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HARLAN & ASSOCIATES, INC. <br /> CONSULTING HYDROGEOLOGISTS AND ENGINEERS <br /> 3900 South Wadsworth Boulevard, Suite 155 <br /> Lakewood,Colorado 80235-2205 <br /> (303)988-7270 • Fax(303)989-8188 <br /> June 3, 1996 <br /> Mr. Walter Avramenko <br /> Colorado Department of Pubic Health & Environment <br /> Hazardous Materials and Waste Management Division <br /> 4300 Cherry Creek Drive South <br /> Denver, Colorado 80222-1530 <br /> Dear Mr. Avramenko: <br /> Re: Mid-Continent Resources - Coal Basin Property: <br /> Environmental Site Assessment Work Plan <br /> This letter transmits on behalf of Mid-Continent Resources, our responses to the May <br /> 8, 1996 comments from the Hazardous Materials and Waste Management Division of the <br /> Colorado Department of Public Health and Environment on the Environmental Site Assessment <br /> Work Plan for Mid-Continent Resources Coal Basin property. For completeness, the Division's <br /> comments are repeated here (in italics), followed by our response. <br /> 1. Commen : The work plan states that "conditional on the result of the initial evaluations, <br /> additional investigations may be proposed if environmental liabilities are identified <br /> through the environmental assessment process'. We wish to emphasize this point by <br /> stating that the Division also views this proposal as an initial step towards fully assessing <br /> environmental liabilities at this site. Considering the size of the facility and the variety <br /> of activities that occurred on-site, we feel that the limited number of environmental <br /> samples to be collected will simply provide an indication of whether contamination may <br /> be present. A follow-up investigation may be necessary in order to better define any <br /> contamination encountered during this initial phase of the site assessment. The Division <br /> believes that additional work will be reauired to better characterize and/or remediate <br /> petroleum contamination known to exist in the vicinity of the Maintenance Shop. <br /> Response: The objective of the initial sampling and analysis program is to identify <br /> potential environmental liabilities associated with the Coal Basin property. It is <br /> acknowledged that additional work may be required to characterize and/or remediate any <br /> environmental problems that are identified including the petroleum contamination known <br /> to exist in the vicinity of the Maintenance Shop. <br /> 2. Comment: The scope of work and tasks presented in the February 29, 1996 work plan <br /> should be modified or refined, if warranted, based on the results of both the review of <br /> the facility's operational history and the field reconnaissance tasks. In the event that <br /> changes are made to the field investigation program, Mid Continent Resources should <br /> notify the Division of Minerals and Geology and the CDPHE of the proposed changes <br />