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Page 2 of 3 pages A fairly detailed discussion followed concerning the safety and appropriateness of disposing of waste; rock, waste ores and mill processing wastes (tailings) by placing them back into mine shafts and tunnels. Mr. Otten and Rick Brown were the major participants in this discussion. Then discussion turned to the inter-relationship of CERCLA remedial activities and the state's solid waste regulations. Pam Harley assured Mr. Otten and Mr. Schurman that the state's solid waste and mined land reclamation programs were making every effort to avoid duplication of permitting and to increase the consistency of the technical requirements applied to similar sites under each agencies' jurisdiction. She told Mr. Otten and Mr. Schurman that the regulated community as a whole considered fairness and a "level playing field" to be very significant issues when comparing the closure and monitoring requirements imposed at mine waste sites and at other commercial and industrial waste sites. Mr. Otten and Mr. Schurman expressed specific concerns about the cost of disposing of wastes at Last Chance. They were assured by both Rick Brown and Pam Harley that other appropriately approved and permitted sites including CSI and Solution Gold would be allowed to receive the tailings if off-site disposal were selected as the closure method by the owners/operators. The neat concern voiced by Mr. Otten and Mr. Schurman was the need for a solid waste disposal permit for Golden Gilpin Mill closure. Pam Harley assured them that, if on-site closure was the option selected by the owners/operators, the site could be closed under the provisions of existing MLRD permit and no added permit would be required for the under the Colorado solid waste regulations. Post-closure monitoring requirements were discussed,. The requirements for a closed site under the Solid Waste site model would include physical inspection of the cap over the waste disposal site, the status of revegetated areas, and the storm water diversion structures to assure that all were in good condition. Twice annual ground water sampling would be required at wells down gradient of the site. The chemical laboratory ana:yses for these sampling events would include appropriate parameters based on known waste constituents. Also discussed, as background, were the scope and applicability of the federal solid waste regulations commonly referred to as Subtitle D of the Resource Conservation and Recovery Act (RCRA). Mr. Schurman felt that since the federal regulations did not specifically include mining waste that the state's solid waste regulations could not be more stringent. Pam Harley noted that the state's solid waste regulations have an independent authority in the state's statutes that does not rely on the federal provisions and, in fact, existed before RCRA became effective. She agreed the Part 258 of federal regulations (RCRA Subtitle D) addresses only municipal solid waste landfills; but she reminded Mr. Schurman that Part 257 did include other types of solid waste treatment and all industry and commercial waste streams including mining wastes.