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~ iiiiiiiiiiiiiiuiii ~ <br />STATE OF COLORADO <br />Roy Romer, Governor r- <br />Pani Shwayder, Acting Executive Director ~ r ~ F j`\~ F 11 <br />Dedicated [o protecting and improving (he health and environment o![he people of Crolorado !, <br />4300 Cherry Creek Dr. 5. Laboratory Building ApR 1 p lgg5 <br />Denver, Colorado 80222-1530 4210 E. 11th Avenue <br />Phone (303) 692 2000 Denver, Colorado 802 2 0-3 71 6 <br />(3031691.4700 <br />Mr. Berhan Keffelew <br />Division of Minerals and Geology <br />Departrctent of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />pivision of minerals & neology <br />April 6, ]995 <br />Of COlQf <br />„e~ <br />• ~ a <br />r <br />~ rBi6 ~ <br />Colorado Deputment <br />of Public Health <br />and Environment <br />RE: Western Aggregate, Inc. <br />Section ]6 mine; permit #M 94 045 <br />Bluestone Mine; permit #M91 035 <br />Dear Berhan: <br />Thank you for the opportunity to review WAI, Inc. responses to your agency's comments on the <br />Bluestone and Section 16 Adequacy Review. <br />Previously we stated in our letter of August 1, 1994 to Carl B. Mount on WAI, Ines <br />f~ection 16 Mine: permit #M 94 045 and Bluestone Mine; permit # M 91 035; "The <br />process for decisions on the leasing or sale of federal properties that are Superfund sites <br />includes the provisions of the Community Environmental Response Facilitation Act <br />(CERFA), which require certification by the Environmental Protection Agency (EPA) that <br />the property in question is clean..." It is still our understanding that this certification has <br />riot been made either by EPA or DOE. <br />At this time there is no conservation plan in place at Rocky Flats Environmental <br />Technology Site (BEETS) to protect and sustain the biological resources. The ecological <br />system has not been described and integrated into a plan for the conservation and <br />preservation of this resources. <br />On February 27, 1995 LeRoy Carlson, of the Fish and Wildlife Service (FWS) issued a <br />letter to Western Aggregate, Inc detailing their concerns. The details cited in the FWS <br />letter, refer to many of the issues that need to be understood to prepare and implement a <br />conservation plan for the area. At this time, neither the assessment endpoints nor the area <br />of concern are delineated that are needed to implement a conservation plan at RFETS. <br />\~Vithout these relevant endpoints/set points neither the yardsticks to measure impacts of <br />the mining, simulated changes due to the proposed mining nor the monitoring needed for <br />ongoing mining operations can be evaluated properly. <br />