Please find enclosed the Operational Unit 2 (OU2) Lincoln Park Water Use Survey plan for your review.

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1 April 7, 2008 Mr. Jeff Deckler, Program Manager Remediation Program Hazardous Materials and Waste Management Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado Dear Mr. Deckler, Please find enclosed the Operational Unit 2 (OU2) Lincoln Park Water Use Survey plan for your review. As you are aware this plan has been formulated and modified based on comments from the EPA Five-Year groundwater technical advisory group consisting of EPA, CDPHE and Cotter representatives and the Community Advisory Group (CAG). To insure the compatibility and reliability of the data, the Cotter Corporation Canon City Milling Facility Laboratory will do the analytical work. To accomplish the analysis inhouse, we request that the timeframe for delivery of samples to the owners be 90 days and also that the second quarter 2008 quarterly water sample report now be due September 30, The proposed schedule of activities to complete this plan is quite aggressive and is temporally dependent on procuring a contractor and cooperation of the affected community. Therefore the schedule should be considered tentative. In that regard Cotter has been in contact with both Colorado State University Ft. Collins and Colorado State University-Pueblo to explore a partnership to accomplish this effort. We would like to meet with you and the Colorado State University representatives at your earliest convenience to determine the feasibility of that partnership on a technical and practical level. Please contact me at extension 212 or by at jim.cain@cottercc.com if you have questions and to schedule a meeting.

2 Sincerely, Jim Cain, Environmental Coordinator/Radiation Safety Officer Cc: Mr. Steve Tarlton Mr. Edgar Ethington Mr. John Hamrick Mr. Amory Quinn Mr. Craig Harlin Mr. Gus Gaviotis Mr. Thomas Johnson, Ph.D. Colorado State University-Fort Collins Mr. Perry Cabot, Ph.D. Colorado State University-Pueblo Ms. Pat Smith, EPA Remediation Program Manager, Lincoln Park Superfund Site

3 OPERATIONAL UNIT 2 (OU2) LINCOLN PARK WATER USE SURVEY Introduction and Purpose Cotter Corporation performed a water use survey entitled Lincoln Park Water Use Survey in the Lincoln Park Study area in 1989 pursuant to Section 13.2 of the Remedial Action Plan (RAP). This survey was conducted for Cotter Corporation Canon City Milling Facility (CCMF) by Intermountain Soils Inc. Relative to the First Five-Year Review Report for Lincoln Park Superfund Site Operable Unit 2, Fremont County Colorado, September 2007, U.S. Environmental Protection Agency, Region 8 Denver, Colorado, the Environmental Protection Agency (EPA) required that an updated water use survey be performed. The Colorado Department of Public Health and Environment (CDPHE) is the lead agency for the RAP. The survey is the combination of an interview questionnaire and sampling of the water source(s). Survey results will be reported and made available for public review. The purpose of the original survey was to (1) inventory water users, (2) identify and locate domestic and commercial well uses and (3) offer city water connections to those not connected. The purpose of the present survey is to update the previous survey relative to changes in the boundary of the potentially affected area resulting from revised water quality standards from the Colorado Water Quality Commission, Regulation 41, for uranium and molybdenum which are effective May 31, A public outreach campaign will be used to provide early identification of owners/residents who are not connected to city water. Priority will be given to those residents who are currently using groundwater domestically, and they will be interviewed first with samples collected at the earliest opportunity. Based on use and seasonality a second sampling may be conducted. Following the identification of those not connected to city water, owners/residents will be offered connection to the city water supply at Cotter s sole expense based on the RAP criteria. Those owners deemed qualified to receive connection to city water will be scheduled for hookup. Completion of the hookup to city water will be reported to CDPHE via separate correspondence. The survey will be conducted in two phases. Phase I of the survey will be to interview owners/residents of the study area and Phase II will be to sample groundwater sources identified in the interview. Analytical results will be provided to owners/residents within 45 days of receipt from the laboratory, with the goal of ninety (90) days from the time the samples are submitted to the laboratory for analysis. Phase III of the survey will be to interview and sample groundwater sources outside the proposed boundary if uranium

4 and/or molybdenum concentrations from groundwater sources near the proposed boundary are above the standards. A summary report of the interview questionnaires and analytical data will be provided to CDPHE. Boundary of Area (attached maps) The proposed boundary for the present study was devised to encompass any potentially affected area outside of OU1 (CCMF) which may fall into OU2. Maps showing the molybdenum plume (figure 1) and the uranium plume (figure 2) are based on 2007 average data. The proposed boundary of the study area was agreed upon by the EPA Five-Year groundwater technical advisory group consisting of EPA, CDPHE and Cotter Corporation. Identification of Wells/Springs Cotter will compile a list of survey area property owners and residents from several sources of information including previous water use surveys, the State Engineer Office Records, local telephone directory, Fremont County Property tax records, and records of the Canon City Water Department. A list of potential well and spring users will be made. Notification Method to Property Owners/Residents Cotter will notify the affected property owners/residents by multiple means. Initial community notification will occur as a Public Outreach which may consist of assistance from the print and broadcast media such as the Daily Record newspaper and KRLN/KSTY radio station. The Community Advisory Group will also be utilized to disseminate the details of the survey plan. As noted above, a primary goal of the Public Outreach will be to identify those not connected to the city water supply. The secondary goal will be to inform owners/residents of the purpose of the survey and what they can expect during the interview and sampling process. Owners/residents will be sent, by regular mail, a letter of notification and survey explanation with the request to fill out and return an enclosed post card requesting information regarding well/springs and contact information. Telephone canvassing will occur to verify the information received from the notifications and to schedule appointments to conduct the interviews and collect water samples of the groundwater sources.

5 Interview Questionnaire (Attached) The questionnaire is designed to determine wells and springs in the study area, private and commercial uses, number and demographics of users, timeframe of uses and, in particular, whether the resident is connected to the city water supply. Sample Collection and Sample Custody Water samples will be collected in a manner equivalent to CCMF Radiation Protection Plan Procedures (RPPP) EV- 40 Water Quality Monitoring, EV-41 Measurement of ph of Water Samples, EV-42 Measurement of the Electrical Conductivity of Water Samples, EV-43 Water Level Measurements, EV-44 Sampling Equipment Decontamination, and EV-45 Oxygen in Water. Sample Custody will be handled in a manner equivalent to the Quality Assurance Program Plan (QAPP) for the Cotter Corporation Canon City Mill Environmental Sampling and Monitoring Studies section 7 Sample Processing. Analytes (Constituents of Concern (COCs)) Analysis of water samples will be done equivalent to Cotter Corporation Canon City Milling Facility Laboratory Analytical Procedures: SOP 1-1 Conductance SOP 1-2 ph SOP 1-4 Residue, Non-Filterable (TSS) SOP 1-5 Residue, Total (TDS) SOP Iron (Fe) by AA using Direct Aspiration, SOP Molybdenum or Selenium (Mo or Se) by AA using Graphite Furnace, SOP Calcium (Ca), Iron (Fe), Potassium (K), Magnesium (Mg), Manganese (Mn), Molybdenum (Mo), Sodium (Na) and Vanadium (V) by AA using Direct Aspiration, SOP 4-3 Alkalinity (Titrimetric, to ph 8.2 and 4.2), SOP 4-9 Chloride (Titrimetric, Mercuric Nitrate), SOP 4-10 Nitrate (Chromotropic Acid Method), SOP 4-12 Sulfate (Gravimetric), SOP 5-2 Gross Alpha and Beta Measurements of Soil, Water, and Other Matricies, SOP 5-5 Uranium Measurement by Kinetic Phosphorescence, SOP 5-9 Radiochemical Procedure for Radium-226/224, Isotopic Thorium, Isotopic Uranium, Polonium-210 and Lead-210. The following is the list of field and laboratory measurements which will be analyzed for the water samples collected. Based on historical evidence and literature citations regarding mobility of uranium decay chain radionuclides, gross alpha will be tested on all

6 samples. The alpha particle activity for uranium will be calculated and subtracted from the gross alpha for each sample. If the resulting alpha particle activity exceeds the Colorado Water Quality Commission Regulation 41, Table 1, Domestic Water Supply - Human Health Standard, of 15 pci/l, then 230 Th, 226 Ra, 210 Pb, and 210 Po may be analyzed later. Uranium speciation, that is analysis for 238 U and 234 U may be done later for further plume delineation. The radionuclide analysis may be done based on the recommendation of the EPA Five-Year groundwater technical advisory group. Test Test Description LLD's Units Symbol Alk Alkalinity, measured in the lab. 10 Milligrams per liter, mg/l Ca dis Calcium, dissolved 1 Milligrams per liter, mg/l Cl Chloride 3 Milligrams per liter, mg/l CO3 Carbonate 10 Milligrams per liter, mg/l DTW Depth to Water 0.01 Feet DTW RL Depth to Water after recovery 0.01 Feet F Cond Specific Conductance, measured in field 0.5 Micromhos, µmhos Fl Rate Flow Rate Cubic feet per second, CFS F ph ph measured in the field Hydrogen-Ion Activity Gross Alpha Particle Activity, dissolved 5 Picocuries per Liter, pci/l Alpha Gross Beta Particle Activity, dissolved 5 Picocuries per Liter, pci/l Beta HCO3 Bicarbonate 10 Milligrams per liter, mg/l K dis Potassium, dissolved 0.3 Milligrams per liter, mg/l L Cond Specific Conductance, measure in lab. 0.5 Micromhos, µmhos L ph ph measured in the laboratory Hydrogen-Ion Activity Mg dis Magnesium, dissolved 1 Milligrams per liter, mg/l Mo dis Molybdenum, dissolved Milligrams per liter, mg/l Mo sus Molybdenum, suspended Milligrams per liter, mg/l Na dis Sodium, dissolved 5 Milligrams per liter, mg/l NO3 Nitrate 0.5 Milligrams per liter, mg/l Pm Rate Pump Rate Gallons per minute, gpm SO4 Sulfate 5 Milligrams per liter, mg/l TDS Total Dissolved Solids 10 Milligrams per liter, mg/l Temp Temperature, measured in field Degrees Celsius TSS Total suspended solids 10 Milligrams per liter, mg/l U dis Uranium, dissolved Milligrams per liter, mg/l U sus Uranium, suspended Milligrams per liter, mg/l Lower Limits of Detection (LLDs) Lower Limits of Detection will be as in Table 1 above and in concert with Appendix B of Cotter Corporation Radioactive Materials License (RML)

7 Schedule The schedule shows the timeframes expected to conduct the activities. Every effort will be made to complete the work as expeditiously as possible. 1. Submit plan to CDPHE April 7, CDPHE Plan Approval 7 days after submittal 3. Select contractor for work 30 days after plan approval 4. Identify water users and conduct Public Outreach Program 30 days after contractor selected 5. Conduct interviews and collect samples from respondents not connected to city water. Offer connection to city water and provide preliminary data 21 days after start of interviews 6. Conduct interviews and collect samples from all other water users including outside starting boundary as necessary 90 days after start of interviews 7. Provide all data to water users 90 days after samples received in laboratory. 8. Submit summary report to CDPHE December 31, 2008