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III IIIIIIIIIIIII III 999 • • STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman 51., Room 215 Denver, Colorado 80203 Phone: (3071 866-3567 f Sete}r~~e~-"~°, ~I 998 Mr. Scott Hoover B & B Excavating, Inc. Drawer 249 Vad, CG 81658 RE: Draft Sampling and Analysis Plan, Montgomery Pit, Permit No. M-86-104 Dear Mr. Hoover: ~. ~~ DEPARTMENT ~' NATURA~~ RESOURCE~f Roy Romer Governor lames 5 Lochhead Etecwive Direcor michael B. Long Division Director The Division of Minerals and Geology (DMG) has completed a review of the "Draft Sampling and Analysis Plan for the Montgomery Pit Facility" (SAP) prepared by Dames and Moore and submitted to DMG on December 18, 1998. The following issues remain to be addressed to the satisfaction of DMG prior to implementation of the SAP. 1. On page 8 of the SAP a listing is provided of the media potentially affected by the chemical releases. The followine media, not included in the SAP listing, may also have been affected: Soils under the''/z inch road base pile Soils under the'/a inch road base pile Soils under the'/s inch rock pile Although these media may have been affected, the DMG will not require characterization of these soils as part of the SAP. If the results of the chazacterization of the soils under the original minus 3/a inch road base stockpile show contamination, or if contamination is found in the surface or ground water (see item 8 below), the DMG may require characterization of the additional three soil azeas listed above.. (Note that this item #1 is a point of clarification rather than an issue to be addressed to gain approval of the SAP; B and B need only register their concurrence or present any azguments against this item at this time). 2. It is stated on page 10 of the SAP that the 2,4-D concentration present in the sample taken from the minus''/z inch road base pile "was below regulatory limits that would require treating the pile as a hazardous waste." It is stated on page 19 of the SAP that preliminary results indicate that the''/z inch road base "will most likely be regulated as non-hazardous, petroleum affected soils." Presumably, the basis for these statements is that the RCRA land disposal restriction level for 2,4- D is IO mg/Kg. I-rowever, environmental media with contaminant concentrations below the RCRA land disposal rest fiction level may still require special handling and disposal in order to protect ground and surfa a water quality. Upon conclusion of the complete characterization of the contaminated env ronmental media at the Montgomery Pit through the implementation of the SAP and any required dditional measures, a plan must be developed for DMG approval describing a