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AREQUA GULCH OPERATING PLAN <br />This "Arequa Gulch Operating Plan" (Plan) addresses the requirement specified in <br />Pazagraph 27 of the Colorado Department of Public Health and Environment, Division of <br />Administration, Water Quality Control Division Administrative Order on Consent <br />(Order) executed on February 10, 2003. Paragraph 27 specifies the following. <br />27. Within ninety (90) days after the Effective Date of this Order, CC&V shall <br />in good faith submit to the Division and EPA for review an "Arequa Gulch <br />Operating Plan" in accordance with this Paragraph. The Arequa Gulch <br />Operating Plan shall describe how the flows contributing to the Arequa Gulch <br />Outfa11001A regulated by the Cresson Project Permit will be managed to meet all <br />applicable federal and state requirements including, but not limited to, the <br />effective terms or conditions in the Cresson Project Permit The Arequa Gulch <br />Operating Plan shall also: <br />a. Include an implementation schedule; <br />b. Identify where the discharge from Arequa Gulch Outfall OOIA will be <br />routed and how it will be managed there; and <br />c. Describe haw flows subject to the Cresson Project Permit will be <br />managed in the past-mining period. <br />The Plan is structured to provide background information about the ptunpback system <br />and then address each of the three components specified in Pazagraph 27 of the Order. <br />Backeround: <br />Cripple Creek & Victor Gold Mining Company (CC&V) voluntarily installed a <br />pumpback system for flows from the north underdrain (NUD) as a best management <br />practice (BMP) in 2001. The Arequa Gulch pumpback system fast became operational <br />in May 2001. It was originally designed and constructed to transfer water from the NUD <br />to the upgradient valley leach facility (VLF) or external storage pond (ESP)t during <br />periods of high flow and/or heavy precipitation. During such periods of high <br />precipitation/flow in 1998 and 1999, elevated levels of cyanide were observed in the <br />water flowing from the NUD that contributed to the excursions that were self-reported by <br />CC&V under its then existing dischazge permit for which CC&V asserted the upset <br />defense. The pumpback system was installed to minimize the potential for cyanide <br />excursions during future high flow/precipitation events. <br />The operation of the pumpback system was influenced by highway construction and <br />associated land reclamation activities that occurred in 2001 and 2002. A portion of State <br />Highway 67 was relocated azound CC&V's activities with a bridge constructed to span <br />Arequa Gulch immediately upgradient of Outfa11001A of Colorado Dischazge Permit <br />~ Recall [hat the VLF is amulti-layered synthetically lined facility wherein the mineralized rock is <br />placed for gold and silver recovery and that the FSP is amulti-layered synthetically lined pond associated <br />with the VI.F. The VLF and ESP have been rigorously designed, tested and certified by qualified third- <br />pazty engineers registered in the State of Colorado. <br />6/6/2003 1 <br />L,. <br />