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are constructed of wheel compacted native, low permeability materials (estimated at no less <br />than 10 -6 cm /sec). Future operations need to consider the working fluid levels of the ponds <br />with respect to the volume necessary for storm water runoff storage. <br />All surface water generated from precipitation within the disturbed areas is captured by the site <br />perimeter diking. Small berms contain localized containment areas, such as the ore stockpile <br />area, and an additional large berm is located to the west of the tailings pond that has capacity <br />to retain all storm -water runoff generated by the site. Runoff from topographically up- gradient <br />areas outside of the permit boundary is diverted by up- gradient berms as run -on protection. <br />Due to the simplicity of the surface flows at the site and the designed containment of all run -off <br />generated within the permitted area, the Colorado Department of Public Health and <br />Environment (CDPHE) has determined that no storm -water runoff permit is required for this <br />operation. <br />11 SURFACE WATER QUALITY STANDARDS <br />The site is located along a high divide and there are no perennial streams. The closest stream <br />that can be considered perennial, would be Stubbs Gulch in it lower reaches, a distance of at <br />least 7 miles from the permit area. Thus, since no surface waters exist, there can be no release <br />to them. An exception to the absence of surface waters is the discharge point from the Lucky <br />Strike Spring, which will be sampled as part of the water quality monitoring plan. The State of <br />Colorado defined detection limits for that source are shown in Section 10 above. <br />14 <br />