. Soil sample Burgin-TF-1 exhibited a Aroclor 1260 concentration of 510 µg/kg. This concentration is below the U.S. EPA RSL for Industrial Soil for Aroclor 1260. No other PCBs were detected in these samples. 5.5.2 Burgin 2

Soil samples Burgin2-TF-1 (2,670 ug/kg) and Burgin2-TF-2 (6,000 µg/kg) exhibited Aroclor 1254

concentrations that exceed the U.S. EPA RSL for Industrial Soil for Aroclor 1254 of 970 µg/kg. Soil sample Burgin2-TF-3 exhibited an Aroclor 1260 concentration of 1,630 µg/kg. This concentration exceeds the U.S. EPA RSL for Industrial Soil for Aroclor 1260 of 990 µg/kg. Soil



samples Burgin2-TF-4 and Burgin2-TF-5 exhibited an Aroclor 1260 concentration of 636 µg/kg and 552 µg/kg, respectively. These concentrations are below the U.S. EPA RSL for Industrial Soil for Aroclor 1260. No other PCBs were detected in these samples.

5.5.3 Trixie

Soil samples Trixie-TF-1 (320 µg/kg), Trixie-TF-2 (197 µg/kg), Trixie-TF-3 (449 µg/kg), Trixie-TF-

4 (122 µg/kg), and Trixie-TF-5 (277 µg/kg) exhibited Aroclor 1260 concentrations that are below the U.S. EPA RSL for Industrial Soil for Aroclor 1260. No other PCBs were detected in these samples.

No PCBs were detected in the Trixie-Black-1 soil sample.

6.0 CONCLUSIONS AND RECCOMMENDATIONS

Wasatch has completed a hazardous material and petroleum product inventory of each mine site. Numerous containers, drums, and ASTs of chemicals and hazardous materials will need to be properly disposed of during the reclamation activities. Several unknown containers, drums, and one AST were identified throughout the site. Wasatch is currently obtaining a cost estimate from a certified waste handler for proper packing, shipping, and disposal of all hazardous material and petroleum products. All unknown containers, drums, and ASTs will need to be field screened by the certified waste handler to facilitate proper disposal of the materials. Wasatch recommends that during future sampling of the unknown products and disposal activities, that the observed oil and water in the trenches of the cable engines at Burgin 1 also be characterized and removed. Wasatch recommends the observed transite pipe located in the dump area of Burgin 2 be properly disposed of by a certified asbestos abatement company. The remainder of the debris (plastic piping, wood, metal, plastics, etc.) located in the dump area should also be properly disposed of at a local landfill or salvaged from the dump. It is our opinion, based on cursory visual observations, that the structures located on the Burgin 1, Apex 2, and Trixie Borehole mines appear to be structurally in good condition. There are minor cosmetic issues on the exterior of the buildings, such as exterior metal siding in poor condition. However, the cosmetic issues do not appear to warrant demolition. It is our opinion, based on cursory visual observations, that all but two of the structures located at the Burgin 2 mine appear to be structurally sound. Damage to the structural members of the Wheelhouse and Concrete Mix Buildings appear to warrant demolition of the structures. Wasatch performed pre-demolition asbestos surveys for the Wheelhouse and Concrete Mix Buildings. No asbestos content was detected in any of the samples collected. Again, there are minor cosmetic issues on the exterior of the buildings which do not appear to warrant the demolition of the other structures. It is our opinion, that three of the four structures at the Trixie mine are structurally sound. The supporting frame of the Wheelhouse Building is significantly damaged and appears to warrant demolition of the building. Wasatch performed a pre-demolition asbestos survey of the building. No asbestos content was detected in any of the samples collected. Carbon disulfide was detected in a gas sample collected near the opening of the Trixie Borehole mine. Carbon disulfide is a flammable liquid that is highly volatile. In the vapor form it is denser than air. Additionally, carbon disulfide is corrosive to metals. Given that carbon disulfide was detected in the mine gases escaping the Trixie Borehole (at concentrations below the U.S. EPA Industrial Air and NOISH TWA concentrations), and carbon disulfide is denser than air, it is possible that carbon disulfide concentrations



lower in the mine shaft may exceed the lower explosive limit (1.3%). Wasatch recommends that no hot work or metal cutting activities are conducted near the mine opening. It may also be prudent to reassess the current DOGM-approved shaft covering for this mine. Wasatch identified numerous transformers and other suspected PCB-containing equipment throughout the site. Most of the equipment was labeled as containing less than 50 ppm of PCBs. Two unlabeled transformers were unlabeled, and one 1,000-gallon transformer was labeled as containing PCBs ranging from 50 to 500 ppm. Based on the analytical results of the transformer oil samples (for both unlabeled transformers), the unlabeled transformers qualify as containing less than 50 ppm of PCBs. TSCA regulations state that all PCB-containing oil greater than 50 ppm require incineration when discarded. However, mineral oil recyclers that historically accepted PCB-oil less than 50 ppm, will no longer accept PCB-oil containing more than 2 ppm PCBs. Therefore, all transformer oil to be discarded will likely be required to be incinerated. TSCA regulations state that if PCB-impacted soils with concentrations less than 50 ppm are excavated during remediation activities, those soils may be disposed of at a Subtitle-D landfill facility. Based on the analytical soil data, several areas within the Burgin 1 and Burgin 2 mine sites will need to be excavated and properly disposed of to meet DOGM reclamation criteria. Wasatch recommends that the impacted soils be removed, confirmation soil samples collected, and all TSCA regulations regarding generation, transporting, and disposing of the impacted soils be followed. Our services consist of professional opinions and recommendation made in accordance with generally accepted environmental engineering principles and practices. This warranty is in lieu of all other warranties either expressed or implied. Should you have any questions, please do not hesitate to contact us. Sincerely, WASATCH ENVIRONMENTAL, INC. Blake Downey, P.G. Julie Kilgore, President Project Hydrogeologist Environmental Manager Audra Heinzel Project Environmental Scientist

DATE:PROJECT NO.:Environmental Science and Engineering

Vicinity and Mine Site Location Map

April 12, 20172224-001

Chief Consolidated Mine Sites - Tintic OperationsUtah County

Approximately 3 Miles Southeast of Eureka, Utah

Eureka

Trixie Mine

Trixie Borehole

Apex Mine

Burgin 2 MineBurgin 1 Mine

FIGURE 1

Scale: 1-inch equals approximately 2,500 feet


Burgin 1 Mine Site Materials And Building Location Map

April 12, 20172224-001

Office

Wheelhouse

EngineBuilding

OilStorage

WoodBuilding

TinBuilding

Concentrator

AssayOffices

Substation

Maintenance

GuardShack

Accounting

LEGEND

FIGURE 2

Unknown Full AST

Empty AST

Exterior Drum(s) Location

Oil Stained Soil

PCB Oil Containing Equipment



Scale: 1-inch equals approximately 105 feet


Burgin 2 Mine Site Materials And Building Location Map

April 12, 20172224-001

Dump Area

LEGEND

Exterior Containers

Empty AST


PCB Stained Soil


Oil Stained Soil

Area of ObservedAsbestos-Containing

Pipe

Workshop

FlammableShed

SiftingBuilding

PartsBuilding

ElectricalBuilding

Substation

WoodShed

ConcreteStorage Yard

Drum Shed

TruckShed

WheelHouse

CoreHouse

FIGURE 3

CementMix Bldg

DryBuilding




DATE:PROJECT NO.:Environmental Science and Engineering FIGURE 4

Apex Mine Site PCB Sample And Building Location Map

April 12, 20172224-001



UnknownContainer

Apex-T1

Transformer Oil Sample Location


Substation

Shower House

Geology Office/Wheel House

Shed



Trixie Mine Site PCB Sample And Building Location Map

April 12, 20172224-001

Trixie-TF-3

Trixie-TF-4Trixie-TF-5

Trixie-Black-1

Trixie-TF-1

Trixie-TF-2

LEGEND

Soil PCB Sample Location

Empty AST


PCB Stained Soil


Office

ShowerHouse

WheelHouse

TinShed

Substation

FIGURE 5





Trixie Borehole Mine Site Materials And Building Location Map

April 12, 20172224-001

AS-1

LEGEND

Mine Gas Sample Location


ShedWheelHouse

Substation

FIGURE 6





Burgin 1 Mine Site PCB Sample Location Map

April 12, 20172224-001



LEGEND

Transformer Oil Sample Location


PCB Soil Sample Location

PCB Stained Soil

FIGURE 7

Burgin-TF-2

Burgin-TF-1Burgin-Sub-1



Burgin 2 Mine Site PCB Sample And Building Location Map

April 12, 20172224-001

LEGEND

PCB Stained Soil


PCB Soil Sample Location

Burgin2-TF-1

Burgin2-TF-2

Burgin2-TF-5

Burgin2-TF-4Burgin2-TF-3

FIGURE 8




Gear Lube 5‐gallon bucket 3

Compresser Oil 55‐gallon drum 1

Epoxy 5‐gallon bucket 2

Epoxy Activator 5‐gallon bucket 2

Paint 5‐gallon bucket 1

Rust Inhibitor 5‐gallon bucket 1

Urethane 5‐gallon bucket 1

Engine Oil 55‐gallon drum 1

Chain Lube 1/2 gallon container 1

Quenching Oil 55‐gallon drum 1

1/2‐gallon bucket 1

1/4 bucket 1

Rust Inhibitor Pint 2

Hydraulic Oil 5‐gallon bucket 3

Engine Oil 1‐gallon bucket 4

Turbine Oil 5‐gallon bucket 1

Epoxy Activator 1‐gallon bucket 2


Simply Awesome Degreaser 5‐gallon bucket 1

Roof Cement 1‐gallon bucket 1

ME Lube 1‐gallon bucket 2

Sulfuric Acid 1/2 liter 1

Poly REX 20‐gallon drum 1

Automatic Transmision Fluid 5‐gallon bucket 1

Rubber Patch Cleaner 1/2‐gallon bucket 1

Stoddard Solvent 55‐gallon drum 1

Patching Cement 1‐gallon bucket 1

Tranformer Oil (<50 ppm PCBs) 55‐gallon drum 1

Unknown 55‐gallon drum 1

Sulfuric Acid 5‐gallon container 1

Pure N Seal 5‐gallon bucket 1

Ronex MP 5‐gallon bucket 1

Grease 5‐gallon bucket 1

Transformer Oil (<50 ppm PCBs) 50‐gallon drum 1


Engine Building Grease 5‐gallon bucket 1

Hydraulic Oil 55‐gallon drum 1

Unknown Container 55‐gallon drum 1


Spartan Synthetic EP 55‐gallon drum 1

Engine Oil 5‐gallon bucket 3

Epoxy 1‐gallon bucket 1

Carboxide Absorbent 4‐lbs 5

Batteries (small rectangular) Self contained 71

5‐gallon bucket 1

1‐gallon bucket 6

Paint Thinner 1/2 gallon 1

Amonia 1‐gallon bucket 1

2‐gallon bucket 1

1/2 gallon 1

Enamel pint 1

Antifreeze 1/2‐gallon 1

Small Batteries (rectangular) Self contained 7

Accounting Floor Finish 1/4 gallon 1

Tranformer Oil (transformer unknown) 900‐gallon non‐labeled (sampled by Wasacth) 1

Tranformer Oil (transformer <50 ppm) 110‐gallon 1

Assay Office Bromine 1‐lb containers 9

Tranformer Oil (Transformer <50 ppm) 313‐gallons 1

Gear Oil 55‐gallon drum 1

Epoxy 2‐gallon container 1

Sodium Isopropyl Xanthate Pellets 55‐gallon drum 2

Polyacrilamide Emulsion 55‐gallon drum 2

Unknown 5‐gallon bucket 4

Aboveground Storage Tank (unknown) 250‐gallon 1

Gear Shield 30‐gallon drum 3

35% Hydrogen Peroxide 55‐gallon drum 2

Transfer Fluid 5‐gallon bucket 1

Coal Flotation 55‐gallon drum 1

Nalflate 55‐gallon drum 1

Clotting Granules 10‐gallon bucket 1

Gear Shield 30‐gallon drum 1

Table 1Hazardous Material and Petroleum Product Inventory

Chief Consolidated Mine Sites ‐ Tintic Operations

Unknown Container

Unknown Solvent

Vinyl Acrylic Paint

Wheel House

Oil Storage

Office

Guard Shack

Substation

Concentrator

Tin Building

Burgin 1

Maintenance

Container QuantityArea Building Contents

Battery Acid 3‐gallon bucket 1

Epoxy/Paint 1‐gallon 8


Roof Tar 3‐gallon bucket 1

Lubricant 5‐gallon bucket 1

Pump Oil 5‐gallon bucket 1

Texaco Crater 2X Fluid with Trichloroethylene 5‐gallon bucket 1

Non‐PCB Containing 907 gallons 1

Non‐PCB 54 gallons 3



PCB Containing (50 to 500 ppm) 1,000 gallons 1

Toluene 5‐gallon bucket 1

Varnish 1/2‐gallon 1

PCB Ballasts Self contained 5

Mercury Bulb Self contained 1

Floor Finish 2‐gallon bucket 1

Small Batteries Self contained 20

Acetone 5‐gallon bucket 3

Primer 5‐gallon bucket 1

Lectra Clean Degreaser 5‐gallon bucket 1

55‐gallon drum 1

5‐gallon bucket 1

Automatic Transmision Fluid 55‐gallon drum 1


Backing Material 2‐gallon bucket 2

Oxygen Generating Canisters Self contained 21

Epoxy/Paint 1‐gallon 5

Phosphoric Acid 1‐gallon 1

Carbomastic #14 Black 1/2‐gallon 2

Component A 1‐gallon 2

Component B 1‐gallon 2

Copper Sulfate 20‐pound bag 4

Highcore Chain and Cable Conditioner 1‐pint 1

Paint Thinner 2‐gallon bucket 1

Unkown 5‐gallon bucket 2

Lubricant 30‐gallon drum 10

Unkown 55‐gallon drum 8

Turbine Oil 55‐gallon drum 2


Oil 55‐gallon drum 2

Hydraulic Oil 55‐gallon drum 1


Transite Pipe foot ~150

PCB Ballasts Self contained 1

Solvent container 5‐gallon bucket 1

Oil 55‐gallon drum 1


Automatic Transmision Fluid 55‐gallon drum 1

Lubricant 55‐gallon drum 1

Oil 1‐gallon 1


Mercury Bulb Self contained 1

Rope Lube 5‐gallon bucket 2

Drilling Fluid 5‐gallon bucket 1

Gear Oil 1‐gallon 1


Antifreeze 1‐gallon 1

Electrical Box (<50 ppm) 20‐gallon 3

Grease 30‐gallon drum 1


54‐gallon 3

20‐gallon 3

200‐gallon 1



Substation Tranformers Non‐PCB (<50 ppm) 1200‐gallons 3

Hydrochloric Acid 1/2‐gallon 1

Automatic Transmision Fluid 5‐gallon 1

Diclorax 5‐gallon 1


4‐gallon 1

1/2‐gallon 1

300‐gallon 1

10‐gallon 1

Transformer (non‐PCB) 10‐gallon 2

Tranformer (unknown) 2,500‐gallon (sampled by Wasatch) 1

Shower House Unknown Container 5‐gallon 1


Substation

Unknown Container

Tranformer (non‐PCB)

Gear Oil

Non‐PCB (<50 ppm)

TIN

Geology Office/Wheel

House

Exterior

Dump Field

Exterior

Trixie Borehole

Workshop

Parts Building

Drum Shed

Drum Pile

Office

Shower House

Wheel House

Exterior

Transformers/Electical

Equipment

Flammable Shed

Exterior Transformers

Electrical Building

Apex

Burgin 2

Trixie

Aro

clo

r 12

60

Aro

clo

r 10

16

Aro

clo

r 12

54

Burgin-Sub-1 Oil 3/31/17 18,200 <990 <990

Apex-T1 Oil 3/31/17 25,300 1,080 <990

NOTES:

Only analytes detected above laboratory reporting limits in one or more sample are presented

< = concentration was below the laboratory detection limit

Table 2Oil Analytical Data - PCBs

Chief Consolidated Mine Sites - Tintic Operations

all concentrations are expressed in micrograms per kilogram (µg/kg) except as noted otherwise

Sample I.D. MediaSample

Collection Date

Polychlorinated Biphenyls

Aro

clo

r 12

60

Aro

clo

r 10

16

Aro

clo

r 12

54

Burgin-TF-1 Soil 3/31/17 510 <29.4 <29.4

Burgin-TF-2 Soil 3/31/17 2,120 <289 <289

Burgin2-TF-1 Soil 3/31/17 <274 <274 2,670

Burgin2-TF-2 Soil 3/31/17 <209 <290 6,000

Burgin2-TF-3 Soil 3/31/17 1,630 <28.3 <28.3

Burgin2-TF-4 Soil 3/31/17 636 <26.7 <26.7

Burgin2-TF-5 Soil 3/31/17 552 <137 <137

Trixie-Black-1 Soil 3/31/17 <26.6 <26.6 <26.6

Trixie-TF-1 Soil 3/31/17 320 <26.9 <26.9

Trixie-TF-2 Soil 3/31/17 197 <25.6 <25.6

Trixie-TF-3 Soil 3/31/17 449 <32.5 <32.5

Trixie-TF-4 Soil 3/31/17 122 <30.9 <30.9

Trixie-TF-5 Soil 3/31/17 277 <33.3 <33.3

240 4,100 240

990 27,000 970

NOTES:

=Concentration exceeds the applicable U.S. EPA RSL for Industrial Soil

BOLD = Concentration exceeds the applicable U.S. EPA RSL for Residen

all concentrations are expressed in micrograms per kilogram (µg/kg) except as noted otherwise

U.S. EPA RSL for Residential Soil

U.S. EPA RSL for Industrial Soil

Only analytes detected above laboratory reporting limits in one or more sample are presented

< = concentration was below the laboratory detection limit

U.S. EPA RSL = United States Environmental Protection Agency Regional Screening Level

Sample I.D. MediaSample

Collection Date

Polychlorinated Biphenyls

Table 3Soil Analytical Data - PCBs

Chief Consolidated Mine Sites - Tintic Operations

Appendix A

Asbestos Reports

2410 WEST CALIFORNIA AVENUE ● SALT LAKE CITY, UTAH 84104

PHONE (801) 972-8400 ● FAX (801) 972-8459

Website: www.wasatch-environmental.com ● e-Mail: [email protected]

Mr. Timothy Buchanan April 13, 2017 Enirgi Group Corporation/Chief Consolidated Mining Company Project No. 2224-001 7703 Ralston Road Arvada, Colorado 80002 SUBJECT: Asbestos Survey Report

Burgin No. 2 Mine Concrete Mix Building Approximately 3 Miles Southeast of Eureka

Utah County, Utah On April 31, 2017, Wasatch Environmental, Inc., (Wasatch) performed an asbestos survey of the concrete mix building of the building at the above-referenced property (see Figure 1). The purpose of this survey was to identify asbestos-containing materials (ACMs) in anticipation of possible demolition activities. REGULATORY BACKGROUND

ACM is regulated by the Environmental Protection Agency (EPA) and the Occupational Safety & Health Administration (OSHA). In 1973, the EPA promulgated the "National Emission Standards for Hazardous Air Pollutants" (NESHAP) regulation, which addresses demolition and renovation activities. The federal NESHAP has been adopted by the Utah Department of Air Quality by reference in Section 214-1 of the Utah Air Conservation Rules. The EPA uses the terms "friable" and “non-friable" to make a distinction between building materials that would readily release asbestos fibers when damaged or disturbed and those materials that are unlikely to result in significant fiber release. Friable asbestos material is any material containing more than one percent (1%) asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the asbestos content is less than 10% as determined by a method other than point counting by polarized light microscopy (PLM), asbestos content must be verified by point counting using PLM or may be assumed to contain greater than 1% asbestos content. EPA defines two categories of non-friable materials: Category I non-friable ACM and Category II non-friable ACM:

• Category I non-friable ACM is any asbestos-containing packing, gasket, resilient floor covering, mastic, or asphalt roofing product that contains more than 1% asbestos. Category I non-friable ACM must be inspected and tested before demolition if it is in poor condition. EPA has determined that, if in poor condition, otherwise non-friable materials can release significant amounts of asbestos fibers and the material must be handled in accordance with NESHAP. Asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing materials must be removed before demolition only if they are in poor condition and are friable. Additionally, when non-friable ACM is subjected to intense mechanical forces, such as those encountered during demolition or renovation, it can be crumbled, pulverized, or reduced to powder, and thereby release asbestos fibers. When non-friable materials are damaged or are likely to become damaged during such activities, they must be handled in accordance with the NESHAP regulation.

Wasatch Environmental Inc.

Page 2

• Category II non-friable ACM is any material excluding Category I non-friable ACM containing more than 1% asbestos.

"Regulated Asbestos-Containing Material" (RACM) is (a) friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations. Asbestos NESHAP requires that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal. ACM need not be removed before demolition if it:

• Is a Category I non-friable ACM.

• Is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition.

• Was not accessible for testing and, therefore, was not discovered until after demolition began and, as a result of the demolition, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at all times until disposed.

• Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

ASBESTOS SURVEY Audra Heinzel of Wasatch performed the asbestos survey. Ms. Heinzel is a Utah-certified asbestos inspector (ASB-3952). This survey was conducted on behalf of the Chief Consolidated Mining Company. This survey was conducted for an approximately 144-square-foot, single-story concrete mix building constructed in 1985. The building is constructed of metal with a metal roof. Interior surfaces consist of insulated metal walls and ceilings, and a concrete floor. For surfacing materials, we collected a minimum of three samples for homogenous suspect friable ACM encompassing less than 1,000 square feet, a minimum of five samples for materials encompassing between 1,000 and 5,000 square feet, and a minimum of seven samples for materials encompassing greater than 5,000 square feet. For miscellaneous materials such as floor tiles, ceiling tiles, heat tape, fireproofing, and concrete, at least one sample was collected for each homogenous material. Material visually determined to be non-asbestos (such as fiberglass, foam rubber, wood, etc.) was not sampled. A total of 4 bulk material samples were collected from the following homogeneous materials:

• One sample of foam insulation (approximately 200 square feet); and,

• Three samples of concrete foundation (approximately 144 square feet). Bulk samples were submitted under chain of custody to EMC Labs, a NVLAP-accredited laboratory. All samples were analyzed using visual estimation with the use of polarized light microscopy (PLM) according to EPA 600/R-93-116. The laboratory results and associated chain-of-custody documentation are included in Appendix A. The laboratory report includes samples for another building on the Burgin No. 2 mine site. Analytical results


Page 3

for the samples collected from the concrete mix building are highlighted. No asbestos content was identified in any of the samples collected. There is potential for unidentified suspect ACM to be present within the building in areas that were not accessible during the inspection such as under floors. If additional suspect ACM is discovered, demolition activities should immediately cease, the asbestos inspector contacted, and additional evaluation conducted. A copy of this report must be onsite during demolition activities. Should you have any questions, please do not hesitate to contact us. WASATCH ENVIRONMENTAL, INC.

Audra Heinzel Julie Kilgore, President Project Environmental Scientist Principal Environmental Manager (ASB-3952) Wasatch Environmental (ASBC-169) Distribution: (1) Addressee (electronic) ATTACHMENTS: Figure 1 – Location Map Appendix A – Laboratory Report Appendix B – Inspector Certification

The use or reuse of this information is restricted to the referenced document unless otherwise authorized. Wasatch Environmental Copyright 2006

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Burgin 2 Concrete Mix Building Location Map Figure 1

BURGIN 2 MINE CONCRETE MIX BUILDING WEI 2224-001

Burgin 2Mine

ConcreteMix Building

Appendix A

Laboratory Report

Asbestos

Detected

Layer Name /

Sample Description

Lab ID Sample

Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos

Constituents

Laboratory Report

0184454

NVLAP#101926-0

Client ID

Client:Address: 2410 W. CALIFORNIA AVE

SALT LAKE CITY UT 84104

WASATCH ENVIRONMENTAL

Date Received: 04/05/2017

04/12/2017Date Analyzed:

Job# / P.O. #:

EMC LABS, INC.

Collected: 03/31/2017

EPA Method: Project Name: BURGIN 2

Submitted By: AUDRA HEINZELAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044

Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

04/12/2017Date Reported:

EPA 600/R-93/116

Asbestos Type

(%)

Cellulose FiberNoConcrete, Gray None Detected0184454-001

BURG 2-BLDG 2-1

<1%

CarbonatesQuartzGypsumBinder/Filler

99%


BURG 2-BLDG 2-2

<1%


99%


BURG 2-BLDG 2-3

<1%


99%

NoLAYER 1Insulation, Yellow

None Detected0184454-004

BURG 2-BLDG 2-4

FoamGypsumBinder/Filler

100%

TalcNoLAYER 2Insulation Coat/ Cover, White

None Detected 2%

GypsumQuartzBinder/Filler

98%


BURG 2-BLDG 1-1

<1%


99%

Page 1 of 2

ah

Highlight

ah

Highlight

ah

Highlight

ah

Highlight

ah

Highlight

ah

Highlight

ah

Highlight

Asbestos

Detected

Layer Name /

Sample Description

Lab ID Sample

Location


Non-Asbestos

Constituents

Laboratory Report

0184454

NVLAP#101926-0

Client ID






Job# / P.O. #:

EMC LABS, INC.




Collected By:


Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726


EPA 600/R-93/116

Asbestos Type

(%)

NoConcrete, Gray None Detected0184454-006

BURG 2-BLDG 1-2


100%


BURG 2-BLDG 1-3


100%

Analyst - Kurt Kettler Signatory - Lab Manager - Ken Scheske

Distinctly stratified, easily separable layers of samples are analyzed as subsamples of the whole and are reported separately for each discernible layer. All analyses are derived from calibrated visual estimate and measured in area percent unless otherwise noted. The report applies to the standards or procedures identified and to the sample(s) tested. The test results are not necessarily indicated or representative of the qualities of the lot from which the sample was taken or of apparently identical or similar products, nor do they represent an ongoing quality assurance program unless so noted. These reports are for the exclusive use of the addressed client and that they will not be reproduced wholly or in part for advertising or other purposes over our signature or in connection with our name without special written permission. The report shall not be reproduced except in full, without written approval by our laboratory. The samples not destroyed in testing are retained a maximum of thirty days. The laboratory measurement of uncertainty for the test method is approximately less than 1 by area percent. Accredited by the National Institute of Standards and Technology, Voluntary Laboratory Accreditation Program for selected test method for asbestos. The accreditation or any reports generated by this laboratory in no way constitutes or implies product certification, approval, or endorsement by the National Institute of Standards and Technology. The report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. Polarized Light Microscopy may not be consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials.

Page 2 of 2

Appendix B

Inspector Certification


PHONE (801) 972-8400 ● FAX (801) 972-8459



Trixie Mine Wheel House Building Approximately 3 Miles Southeast of Eureka

Utah County, Utah On April 31, 2017, Wasatch Environmental, Inc., (Wasatch) performed an asbestos survey of the wheel house building at the above-referenced property (see Figure 1). The purpose of this survey was to identify asbestos-containing materials (ACMs) in anticipation of possible demolition activities. REGULATORY BACKGROUND





Page 2






ASBESTOS SURVEY Audra Heinzel of Wasatch performed the asbestos survey. Ms. Heinzel is a Utah-certified asbestos inspector (ASB-3952). This survey was conducted on behalf of the Chief Consolidated Mining Company. This survey was conducted for an approximately 1,000-square-foot, single-story wheel house building constructed in the 1950s. The building is constructed of metal with a metal roof. Interior surfaces consist of metal walls and ceilings, and a concrete floor. For surfacing materials, we collected a minimum of three samples for homogenous suspect friable ACM encompassing less than 1,000 square feet, a minimum of five samples for materials encompassing between 1,000 and 5,000 square feet, and a minimum of seven samples for materials encompassing greater than 5,000 square feet. For miscellaneous materials such as floor tiles, ceiling tiles, heat tape, fireproofing, and concrete, at least one sample was collected for each homogenous material. Material visually determined to be non-asbestos (such as fiberglass, foam rubber, wood, etc.) was not sampled. A total of 3 bulk material samples were collected from the following homogeneous materials:

• Three samples of concrete foundation (approximately 1,000 square feet). Bulk samples were submitted under chain of custody to EMC Labs, a NVLAP-accredited laboratory. All samples were analyzed using visual estimation with the use of polarized light microscopy (PLM) according to EPA 600/R-93-116. The laboratory results and associated chain-of-custody documentation are included in Appendix A. No asbestos content was identified in any of the samples collected. There is potential for unidentified suspect ACM to be present within the building in areas that were not accessible during the inspection such as under floors. If additional suspect ACM is discovered,


Page 3

demolition activities should immediately cease, the asbestos inspector contacted, and additional evaluation conducted. A copy of this report must be onsite during demolition activities. Should you have any questions, please do not hesitate to contact us. WASATCH ENVIRONMENTAL, INC.

Audra Heinzel Julie Kilgore, President Project Environmental Scientist Principal Environmental Manager (ASB-3952) Wasatch Environmental (ASBC-169) Distribution: (1) Addressee (electronic) ATTACHMENTS: Figure 1 – Location Map Appendix A – Laboratory Report Appendix B – Inspector Certification


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Trixie Wheel House Building Location Map Figure 1

TRIXIE MINE WHEEL HOUSE BUILDING WEI 2224-001

Trixie Mine

WheelHouse

Appendix A

Laboratory Report

Asbestos

Detected

Layer Name /

Sample Description

Lab ID Sample

Location


Non-Asbestos

Constituents

Laboratory Report

0184453

NVLAP#101926-0

Client ID






Job# / P.O. #:

EMC LABS, INC.


EPA Method: Project Name: TRIXIE


Collected By:


Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726


EPA 600/R-93/116

Asbestos Type

(%)


TRIXIE-1

<1%


99%


TRIXIE-2

<1%


99%


TRIXIE-3

<1%


99%

Cellulose FiberNoInsulation, Tan/ Lt. Yellow None Detected0184453-004

TRIXIE-4

95%

GypsumQuartz

5%



Page 1 of 1

Appendix B



PHONE (801) 972-8400 ● FAX (801) 972-8459



Burgin No. 2 Mine Wheel House Building Approximately 3 Miles Southeast of Eureka

Utah County, Utah On April 31, 2017, Wasatch Environmental, Inc., (Wasatch) performed an asbestos survey of the wheel house building at the above-referenced property (see Figure 1). The purpose of this survey was to identify asbestos-containing materials (ACMs) in anticipation of possible demolition activities. REGULATORY BACKGROUND





Page 2






ASBESTOS SURVEY Audra Heinzel of Wasatch performed the asbestos survey. Ms. Heinzel is a Utah-certified asbestos inspector (ASB-3952). This survey was conducted on behalf of the Chief Consolidated Mining Company. This survey was conducted for an approximately 648-square-foot, single-story wheel house building constructed in the 1950s. The building is constructed of metal with a metal roof. Interior surfaces consist of metal and pressed wood walls and ceilings and a concrete floor. For surfacing materials, we collected a minimum of three samples for homogenous suspect friable ACM encompassing less than 1,000 square feet, a minimum of five samples for materials encompassing between 1,000 and 5,000 square feet, and a minimum of seven samples for materials encompassing greater than 5,000 square feet. For miscellaneous materials such as floor tiles, ceiling tiles, heat tape, fireproofing, and concrete, at least one sample was collected for each homogenous material. Material visually determined to be non-asbestos (such as fiberglass, foam rubber, wood, etc.) was not sampled. A total of 3 bulk material samples were collected from the following homogeneous materials:

• Three samples of concrete foundation (approximately 648 square feet) Bulk samples were submitted under chain of custody to EMC Labs, a NVLAP-accredited laboratory. All samples were analyzed using visual estimation with the use of polarized light microscopy (PLM) according to EPA 600/R-93-116. The laboratory results and associated chain-of-custody documentation are included in Appendix A. The laboratory report includes samples for another building on the Burgin No. 2 mine site. Analytical results for the samples collected from the wheel house building are highlighted. No asbestos content was identified in any of the samples collected.


Page 3

There is potential for unidentified suspect ACM to be present within the building in areas that were not accessible during the inspection such as between the walls and under floors. If additional suspect ACM is discovered, demolition activities should immediately cease, the asbestos inspector contacted, and additional evaluation conducted. A copy of this report must be onsite during demolition activities. Should you have any questions, please do not hesitate to contact us. WASATCH ENVIRONMENTAL, INC.

Audra Heinzel Julie Kilgore, President Project Environmental Scientist Principal Environmental Manager (ASB-3952) Wasatch Environmental (ASBC-169) Distribution: (1) Addressee (electronic)

ATTACHMENTS:

Figure 1 – Location Map Appendix A – Laboratory Report Appendix B – Inspector Certification


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Burgin 2 Wheel House Building Location Map Figure 1

BURGIN 2 MINE WHEEL HOUSE BUILDING WEI 2224-001

Burgin 2Mine

WheelHouse

Appendix A

Laboratory Report

Asbestos

Detected

Layer Name /

Sample Description

Lab ID Sample

Location


Non-Asbestos

Constituents

Laboratory Report

0184454

NVLAP#101926-0

Client ID






Job# / P.O. #:

EMC LABS, INC.




Collected By:


Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726


EPA 600/R-93/116

Asbestos Type

(%)


BURG 2-BLDG 2-1

<1%


99%


BURG 2-BLDG 2-2

<1%


99%


BURG 2-BLDG 2-3

<1%


99%

NoLAYER 1Insulation, Yellow

None Detected0184454-004

BURG 2-BLDG 2-4

FoamGypsumBinder/Filler

100%

TalcNoLAYER 2Insulation Coat/ Cover, White

None Detected 2%

GypsumQuartzBinder/Filler

98%


BURG 2-BLDG 1-1

<1%


99%

Page 1 of 2

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Asbestos

Detected

Layer Name /

Sample Description

Lab ID Sample

Location


Non-Asbestos

Constituents

Laboratory Report

0184454

NVLAP#101926-0

Client ID






Job# / P.O. #:

EMC LABS, INC.




Collected By:


Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726


EPA 600/R-93/116

Asbestos Type

(%)


BURG 2-BLDG 1-2


100%


BURG 2-BLDG 1-3


100%



Page 2 of 2

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Appendix B


Appendix B

Oil/Soil Laboratory Analytical Report

Phone: (801) 263-8686, Toll Free: (888) 263-8686, Fax: (801) 263-8687

e-mail: [email protected], web: www.awal-labs.com

Kyle F. Gross Laboratory Director

Jose Rocha QA Officer

3440 South 700 West

Salt Lake City, UT 84119

Wasatch EnvironmentalAudra Heinzel

Dear Audra Heinzel:

Chief / 2224-001

Lab Set ID: 1704013

TEL: (801) 972-8400

2410 West California AvenueSalt Lake City, UT 84104

RE:

American West Analytical Laboratories received sample(s) on 4/3/2017 for the analyses presented in the following report.

American West Analytical Laboratories (AWAL) is accredited by The National Environmental Laboratory Accreditation Program (NELAP) in Utah and Texas; and is state accredited in Colorado, Idaho, New Mexico, Wyoming, and Missouri.

All analyses were performed in accordance to the NELAP protocols unless noted otherwise. Accreditation scope documents are available upon request. If you have any questions or concerns regarding this report please feel free to call.

The abbreviation "Surr" found in organic reports indicates a surrogate compound that is intentionally added by the laboratory to determine sample injection, extraction, and/or purging efficiency. The "Reporting Limit" found on the report is equivalent to the practical quantitation limit (PQL). This is the minimum concentration that can be reported by the method referenced and the sample matrix. The reporting limit must not be confused with any regulatory limit. Analytical results are reported to three significant figures for quality control and calculation purposes.

Thank You,

Approved by: _____________________________Laboratory Director or designee

Report Date: 4/10/2017 Page 1 of 15

http://www.awal-labs.com





3440 South 700 West


Client: Wasatch Environmental

ORGANIC ANALYTICAL REPORTContact: Audra Heinzel

Project: Chief / 2224-001Lab Sample ID: 1704013-001AClient Sample ID: Burgin-Sub-1Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results

PCBs by GC/ECD Method 8082A/3580A1832h1530h

Test Code: 8082-O

Units: mg/kg Dilution Factor: 1Analyzed: 4/4/2017 1148h 4/4/2017 926hExtracted:

Method: SW8082A

AnalyticalResultCompound

Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 0.990 U0.9900.30912674-11-2Aroclor 1221 < 0.990 U0.9900.41511104-28-2Aroclor 1232 < 0.990 U0.9900.31211141-16-5Aroclor 1242 < 0.990 U0.9900.50653469-21-9Aroclor 1248 < 0.990 U0.9900.18912672-29-6Aroclor 1254 < 0.990 U0.9900.063911097-69-1Aroclor 1260 18.20.9900.19111096-82-5

Sulfuric acid cleanup method 3665A utilized for this sample.U - This flag indicates the compound was analyzed for but not detected above the MDL.

Surrogate CAS Result Amount Spiked % REC Limits Qual

0.2970 75.0 Surr: Decachlorobiphenyl 2051-24-3 10-4230.2230.2970 62.2 Surr: Tetrachloro-m-xylene 877-09-8 10-1570.185







3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-002AClient Sample ID: Apex-T1Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results

PCBs by GC/ECD Method 8082A/3580A1725h1530h

Test Code: 8082-O

Units: mg/kg Dilution Factor: 1Analyzed: 4/4/2017 1224h 4/4/2017 926hExtracted:

Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 1.080.9900.30912674-11-2Aroclor 1221 < 0.990 U0.9900.41511104-28-2Aroclor 1232 < 0.990 U0.9900.31211141-16-5Aroclor 1242 < 0.990 U0.9900.50653469-21-9Aroclor 1248 < 0.990 U0.9900.18912672-29-6Aroclor 1254 < 0.990 U0.9900.063911097-69-1Aroclor 1260 25.30.9900.19111096-82-5










3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-003AClient Sample ID: Burgin2-TF-4Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results

PCBs by GC/ECD Method 8082A/35461859h1530h

Test Code: 8082-S-3546

Units: µg/kg-dry Dilution Factor: 1Analyzed: 4/5/2017 1028h 4/4/2017 1012hExtracted:

Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 26.7 U26.713.312674-11-2Aroclor 1221 < 26.7 U26.715.611104-28-2Aroclor 1232 < 26.7 U26.717.411141-16-5Aroclor 1242 < 26.7 U26.710.153469-21-9Aroclor 1248 < 26.7 U26.76.8512672-29-6Aroclor 1254 < 26.7 U26.74.2011097-69-1Aroclor 1260 636 ¹26.72.5511096-82-5

¹ - Matrix spike recovery indicates matrix interference. The method is in control as indicated by the LCS.S - Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.Sulfuric acid cleanup method 3665A utilized for this sample.U - This flag indicates the compound was analyzed for but not detected above the MDL.


5.339 203 Surr: Decachlorobiphenyl 2051-24-3 10-18010.8 S5.339 57.9 Surr: Tetrachloro-m-xylene 877-09-8 10-1453.09







3440 South 700 West





Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 28.3 U28.314.212674-11-2Aroclor 1221 < 28.3 U28.316.611104-28-2Aroclor 1232 < 28.3 U28.318.511141-16-5Aroclor 1242 < 28.3 U28.310.753469-21-9Aroclor 1248 < 28.3 U28.37.2712672-29-6Aroclor 1254 < 28.3 U28.34.4611097-69-1Aroclor 1260 1,63028.32.7111096-82-5

S - Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.Sulfuric acid cleanup method 3665A utilized for this sample.U - This flag indicates the compound was analyzed for but not detected above the MDL.


5.669 125 Surr: Decachlorobiphenyl 2051-24-3 10-1807.085.669 3.81 Surr: Tetrachloro-m-xylene 877-09-8 10-1450.216 S







3440 South 700 West





Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 274 U27413712674-11-2Aroclor 1221 < 274 U27416011104-28-2Aroclor 1232 < 274 U27417911141-16-5Aroclor 1242 < 274 U27410453469-21-9Aroclor 1248 < 274 U27470.312672-29-6Aroclor 1254 2,67027443.111097-69-1Aroclor 1260 < 274 U27426.211096-82-5

S - Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.Sulfuric acid cleanup method 3665A utilized for this sample.The reporting limits were raised due to high analyte concentrations.U - This flag indicates the compound was analyzed for but not detected above the MDL.









3440 South 700 West





Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 290 U29014512674-11-2Aroclor 1221 < 290 U29016911104-28-2Aroclor 1232 < 290 U29018911141-16-5Aroclor 1242 < 290 U29010953469-21-9Aroclor 1248 < 290 U29074.312672-29-6Aroclor 1254 6,00029045.611097-69-1Aroclor 1260 < 290 U29027.711096-82-5










3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-007AClient Sample ID: Trixie-TF-4Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 30.9 U30.915.512674-11-2Aroclor 1221 < 30.9 U30.918.111104-28-2Aroclor 1232 < 30.9 U30.920.211141-16-5Aroclor 1242 < 30.9 U30.911.753469-21-9Aroclor 1248 < 30.9 U30.97.9312672-29-6Aroclor 1254 < 30.9 U30.94.8611097-69-1Aroclor 1260 12230.92.9611096-82-5










3440 South 700 West





Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL


S - Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.Sulfuric acid cleanup method 3665A utilized for this sample.U - This flag indicates the compound was analyzed for but not detected above the MDL.


5.120 67.4 Surr: Decachlorobiphenyl 2051-24-3 10-1803.455.120 0 Surr: Tetrachloro-m-xylene 877-09-8 10-1450 S







3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-009AClient Sample ID: Trixie-Black-1Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 26.6 U26.613.312674-11-2Aroclor 1221 < 26.6 U26.615.511104-28-2Aroclor 1232 < 26.6 U26.617.311141-16-5Aroclor 1242 < 26.6 U26.610.053469-21-9Aroclor 1248 < 26.6 U26.66.8112672-29-6Aroclor 1254 < 26.6 U26.64.1811097-69-1Aroclor 1260 < 26.6 U26.62.5411096-82-5

Additional chromatographic peaks are present in this sample similar to PCB Aroclors but do not match any reported Aroclor patterns.S - Surrogate outside recovery limits. Minimum method criteria of one surrogate within established recovery limits was met.Sulfuric acid cleanup method 3665A utilized for this sample.U - This flag indicates the compound was analyzed for but not detected above the MDL.


5.315 105 Surr: Decachlorobiphenyl 2051-24-3 10-1805.575.315 0 Surr: Tetrachloro-m-xylene 877-09-8 10-1450 S







3440 South 700 West





Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL











3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-013AClient Sample ID: Burgin-TF-2Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL

Aroclor 1016 < 289 U28914512674-11-2Aroclor 1221 < 289 U28916911104-28-2Aroclor 1232 < 289 U28918911141-16-5Aroclor 1242 < 289 U28910953469-21-9Aroclor 1248 < 289 U28974.212672-29-6Aroclor 1254 < 289 U28945.511097-69-1Aroclor 1260 2,12028927.711096-82-5



5.788 117 Surr: Decachlorobiphenyl 2051-24-3 10-1806.805.788 36.4 Surr: Tetrachloro-m-xylene 877-09-8 10-1452.11







3440 South 700 West




Project: Chief / 2224-001Lab Sample ID: 1704013-014AClient Sample ID: Burgin-TF-1Collection Date: 3/31/2017Received Date: 4/3/2017

Analytical Results




Method: SW8082A


Reporting Limit

CASNumber Qual

MDL







ANALYTICAL REPORT

Audra HeinzelWasatch Environmental, Inc.2410 California AveSalt Lake City, UT 84104

Phone:

E-mail:

(801) 972-8400

[email protected]

Report Date: April 10, 2017

34-1709376Workorder:

Chief 033117ChiefPurchase Order:

Project ID:

Project Manager Rand Potter

Sampling SiteReceive DateCollect DateLab IDClient Sample ID

1709376001 03/31/17AS-1 04/03/17 Chief

Page 1 of 4 Mon, 04/10/17 11:26 AM ENVREP-V4.4

ADDRESS 960 West LeVoy Drive, Salt Lake City, Utah, 84123 USA PHONE FAX+1 801 266 7700 +1 801 268 9992

ALS GROUP USA, CORP. An ALS Limited Company

||

ANALYTICAL REPORT

Project Manager: Rand Potter

Client: Wasatch Environmental,Inc.

Workorder: 34-1709376

Analytical Results

Sample ID: 03/31/201704/03/20171709376001Lab ID:

Collected:Received:

AS-1 Chief

Sampling Parameter: Air Volume 6 LMatrix:Media:

AirSumma 6 Liter Canister

Sampling Site:

Analysis: Sulfur Gases Scan, Air

Analyzed: 04/06/2017 13:42Batch:

Instrument ID:ISCD/1662 (HBN: 188176) Percent Solid: NA

GCE27

Report Basis: Wet

Preparation: Not Applicable

Result (ppm)Analyte RL (ppm) Dilution Qual

Analysis Method - Sulfur Gases Scan

0.0070<0.0070 1Hydrogen sulfide

0.0070<0.0070 1Carbonyl sulfide

0.0070<0.0070 1Methyl mercaptan

0.0070<0.0070 1Ethyl mercaptan

0.0070<0.0070 1Dimethyl sulfide

0.00350.0045 1Carbon disulfide

0.0070<0.0070 1Isopropyl mercaptan

0.0070<0.0070 1t-Butyl mercaptan

0.0070<0.0070 1n-Propyl mercaptan

0.0070<0.0070 1Thiophene

0.0070<0.0070 1Diethyl sulfide

0.0070<0.0070 1n-Butyl mercaptan

0.0035<0.0035 1Dimethyl disulfide

0.0070<0.0070 1Tetrahydrothiophene

0.0070<0.0070 1Sulfur dioxide

Report Authorization

Analyst Peer ReviewMethod

(/S/ is an electronic signature that complies with 21 CFR Part 11)

Sulfur Gases Scan /S/ Lyle Edwards04/10/2017 10:25 04/10/2017 11:22

/S/ Mila V. Potekhin

Laboratory Contact Information(801) [email protected]

ALS Environmental960 W Levoy DriveSalt Lake City, Utah 84123

Phone:Email:Web:


ANALYTICAL REPORT




The results provided in this report relate only to the items tested.Samples were received in acceptable condition unless otherwise noted.Samples have not been blank corrected unless otherwise noted.This test report shall not be reproduced, except in full, without written approval of ALS.

General Lab Comments

ALS provides professional analytical services for all samples submitted. ALS is not in a position to interpret the data andassumes no responsibility for the quality of the samples submitted.

All quality control samples processed with the samples in this report yielded acceptable results unless otherwise noted.

ALS is accredited for specific fields of testing (scopes) in the following testing sectors. The quality system implemented at ALSconforms to accreditation requirements and is applied to all analytical testing performed by ALS. The following table lists testingsector, accreditation body, accreditation number and website. Please contact these accrediting bodies or your ALS projectmanager for the current scope of accreditation that applies to your analytical testing.

Testing SectorAccreditation Body Certificate

Number Website

Environmental ANAB (DoD ELAP)Utah (NELAC)NevadaOklahomaIowaTexas (TNI)

ADE-1420DATA1UT00009UT00009IA# 376T104704456-11-1

http://www.anab.org/accredited-organizations/http://health.utah.gov/lab/labimp/http://ndep.nv.gov/bsdw/labservice.htmhttp://www.deq.state.ok.us/CSDnew/http://www.iowadnr.gov/InsideDNR/RegulatoryWater.aspxhttp://www.tceq.texas.gov/field/qa/lab_accred_certif.html

Industrial Hygiene 101574 http://www.aihaaccreditedlabs.orgAIHA LAP LLC (ISO 17025 &IHLAP/ELLAP)

Lead Testing: CPSC ANAB (ISO 17025, CPSC) ADE-1420 http://www.anab.org/accredited-organizations/Soil, Dust, Paint ,Air AIHA LAP LLC (ISO 17025 &

IHLAP/ELLAP)101574 http://www.aihaaccreditedlabs.org

Dietary Supplements ACLASS (ISO 17025) ADE-1420 http://www.aclasscorp.com

Washington C596-16 http://www.ecy.wa.gov/programs/eap/labs/index.html

(Standard)

Kansas E-10416 http://www.kdheks.gov/lipo/index.html

Washington C596-16 http://www.ecy.wa.gov/programs/eap/labs/index.html


ANALYTICAL REPORT




MDL = Method Detection Limit, a statistical estimate of method/media/instrument sensitivity.RL = Reporting Limit, a verified value of method/media/instrument sensitivity.CRDL = Contract Required Detection LimitReg. Limit = Regulatory Limit.ND = Not Detected, testing result not detected above the MDL or RL.< This testing result is less than the numerical value.** No result could be reported, see sample comments for details.

U = Qualifier indicates that the analyte was not detected above the MDL.J = Qualifier Indicates that the analyte value is between the MDL and the RL. It is also used to indicate an estimated value fortentatively identified compounds in mass spectrometry where a 1:1 response is assumed.B = Qualifier indicates that the analyte was detected in the blank.E = Qualifier indicates that the analyte result exceeds calibration range.P = Qualifier indicates that the RPD between the two columns is greater than 40%.

Result Symbol Definitions

Qualifier Symbol Definitions


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