2017-05-05_GENERAL DOCUMENTS - M1977004

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RECEIVED MAY 0 5 7017 DIVISION OF RECLAMATION HOM ✓S AYE MINING AND SAFETY Pitch Reclamation Project—Colorado,USA 2 May,2017 State of Colorado,Division of Reclamation Mining and Safety Department of Natural Resources 1313 Sherman Street,Room 215 Denver,Colorado 80203 Attn: Mr. Russell Means Re: Pitch Reclamation Project,Saguache County M-1977-004-Loag Term Reclamation Plans Dear Mr. Means: The Homestake Mining Company(HMC)appreciates the Division of Reclamation, Mining and Safety's(DRMS)position regarding updating the final reclamation plans for the Pitch Project site. HMC agrees that an update is needed to establish a final reclamation plan that is acceptable to the Pitch stakeholders. This final plan would then be used to guide interim reclamation efforts. However, at this point, HMC is concerned that the requested date of January 2,2018 is not sufficient to address the updates to this plan and requests additional time. The most important issue that drives the project reclamation and closure approach and schedule is clear definition of the water quality discharge requirements for the site. As DRMS is aware, HMC is working with the Water Quality Control Division(WQCD)of the Department of Public Health and Environment(CDPHE) to address issues with water quality standards and the concentrations of uranium leaving the site.The site discharges water to Indian Creek which has a "lowest practical level"(LPL)standard for uranium.The WQCD is asking HMC to determine what can be done to reduce uranium concentrations leaving the site, and thereby defining LPL. It is unknown at this point whether the definition of LPL will be a set of narrative conditions/activities that can be implemented at the site or if it will be a numeric standard. A meeting held on December 7,2016,which was attended by both DRMS and the WQCD, provided an update on HMC's activities and investigations at the site and contained a discussion of the LPL standard. Part of the discussion regarding activities that could reduce uranium concentrations and define LPL included the potential for a"best management practice"(BMP) type approach for managing water runoff and infiltration.This option would cause additional disturbance,albeit temporary,at the site. In addition, HMC is also investigating the potential for