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• III IIIIIIIIIIIII III ~ STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of natural Resource 1313 Sherman SI . Rnom ?15 Denver, Colorado AO?03 Phone: 13011 R66-3567 FAX: 13031 R3?-R106 March 21, 1997 Lji~.SVi~ ~~ UFFlrC CE~Q ~tr v ~ rte) ~~ DEPARTMENT OF NATURAL RESOURCES Mr. Kye Abraham LKA International, Inc. 3724 47th St. Ct. NW Gig Harbor, WA 98335 Roy Romer Governor lames S Lochhead Exe<uhae Direcor Michael B. Long Dinsion Director Re: Golden Wonder Mine, Permit No. M-78-091, Adequacy Review of Environmental Protection Plan Submittal. Dear Mr. Abraham, This letter will briefly outline the major topics which have not been addressed satisfactorily in the recently- submitted Environmental Protection Plan (EPP) for the Golden Wonder Mine. The latest EPP submittal from you, received on March 3, 1997, responded specifically to the Division's adequacy review letter dated August 5, 1996. That letter from the Division specified, rule by rule, exactly what was expected to be included in the EPP. Many of the items described in detail before have still not been addressed. However, I am not going to reiterate the same points to you in this letter. Below I will outline generally what are the Division's main concerns. I hope that you will review the Hard Rock/Metal Mining Rules and Regulations which pertain to an EPP, and also review the Division's aforementioned letter to you. The Golden Wonder Mine consists of two adits and their associated dumps and access roads, located on or near Deadman Gulch. Main concerns involve stormwater runoff, acid mine drainage, dump stability and are handling, baseline water quality and follow up water quality monitoring. This is a historic mine which, presumably has continuously discharged acidic, metal-laden water since its early days. It is located in an area which has a watershed of over 60 acres uphill from it. The dump material, mostly pre-law but also some recent, is permeable and contains a degree of mineralization. Mine drainage passes over and through the dumps; stormwater run-on and runoff passes over and through the dumps; access road drainage may pass through the dumps; ore storage on the dumps is not performed in a manner to isolate the minerals from weathering into the dump material; and there is no sediment control plan or structure within the permit area. As such, there is very little which specifically addresses the potential for degradation of water quality due to stormwater, sediment, or acid mine drainage. There is no map provided which shows surface drainage patterns, control structures or sampling points. The water quality from acid mine drainage is not suitably sampled nor is there an adequate sampling program proposed. A recent analysis of samples taken months or years prior is meaningless; likewise, there is nothing substantive in the CDPHE permit applications, copies of which we received from you and which we assume are complete, addressing structures or practices to control sediment or mineralization of effluent. There is no specific plan or proposed set of locations to obtain baseline or follow up water quality data. On that topic also, you have received information from us which indicates that many of the mineral parameters to be tested are "hardness based" (dependent on the amount of CaC031, and dependent on the classification of the receiving stream. Your sampling and analyses must account for these. The Gold Quartz Mine, an adjacent mine but not permitted nor part of your operation, also discharges acid water. It apparently drains to a location common to the drainage from J/6 level of the Golden Wonder.