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iii iiiiiiiiiiiu iii <br />COLORADO DEPARTMENT OF HEALTH <br />Dedicated to protecting and improving the health and <br />environment of the people of Colorado <br />4300 Cherry Creek Dr. S. Laboratory Building <br />Denver, Colorado 80222-1530 4210 E. 11th Avenue <br />Phone (3031 6922000 Denver, Colorado 80220-3716 <br />(303) 691-4700 <br />June 29, 1994 <br />COLORADO <br />JUL 51994 <br />Dia~is'on of P,llnetais es Geo'coy <br />Carl 13. Mount, Senior Environmental Protection Specialist <br />Colorado Division of Minerals and Geology <br />1313 Sherman, Room 215 <br />Denver, CO 80203 <br />Of CO <br />Ne/ <br />.~. <br />~rB 16~ <br />Roy Romer <br />Governor <br />Patricia A. Nolan, MD, MPH <br />Executive Diretlnr <br />Western Aggregates, Inc. Gonda/MCRay <br />Permit No. M-91-035 <br />Dear P4r. Mount: <br />The Colorado Department of Health (CDH) would like to provide <br />comments on the amendment to the above application to conduct <br />gravel mining operations in the buffer zone of the Rocky Flats <br />Plant in Jefferson County, Colorado. <br />Our general concerns center around decisions to expand operations <br />in tYte buffer zone without the Department of Energy (DOE) <br />completing an evaluation of the suitability of this activity in <br />regard to existing contamination, future site use, and proximity to <br />plant operations. We recommend that the application process be <br />interx•upted until this evaluation is completed and reviewed by <br />involved agencies and the public. <br />Each cf these general concerns is explained below, followed by some <br />specific technical concerns: <br />Existi.nq Contamination <br />The a~>plication discusses sampling of surface soils conducted by <br />the applicant in 1990, and compares the results to a soil standard <br />used :Eor off site development activities. The location of the <br />propo~:ed operation within a Superfund site may require other <br />assessment, including an assessment of the risks of the operation <br />to workers and the general public. <br />The process for decisions on the leasing or sale of federal <br />properties that are Superfund sites includes the provisions of the <br />Commur,.ity Environmental Response Facilitation Act (CERFA), which <br />require certification by the Environmental Protection Agency (EPA) <br />that the property in question is clean. <br />In addition, DOE has designated this area as a reference site to <br />allow comparative evaluation of ecologic impacts and contamination <br />