2008-02-13_HYDROLOGY - M1978091UG

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letter). It should be noted that current weather conditions prohibit further BMP implementation. In addition, the letter requests an application for permit coverage under an Individual Industrial Wastewater (Process water) Discharge permit.(refer to Attachment C). It should be noted that there are no flows within Deadman Gulch, nor any flows associated with the 'point source' (waste rock toe seeps). Given the time frame of the permit request and the lack of flows from the seep, portions of the application remain incomplete. Finally, the Letter requests "a report outlining the findings from the evaluation (describing the associated drainages for the facility), a plan for remediating pollution sources associated with the Facility if necessary; and c) a time schedule for completing the remedial activities. (much of this information was previously provided within the SWMP and Chemical Trace documentation initially supplied to CDPHE. However, additional information is provided within Documentation provided within Attachment D. Copies of the correspondence documenting the waste rock removal activities, and associated time line is provided in Attachment D). It should be noted that LKA Int./GGI and the BLM have reached a consensus on the next steps to be taken in regards to the waste rock pile at the Golden Wonder. The pending removal of this pile will eliminate the 'point source' (waste rock toe seeps). In addition, it should also be recognized that CDPHE has assumed there are no current BMPs in place that control Deadman Gulch flows from contacting the waste rock pile. This is an incorrect assumption. The diversion channel which routes Deadman Gulch flows away from the pile was completed in September, 2007. This channel should manage the'point source' (waste rock toe seep) from occurring. CDPHE needs to acknowledge the fact that the diversion channel in combination with the pending waste rock removal effort will effectively eliminate the point source. The Advisory Letter states that there were no revised best management practices in place during a site visit conducted on June 8, 2007 and that LKA Int. would be considered out of compliance unless these measures were implemented within a 30-day time period following receipt of the letter. It should be noted that the Deadman Gulch diversion channel has since been completed (September, 2007) and represents a significant portion of the BMP concerns raised by CDPHE. Documentation for the construction and completion of the channel is provided in Attachment A. As discussed with Kelly Morgan, current site conditions render access and construction extremely problematic and un-safe due to winter weather. Furthermore, LKA Int./GGI has reached an agreement with the BLM that will involve the removal of the waste rock pile from the Deadman Gulch flow pathway. Removal activities will begin when weather permits in 2008 and likely continue through 2010. These activities will address the concerns brought forth within the Advisory Letter including the outstanding BMPs as well as the control of Deadman Gulch Flows and the need for a point source discharge permit (which will be eliminated). Documentation of the correspondence between LKA Int./GGI and the BLM is provided within Attachment D. Since the waste rock pile is to be removed (and accepted by the BLM as documented within their 'Termi nation of Noncompliance Order, effective date of November 10,2007 - copy provided in Attachment D), certain aspects of the SWMP will be inapplicable as requested within the Advisory Letter. In summary, this letter and the associated attachments are provided in response to CDPHE's outlying concerns surrounding the Golden Wonder mine site conditions associated with the management of both storm-water and the point source discharge as defined by CDPHE located at Page 2 of 37