HYDRO27875

• Permit No: M1978091UG
• IBM Index Class Name: Hydrology
• Doc Date: 9/4/2007
• Doc Name: SWMP control response
• From: Gault Group Inc
• To: Water Quality Control Division
• Media Type: D
• Archive: No

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Regardless, GGI would support the fact that there aze no negative impacts to the
appropriate (to Deadman) or defined (to Lake Fork) uses for these drainages. The
rationale behind these conclusions aze as follows;
a. Deadman Gulch: The statement within the Advisory Letter fails to
recognize the fact that `background' conditions within Deadman Gulch
could be defined as being impaired based upon the metals content and pH
decrease observed over time in response to the onset of Fall flows. The
Advisory Letter statement indicates that the mine is solely responsible for
the observed `negative impacts'. A thorough analysis of background was
completed using data gathered by GGI and others and is provided in
Attachments A and B. Furthermore, Deadman Gulch is an intermittent
tributary with a sinuosity of 1 and a gradient typical of headwaters
systems. The headwaters occur immediately adjacent to the Golden
Wonder Leve16 pad, and then plummet to the valley floor by means of
traverse through a fault zone in the mountain side. With such significant
gradient, there is no aquatic habitat of significance. The channel of the
gulch is thoroughly vegetated with native species due to the availability of
moisture provided by this unique zone. As observed by GGI personnel,
there is absolutely no sign of phytotoxicity to any of the plant species that
occur in the channel. The vegetation assemblage is robust, diverse and
comprised of multiple age classes. There aze no visible signs of toxicity.
b. Lake Fork of the Gunnison: Flows from Deadman Gulch represent 0 to
0.25% of the flow within the receiving drainage; the Lake Fork of the
Gunnison. GGI personnel have measured the footprint of the possible
mixing zone at the confluence and found the impacts to be negligible to
un-measurable within the immediate vicinity of the point of release. In
addition, repeated water quality monitoring as part of the DRMS
reclamation permit requirements for the Golden Wonder have never
shown impacts to the Lake Fork. The gathered BLM/EPA data for
locations along the Lake Fork shows some pH difference however these
data points were `estimated' and potentially uncertain (refer to
Attachments A and B).
(3) The statement that `negative impacts on Deadman's Gulch originat(e) at the mine
site' is incorrect. As per the results obtained from the Golden Wonder Chemical
Trace study (Attachment A) it appears that Deadman Gulch base flows from its
historic channel are primarily the source of the toe seeps. The Chemical Trace
study was embazked upon in response to the repeated misinterpretation of
underground water management issues surrounding the Golden Wonder Level 6
workings as identified by the BLM. As shown by the Chemical Trace study, the
toe seep water characteristics aze the result of Deadman Gulch base flow (from
this historic channel) comingled with waste rock elutriate/leachate. These results
further endorse the ongoing efforts by Au Mining to route Deadman Gulch base
flows away from the waste rock pile. It is recommended that this management
practice be allows to equilibrate, and wait until Spring 2008 to determine whether
there is a continued need for a point source discharge permit. It is anticipated that
control of Deadman Gulch base flows will sever the toe seep flow pathway.
(4) The statement that the `seeps at the mine site are in direct violation of the Water
Quality Control Act, which requires that all discharges ofpollutants to the state
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