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In a very similar situation to the Pandora Mill, the Paris Mill, it was determined that the <br /> predominant COC was lead, and the receptor of greatest exposure was an on-site worker <br /> (document referenced above). In addition, CDPHE concluded in the Targeted Brownfields <br /> Assessment, Analytical Results Report, Phase II Environmental Site Assessment for the Ute <br /> Ulay Mine and Mill site in Lake City, Colorado (July 2012) that while arsenic and lead were <br /> the predominant contaminants of concern, that all remedial decisions would be based on lead <br /> for the cleanup standard for the site. <br /> Based upon this evaluation, we believe that to meet any of these criteria effectively; it is <br /> expected that remediation would generally include: <br /> • gross cleaning and removal of soil, dust, sediment, and debris from the Mill and <br /> ancillary building interiors (including proper characterization/disposal of collected <br /> material), <br /> • pressurized cleaning of all surfaces (including collection, treatment, and/or proper <br /> disposal of collected materials), and <br /> • confirmation sampling and analysis. <br /> Subsequent encapsulation of exposed soils remaining in the Mill or other surfaces may be <br /> necessary (depending on the specific use of an area for tour purposes or for worker access and <br /> egress), via the additional application of an encapsulation product. <br /> Based upon what is known today, the Town and County recommended that the cleanup <br /> standard is based on lead and that a reasonable initial cleanup goal should be 1,000 mg/kg <br /> which is the level that BLM has established for a camper (exposed to sediment) RMC. Per <br /> BLM, as long as people are not exposed to metal concentrations exceeding the RMC,they are <br /> not expected to experience adverse effects. Assuming the remediation parameters noted <br /> earlier, it is expected that the cleanup goal of 1,000 mg/kg of lead would be met in most areas. <br /> In the Paris Mill, a similar remediation method was deemed acceptable for a Voluntary <br /> Cleanup per CDPHE (document referenced above). The only difference is we propose a <br /> pressurized cleaning versus a steam cleaning, and that the cleanup goal is based on BLM <br /> standards instead of CSEV standards. <br /> Subsequent Administrative Steps <br /> As you have outlined in your March 31, 2017, letter to Idarado, the subsequent administrative <br /> steps necessary to achieve the preservation on the Pandora Mill and release it from the permit <br /> area would include: <br /> "Submittal and approval of an amendment to change the post mine land use for this <br /> area of the DRMS peiinit from wildlife habitat to historic tourism. The amendment <br /> shall also include: <br /> a) Info'illation that addresses the method of remediation of the mill interior to <br /> an agreed upon lead limit and include safeguarding to prevent reasonable <br /> public access. <br /> 4 <br />