2008-05-01_REVISION - M1973007SG (5)

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MINING PLAN J PROPERTY MINING PLAN: This small three acre parcel of land requires some special timing considerations. Between the current affected land boundary north of the J Property and the J Property itself is the groundwater remediation treatment facility. This facility not only includes the treatment ------------ plant but a number of pipelines that connect extraction wells with the plant and other pipelines that connect the plant to the injection wells along Bradley Road. Clearly, to mine the J Property will require mining through the treatment facility location. Ts ,))09 The mining of this area itself is actually no different than mining anywhere else. But until f mining can proceed in the specific area one of two events must occu Either the remediation program plant and pipelines must be relocated or mining must wait until the remediation program is completed. t this point in time it appears the remediation program wi be completed in three to five yews (late 2 10 to late 2012 or early 2013). Considering the amount of time that will be required to mine the North Area plus the Little Johnson Reservoir location, it would not be unreasonable to assume that the J Property will not be mined until thme diction program is completed and the facilities removed. However, in accordance with the agreement between the remediation program and Transit Mix Concrete (the physical operator of the Daniels Sand Pit), Transit Mix can request the facilities be moved with 60 days notice. Although this could be done if necessary, the timing of the completion of the remediation program does not appear to present a problem with waiting until completion to avoid the additional costs to Schlage Lock who is funding the remediation. The problem presented with relocating the facility is significant in that a location must be found near the current site and new pipelines must be installed to connect with the wells. At this time, in the event this alternative must be taken, it is not known where the new location would be. That, of course, presents a problem in that these relocated facilities would most probably be within 200 feet of the affected land. The possibility therefore exists that the mining could theoretically affect the stability of the remediation program facilities. Either it would need to be demonstrated that would not occur or an agreement to repair any damages would be needed. In consideration of the fact that the remediation program is being regulated by the Environmental Protection Agency and the Colorado Department of Public Health and Environment, there would undoubtedly be considerable oversight of any stability issues. It is notable that the current facilities are within 200 feet of the affected land and no problems have occurred. Nevertheless, relocation might affect the situation with the current arrangement being stable but the future arrangement (after relocation)unstable. It seems reasonable that there would be extensive consideration of the effects of nearby mining of sand on any new location and, if there was a hazard, the plans for either the location of the new facility or the mining nearby or both would need to be changed. [-,--lit is requested that for now, the mining plan be allowed to incorporate the J Property under he primary consideration that mining will not occur until the remediation program is completed so ,WQi Is Sand Pit Amendment (2008) Exhibit D Page 18 of 28 Saj M 4 l f o .n