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t <br />= PnRl1GON <br />CONSULTING GROUP <br />SENT VIA CERTIFIED MAIL <br />Certified Number 7002 2410 0007 8773 3096 <br />March 11, 2003 <br />°SERVICE, QUALITY, AND INNGVATIGN° <br />RECEIVED <br />MAR 13 2003 <br />l~Is. Kate Pickford <br />Colorado Division of Minerals and Geology <br />1313 Sherman Street, Room 21~ <br />Denver. Colorado 80203 <br />Division of Minerals and Geology <br />RE: Soil Contamination/Request for Site Closure <br />Aggregate Industries F Street Facility (83`a Joint Venture Pit) <br />409 P Street. Greeiev. Colorado <br />Project Number 1001018 <br />DMG Permit No. ?VI-1992-069iTechnical Revision 003 <br />Dear Ms. Pickford: <br />1107 Oak Park Drivq Suia 110 <br />Fort Coxh,e, CO 80525 <br />Phone (9]O) l]]d600 <br />Fu 19]0) l]LI880 <br />wxr.Pa.eR000R.eum <br />Dnvm M. Rnu, P.&, DEE <br />Scorn A. Rurxmroan, P.E. <br />BRICK SMITH, P.E. <br />JnMCS M. Txomns, P.E. <br />RRAU e. WOHLER <br />SreveN A. Mware, P.E. <br />AMr D. WeRRR, E.LT. <br />HR.sTxeR S. AlnRlw.w <br />IrArHLEEN S. TxeISRN, E.I. <br />The purpose of this letter is to provide additional information to the Division of Minerals <br />and Geology (DMG) regarding soil contamination at the above-referenced site. The <br />approximate location of the site is shown on Figures 1 and 2 which are attached to this <br />report. <br />As you know. Aggregate Industries originally planned to excavate additional impacted soil <br />resulting from the 2001 diesel-fuel release prior to cessation of dewatering activities as <br />described in 'T'echnical Revision 003. In a letter dated November 13, 2002 to the DMG, <br />Aggregate Industries requested a waiver of that requirement since impacted soil that <br />remained at the site after the previous abatement activities had not impacted groundwater as <br />c~~~iderlced by the five (5) groundwater sampling events performed at the site between July <br />201)1 and July 2002. In a letter dated November 22, 2002, the DMG stated that the <br />additional soli excavation activities would still have to be performed or a new Technical <br />Revision could be submitted for additional groundwater monitoring after cessation of <br />dewatering. <br />.Aggregate Industries requested that Paragon Consulting Group, inc. (Paragon) evaluate the <br />potential effect of the remaining soil contamination on groundwater quality at the site. The <br />basis for this evaluation is similar to the risk-based corrective action (RBCA) currently used <br />by the Colorado Department of Labor and Employment Division of Oil and Public Safety <br />(OPS). Effective February 1, 1999, the OPS incorporated a RBCA approach for evaluating <br />petroleum impacted sites regulated under their program. The computer model BP RISC is <br />approved by the OPS for risk modeling at petroleum hydrocarbon impacted sites. <br />ENVIRONMENTAL ENGINEERING AND GEOHYDROLOGY <br />