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B~ ~,e United States Forest Rio Grande Divide Ranger District ~Q,,~..~ ~~F Department of Service National Forest 13308 West Highway l60 ` `~~G 3f Agriculture Del Norte. CO 81132 LY" (719)657-3321 File Code: 2520/2 l60 Date: January 2~, 2000 Mr. Alan Cox Homestake Mining Company 650 California Street San Francisco, CA 94108 Fir,""°~ r ~~ ~. ~.~.Lh i Lr Dear Mr. Cox, Thanks again fcr initiating our Jazuary 13 meeting in Del Norte. During tha: meeting, we could not give you a definitive answer about whether the Forest Service would need to use our CERCLA authority or if we could use Forest Service locatable mineral regulations for reclamation work you were proposing for the Bulldog mine. We visited with our Regional Office staff and have concluded that we must comply with CERCLA. This letter will outline the steps for CERCLA compliance at the Bulldog mine. I know you are uncomfortable with the prospect of a CERCLA cleanup at the Bulldog mine, but I want to reiterate that CERCLA compliance does not have to be a costly, inefficient means of dealing with reclamation and we feel confident that it won't be in this case. The Forest Service approach to CERCLA is consistent with the National Contingency Plan, but is also streamlined and efficient. We desire, as you do, that problems be resolved as efficiently as possible. Based on available information, we believe there is a release or threat of release of hazardous substances from Bulldog waste rock dumps in Windy Gulch. So it is not simply a matter of reclaiming a surface disturbance. We aze working with the Willow Creek Reclamation Cotnmittee (WCRC) on mine cleanup efforts throughout the Willow Creek drainage. Preliminary studies indicate that the entire drainage is a potential CERCLA site. A preliminary assessment (PA) of the East and West Willow Creek drainages was completed by the EPA under their CERCLA authority. The Bulldog mine and Windy Gulch were included in the PA and were identified as a possible source of zinc contamination in Willow Creek. Further site characterization is ongoing. The Forest Service is committed to working with the WCRC to complete site chazacterization. The data you have collected recently coincides perfectly with WCRC site characterization efforts. The WCRC has a technical advisory committee (TAC) that will be meeting February 2"' to begin evaluating the data collected so faz. I would encourage you to participate with the WCRC and TAC in completing necessary data collection. Once necessary data has been collected, the site investigation (SI) phase will be complete. The Forest Service generally does "icon-time critical removal actions" under our CERCLA authority. Non-time critical removal actions require an engineering evaluation cost analysis (EE/CA) to develop alternatives and select the best approach for resolving problems identified in the SI. Caring [or the Land and Serving People a.~~.a a, a.~.ci,a r,oa i~