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"Using watershed models, the operator must demonstrate that <br />implementation of the Sediment Control Plan will result in average annual <br />sediment yields that will not be greater than the sediment yield levels from <br />pre -mined, undisturbed conditions The operator must use the same <br />watershed model that was, or will be used, to acquire the SMCRA permit, <br />The Operator must design, implement, and maintain BMM9 in the manner <br />specified in the Sediment Control Plan. " <br />From the discharge permit fact sheet: <br />"Outfalls 005, 006, 007, 008, 030 and 031: The sole contribution to the ponds and their <br />associated outfalls is stormwater runoff from reclaimed areas, all of which have been seeded. <br />No spoils, springs or other non stormwater flows enter the ponds Discharges from the outfalls <br />are intermittent and dependent upon storm events; The ponds discharge automatically when <br />design capacity is reached, The ponds provide treatment by gravity separation (settling) prior <br />to the discharge entering the receiving stream, " <br />As discussed in the permit fact sheet, the ponds are currently in place, and function by gravity <br />separation of suspended solids prior to discharge entering the receiving stream. The design of <br />the sediment ponds is approved by DRMS, in the form of six sediment ponds, Ponds 005, 007a, <br />006a, 008, 009a (outfall 030), 009b (outfall 031). Design for the Sediment Ponds can be found <br />in Exhibit 15. <br />SedCad has been used to demonstrate that the sediment yield, during the reclaimed status of <br />the Lorencito mine will be less than the pre -mining sediment yield with the sediment ponds in <br />place. <br />A comparison between pre -mining sediment loss and the sediment loss from sediment ponds <br />has been prepared and incorporated into Exhibit 15-16. <br />Per the terms of the discharge permit, a DRMS approved sediment control plan must be in place <br />and submitted to CDPHE, no later than April 1, 2016. <br />Please feel free to contact me if you have any questions. <br />Regards, <br />Ron Thompson <br />Agent <br />