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v <br />`l, <br />', <br />GGI would like to take the opportunity to respond to specific items within the Advisory <br />Letter as numbered below. The Advisory Letter states that <br />findings during a "June 8, 2007 inspection by a Water Quality Control Division <br />representative noted discharges to surface water(1) at the mine site. These <br />discharges were in the form of seeps that daylight at the toe of the waste rock pile <br />at the Level 6 pad and flow into Deadman's Gulch. Recent water quality <br />monitoring in Deadman's Gulch indicate a negative impact(2) on Deadman's <br />Gulch originating at the mine site(3). The discharges from the seeps at the mine <br />site are in direct violation of the Water Quality Control Act, which reguires that <br />all discharges ofpollutants to the state waters(4) must be permitted:..." <br />(1) GGI disagrees with the statement that there aze `discharges to surface water' We <br />disagree that the `mine dischazges to surface water `for two reasons; a) the mine <br />does not dischazge and b) Deadman Gulch would not be defined as a surface <br />water of the United States. Any encountered water within the Golden Wonder <br />mine is managed underground. These practices aze typical water management <br />strategies for mines which keep `groundwater as groundwater'. There is no <br />daylighted flows from the mine. Furthermore, Deadman Gulch is an intermittent <br />drainage that contains seasonal flows during spring melt if sufficient snow melt <br />capacity was achieved the yeaz prior. The Gulch has been known to be dry for <br />years and is currently dry throughout its' length. At best, the Gulch runs from late <br />Mazch through August if weather permits. During the June 7, 2007 WQCD site <br />visit, GGI staff discussed the mine-site hydrologic setting with the representative. <br />It is known that the mine waste rock pile occurs on top of the historic Deadman <br />Gulch channel. In addition, waters from the mine (in the form of stormwater and <br />underground managed water [referred to as sump water]) may also connect with <br />the waste rock pile. In order to delineate the sources and flow pathways <br />associated with the mine site, GGI wnducted a `chemical trace' study. This study <br />was agreed upon by DRMS and the WQCD personnel as being beneficial to this <br />process and is summarized in Attachment A to this letter. In addition, given the <br />fact that the Deadman Gulch historic channel is a known flow pathway, it was <br />agreed (again by DRMS and the CWCD representative) that control of these <br />flows with the placement of a lined channel would be beneficial, and possibly <br />eliminate the toe seeps entirely. Au Mining is currently in the process of <br />completing this channel. It is anticipated that the effectiveness of this <br />management practice will be observable during next yeaz's flows if Deadman <br />Gulch does flow. <br />(2) The statement that `recent water quality monitoring in Deadman's Gulch indicate <br />a negative impact' is speculative (perceived) and not supported by true site risk <br />conditions. It is uncleaz whether this statement refers to negative impacts <br />observed or measured within Deadman Gulch and/or the Lake Fork of the <br />Gunnison which Deadman Gulch is a tributary to. Also, the Division does not <br />clearly define what is meant by `negative impacts'. It appears given <br />correspondence from the Division personnel to DRMS that this conclusion was <br />drawn based upon pH and conductivity measures gathered by the BLM. <br />Page 2 of 16 <br />