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Exhibit D -Reclamation Plan <br />22. This item asked aggregate Industries to demonstrate that DIMP and other contaminants that objector Kazen <br />Topper refers to do not exist in the amendment azea or if they do, to demonstrate that the proposed mining <br />and reclamation operations will not mobilize them and contaminate her drinking water to levels above safe <br />Standazds (see Rule 3.1.6(b). Your response was that, according to the South Adams Water and Sazdtation <br />District, Ms Topper's wells were not within the azea of the DIMP plume and [hat since that time the DIMP <br />plume has been further reduced to an azea 3 miles east of Ms Topper's property. You stated that the <br />information was included in your Exhibit F. It was found in your Exhibit E. Please move it to the correct <br />location. You referred to a memo from South Adams County Water and Sanitation District, which says <br />"The District did not install water taps under the Army agreement to 8120E 104`" Ave. (Topper Property) <br />...because they aze not in the DIMP plume. <br />Ms Topper's objection is not that the ground water in the proposed mining azea is contaminated but that <br />contaminants including DIMP were adsorbed onto particles during historic contamination (pre EPA and <br />Army studies) and will be released to the groundwater by excavafion and water level fluctuations due to de- <br />watering. She believes elevated levels of DIMP and other contaminants could move by groundwater flow <br />to her wells. The Division believes that there maybe some merit to this concern. You have not provided <br />documentation that the "adsorbed" contaminants would not be released to the groundwater by the proposed <br />mining operation or that if such contaminants were released to groundwater they would not contaminate the <br />Topper wells. <br />Disaggregation and wetting and drying will occur in the gravel pit pond area during the mining operafion, <br />and any increase in the levels of contaminants would be highest in the pond water. <br />Therefore, if Amendment No. 1 is found otherwise approvable the Division will require the following <br />condition of approval. <br />"No de-watering or extraction activities will occur until Aggregate Industries develops a plan to monitor <br />the gravel pit pond water for diisopropyhnethylphosphonate (DIMP) and obtains approval of that plan from <br />the Division of Minerals and Geology. The plan will include monthly sampling and analysis to begin <br />immediately after de-watering and/or extraction activities are started. The monthly monitoring will <br />continue for one year and then will change to quarterly monitoring, until the Division issues a letter <br />authorizing discontinuance. The plan will include the sampling and analytical methods to be used and an <br />agreement to submit the results of the analysis to the Division within 30 days of the sampling date. The <br />samples will be obtained and analyzed by a company, individual, or agency certified to do the work. If an <br />analysis shows a level of DIIvIP exceeding 8ug/L, Aggregate Industries or its agent will immediately notify <br />the Division by certified mail and include a response plan to deal with the contaminant, and to prevent on- <br />site and off-site damage. If the Division determines from the monitoring data that there is reasonable <br />potential for the operation to cause groundwater quality standazds for DIMP to be exceeded, the Division <br />will notify Aggregate Industries to modify the permit as necessary to comply with Subsection 3.1.7 of the <br />Rules. <br />23. Your answer to this item was "partial de-watering will only occur after an agreement is made with any <br />owners of wells within 600 feet or the State Engineers Office (SEO) approves partial de-watering." Please <br />