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located approximately 2000 feet to the east during the pit pumping. For this reason, no additional <br />well testing is proposed for this permit. <br />Elam Construction, Inc. permitted a gravel mine site directly down gradient from the plumes and <br />in areas that have known contamination (south of the refinery buildings). The CDPHE has <br />allowed the Elam pit to occur, and a strict Waste Management Contingency Plan was developed <br />to address any waste (solid or liquid) or contaminated water encountered during the extraction <br />process. If any is found, the procedures outlined in the Waste Management Contingency Plan <br />will be in effect. The Colorado Department of Public Health and Environment (CDPHE) has <br />worked for years with the landowner, FMM, in analyzing the contamination on the site and <br />developing the plan to allow gravel mining based on the levels of risk found, knowing that the <br />gravel mining will require pumping of water from the pit A discharge permit has also been <br />issued for the Elam mining operation. <br />Given the fact that the CDPHE has approved gravel mining (Elam) in an area which is known to <br />have some contaminated soil and groundwater, as well as directly down gradient from known <br />hydrocarbon plumes, it is certain that gravel mining should be allowed to occur 2000 feet to the <br />east, which is up gradient from the contamination and should not draw it to the east as a result of <br />pumping. <br />United agrees to work with the CDPHE and notify them of the start of pumping, the location and <br />flow rates. If monitoring wells on the FMM site show any problem with contaminant movement, <br />United will work with the CDPHE and the DMG to address the issue. <br />6. Water Information, Rights and Augmentation <br />All water rights issues such as availability of water for this operation, consumption rates, dust <br />control, etc. are presented in Exhibit G - Water Information. <br />15 Road Pit May 14 D -10 <br />