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equipment, natural resources or scrap metal. Operation of the gravel mine will contribute <br />significant resources towards this cleanup goal. <br />This site figures prominently in the City of Fruita and Mesa County's master plan for the <br />redevelopment of this area. This plan was developed by the Fruita Area Economic <br />Development Steering Committee, which included representatives from the City, <br />County, local business leaders, local elected representatives, the Governor's office and <br />representatives of Wayne Allazd's office. Our inability to get this site cleaned up will be <br />a great disappointment not only to the people who worked on the master plan, but also to <br />the citizens who have to live in close proximity to this closed refinery. <br />The traditional methods of regulating this facility will not work if one expects to achieve <br />anything positive. Considering the unique chazacteristics of the site noted above and the <br />high level of interest in its cleanup, the CDPHE has committed considerable resources <br />assisting FMM in the cleanup of the old refinery (we have essentially become FMM's <br />envirorunental consultants, replacing others who's work proved to be both costly and <br />deficient). We have successfully implemented an innovative remediation strategy to <br />overcome the numerous roadblocks that stand in the way of site cleanup, strategically <br />using FMM's limited resources and relying on regulatory flexibility to accomplish <br />health-based cleanups in an efficient and effective manner. This approach relies heavily <br />on the collaborative relationship built up through the years between FMM and the <br />CDPHE. <br />This site has risen to national prominence, the innovative and collaborative approach we <br />have employed being a model for the redevelopment of other brownfields sites across the <br />country. This approach and our successes to date were presented to a national audience <br />this past August at the RCRA National Conference in Washington DC, hosted by the US <br />EPA. This site also attracts great interest from EPA's Brownfields program, which has <br />been very supportive of our efforts (recently providing us with approximately $40,000 in <br />free analytical work to close the Oxidation Ponds so that they maybe mined for gravel at <br />a later date). <br />• Compared to other contamination sites being remediated by the CDPHE, the ground <br />water contamination at the former refinery is comparatively low level. The few pockets <br />of free phase contamination present onsite consist of relatively immobile, weathered <br />hydrocarbon residues confined in places where the hydrostatic pressure has pushed it up <br />against the confining clay layer. The relatively low-level dissolved phase contamination <br />consists of volatile organic compounds that easily biodegrade, thereby limiting the extent <br />of the ground water plume. Based on the information presently available, this ground <br />water contamination poses no risk to human health and the environment. This fact has <br />allowed us to turn our attention to the higher priority task of eliminating source areas and <br />associated soil contamination that do have the potential to pose a risk of exposure. There <br />is little to no contamination at the proposed gravel mining site. <br />• We believe the design and operation of the gravel mine as proposed will be effective at <br />preventing contamination interior to the site from migrating and potentially affecting <br />2 <br />