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other aeeas of the property. The infiltration trench will create a hydraulic barrier for both <br />free phase and dissolved phase contamination. The operation of the trench can be <br />adjusted to either increase or decrease the hydraulic head upgradient of the open pit, <br />depending upon what water level measurements indicate is necessary to maintain the <br />hydraulic barrier. The collection trench within the open pit will effectively recover any <br />low level contamination that may exist downgradient of the trench after gravel mining <br />commences: the anticipated concentrations are orders of magnitudes below the Colorado <br />Dischazge Permit limits issued for the site, and will likely be remediated by aeration <br />during pumping. This activity not only has the benefit of generating funds that can be <br />applied towards the cleanup of other aeeas at the facility, it will also contain/remediate <br />soil and ground water contamination that is known to exist nearby. <br />Our greatest concern is that the imposition of additional monitoring requirements that <br />provide little added benefit will increase FMM's expenditures, taking resources away <br />from other more cost effective remedial efforts (source reduction). The worst case <br />scenario is that the monitoring requirements become so burdensome that it either prevents <br />the cleanup of other areas, or it no longer makes it cost effective to pursue the mining <br />option, potentially killing the deal and thereby eliminating another source of revenue that <br />would go into the cleanup escrow account. If the prospects of cleaning up the site for <br />future redevelopment are dimmed, there is also the potential that FMM may decide that it <br />is no longer worthwhile doing anything with the property. The likelihood of having <br />another property owner come in and cleanup the site if FMM were to abandon it is low. <br />No one benefits from this alternative. <br />Terry is in the process of revising the Waste Management Contingency Plan (WMCP) to address <br />your concerns, as expressed in your letters dated August 19, 2003 and September 24, 2003, and <br />as communicated to us in our recent telephone conference call. Implementation of the revised <br />mining plan as designed, and management and monitoring of contaminated media during mining <br />as required in accordance with the WMCP and the Colorado Dischazge Permit, should allow <br />mining to proceed with little chance of adverse impact. We therefore believe that gravel mining <br />is appropriate for the site, can proceed and be managed in an environmentally sound manner <br />under this revised plan, and that the operations will not only aid the overall cleanup of the <br />refinery, but will be beneficial to the community and the State in general. <br />