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Page Two <br /> Division of Minerals and Geology <br /> April 2, 1997 <br /> of water quality in the Main Yard/former Truck Shop area and beneath the Old Refuse <br /> Pile, respectively. The large volumes of water that may be moving through the <br /> subsurface, particularly along the creek and former drainage beneath the flume, could <br /> easily mask localized areas of ground-water contamination. It was for this reason that the <br /> Division originally proposed to Mid Continent Resources, Inc. that they construct and <br /> sample a number of monitoring wells, particularly along the downgradient side of the <br /> property, to better characterize water quality beneath the site. We still recommend this, <br /> especially if the property is to be subdivided and developed into residential properties that <br /> rely on ground water as a drinking water source. <br /> 3) Our May 8, 1996 letter recommended that the possible contamination associated with the <br /> different septic system located on-site be investigated. As discussed above, we do not <br /> believe that the sampling of the seeps along the creek will necessarily characterize water <br /> quality in the vicinity of these other waste disposal units. We stand behind our original <br /> recommendation that either the contents of the septic tank or the soils immediately <br /> adjacent to and beneath the distribution lines be sampled to determine whether an <br /> environmental impact may have occurred at these waste management units. <br /> Your January 6, 1997 letter also poses several questions with regard to the characterization of <br /> wastes for disposal purposes. Unfortunately, the correspondence we received from Harlan and <br /> Associates, Inc. does not include a August 2, 1996 memorandum, nor does our August 2, 1996 <br /> report talk about waste characterization and disposal options. I suspect that what the August 2, <br /> 1996 memorandum is saying is that certain tests may need to be performed on excavated material <br /> for waste characterization(i.e., is it a hazardous or solid waste?) and disposal acceptance purposes <br /> (e.g., verification that it is non-hazardous with a TCLP analysis). Based on the information <br /> contained within the August 2, 1996 and previous reports, hydrocarbons(TPH and BTEX) appear <br /> to be the only contaminants of concern. A RCRA TCLP characteristic test may be required by <br /> the solid waste landfill to verify that the benzene concentrations do not exceed regulatory limits <br /> for a hazardous waste. <br /> The only other precaution we would advise the Division of Minerals and Geology (DMG) to take <br /> with regard to the reclamation of this site, is that a contingency plan be developed and <br /> implemented in the event that a previously unidentified area of contamination is encountered <br /> while restoring the Coal Basin property, such as when the stream channel is excavated through <br /> the facilities area. A plan should be developed to allow the DMG to quickly assess an unplanned <br /> situation and respond accordingly. This plan may be as simple as ensuring that a qualified <br /> individual is present on-site who can recognize a potential problem, have a laboratory available <br /> to characterize contamination encountered, have contacts available to help in the interpretation <br /> of any sampling data, and have a means of managing and disposing of contamination found. <br />