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• i <br />At the last meeting with EPA, Mr. Wangerud indicated that he personally had determined <br />there may be an imminent environmental threat to the Rio Grande due to instability of a <br />waste rock crib wall at the Nelson-Commodore complex. In his opinion, if the crib wall fails, a <br />high sediment load would result that could wipe out fisheries in the Rio Grande. Although <br />there are rumors that Mr. Wangerud may have developed a presumptive remedy - to install a <br />water treatment plant at the Nelson-Commodore complex -this is apparently not correct. <br />There was no coroboration of Wangerud's observations or conclusions. For instance, it is <br />not known whether tailings are stored in the Commodore waste rock pile; without such <br />tailings, the threat of high sediment Toad to the Rio Grande is dubious. Also, the notion that <br />zinc may be coming from the Commodore waste rock, though plausible, lacks credible direct <br />evidence. Even so, if environmental improvements were to be made to the system, a <br />qualitative cost-benefit assessment would not be very favorable. A water treatment plant, <br />operated over several tens of years, would cost tens of millions of dollars while benefit would <br />be realized mostly in just 1 ~/< miles of lower Willow Creek. <br />EPA Region VIII supervisor, Barry Levene, observed the State's clear incentives not to list the <br />Creede site on the NPL. He concluded that EPA would re-evaluate its position, including the <br />possibility they would forego any further investigations of the Creede site. DMG may likely <br />participate in stabilization of the Commodore-Nelson waste rock crib wall using Non-Point <br />Source funding. However, as it currently appears, further EPA-backed investigations will not <br />go forvvard. <br />DMG has agreed to keep EPA informed of our regulatory actions at the bulldog, but I would <br />anticipate no further EPA action there in the near future. <br />• Page 2 <br />