2017-03-31_GENERAL DOCUMENTS - M1977403HR

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COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 March 31, 2017 Larry Fiske Newmont Mining P.O. Box 584 Ouray, CO 81427 Re: Idarado Mine,Permit M1977403HR,Potential Preservation of Pandora Mill Dear Mr. Fiske, The Division of Reclamation, Mining and Safety (Division) appreciates being involved in the discussion regarding the possible preservation of the Pandora Mill. Over the past year there have been discussions as to what potential future uses the site may include. The latest iteration has focused on possible preservation of the Mill building and a few auxiliary structures for exterior viewing purposes to support historical tourism. The Division is not opposed to this option however, we feel that it would be prudent to discuss what administrative steps will be required to facilitate remediation,reclamation, securing access, and long term maintenance in order to secure release of these structures from the remaining permitted area. Remediation and reclamation of the site is challenging since it was operated primarily as a lead/zinc mill. High levels of lead dust are presumed to exist in the building and surrounding site. Compounding this is the age of the structure and the use of lead paints within the building. Informal discussions between Newmont and Division staff indicate that some preliminary sampling has occurred. However, to date, no formal report has been submitted to the Division and therefore no baseline numerical evaluation of the lead issue has ever been established. It will be essential for the Division to know what the current lead levels are prior to contemplating any proposal to change the post-mining land use. A Phase 1 Environmental Assessment/Audit, or something comparable, will be required to document the baseline lead and other metals levels prior to moving forward with the proposed post-mining land use change. Only after a report is generated and evaluated can Newmont and the Division discuss remediation and reclamation feasibility towards achieving lead levels that would limit exposure liability to meet the expected post-mining land use. Under this scenario exterior lead levels would be a primary concern and maximum allowable lead dust exposure levels will need to be achieved through normal reclamation as the site will be readily accessible to the public. It needs to be clearly stated that if the best achievable lead limits would still present an unacceptable risk to human health and the environment, then removal of the structure and remediation and reclamation of the area will be required. The Division also has a concern as to if the mill can be secured and maintained to deny reasonable interior access by the public, not only at the time of release, but into the future. The Division would need documentation of the agreement between Newmont and the City/County regarding transfer of ownership and assumption of security and maintenance obligations. Specifically, the Division would need OF.c O 1313 Sherman Street, Room 215, Denver,CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us *r 5> in 01 John W. Hickenlooper, Governor I Robert Randall, Executive Director I Virginia Brannon, Director •rays