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These uses include: <br /> • exterior building viewing, <br /> • limited, controlled interior building viewing (limiting visitors to staged interior- <br /> viewing platforms along the building's perimeter), <br /> • and controlled interior building viewing (platform and railed guided walkways <br /> through the building interior). <br /> The Town and the County agree that regardless of the selected future use, the administrative <br /> steps (summarized above) required to achieve this goal are similar. The following sections <br /> summarize the proposed steps that make up the remediation component of this project. <br /> Baseline Evaluation <br /> As you have succinctly stated in your March 31, 2017, correspondence: <br /> "Remediation and reclamation of the site are challenging since it was operated <br /> primarily as a lead/zinc mill. High levels of lead dust are presumed to exist in the <br /> building and surrounding site. Compounding this is the age of the structure and the <br /> use of lead paints within the building. Informal discussions between Newmont and <br /> Division staff indicate that some preliminary sampling has occurred. However, to <br /> date, no formal report has been submitted to the Division, and therefore no baseline <br /> numerical evaluation of the lead issue has ever been established. It will be essential <br /> for the Division to know what the current lead levels are prior to contemplating any <br /> proposal to change the post-mining land use. A Phase I Environmental <br /> Assessment/Audit, or something comparable, will be required to document the <br /> baseline lead and other metals levels prior to moving forward with the proposed <br /> postmining land use change." <br /> The Town and the County agree that this step is fundamental to any decision regarding the <br /> development of a remediation strategy. As one would expect for a project of this size, <br /> complexity, and significance, the implementation of the site characterization tasks will be <br /> preceded by the development of a comprehensive work plan. The components of the work <br /> plan will be designed to result in a representative, defensible, and complete characterization of <br /> the building's conditions. <br /> Regulatory Cleanup Requirements <br /> The plan presented in this letter only focuses on the dust, sediment, and loose soil-like <br /> material within the Mill and auxiliary structures. There are several other issues to be <br /> considered related to public safety at this facility including building stability, lead-based <br /> paint, trip/fall hazards, sharp objects, etc. Those are topics for additional investigation and <br /> remediation(if necessary). <br /> As part of this evaluation, we sought guidance from Colorado regulators to establish <br /> applicable standards that could apply for the Mill remediation. Initially, we approached the <br /> Division. In discussions with Mr. Russ Means of DRMS, we were informed that there are no <br /> numeric standards in place in the DRMS regulatory structure. Any standards to be applied to <br /> 2 <br />