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2008-02-13_HYDROLOGY - M1978091UG
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2008-02-13_HYDROLOGY - M1978091UG
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Last modified
8/24/2016 3:22:44 PM
Creation date
8/11/2008 9:54:33 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1978091UG
IBM Index Class Name
HYDROLOGY
Doc Date
2/13/2008
Doc Name
SWMP response
From
Gualt Group, Inc.
To
DRMS
Email Name
RCO
Media Type
D
Archive
No
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letter). It should be noted that current weather conditions prohibit further BMP <br />implementation. <br />In addition, the letter requests an application for permit coverage under an Individual <br />Industrial Wastewater (Process water) Discharge permit.(refer to Attachment C). It <br />should be noted that there are no flows within Deadman Gulch, nor any flows associated <br />with the 'point source' (waste rock toe seeps). Given the time frame of the permit request <br />and the lack of flows from the seep, portions of the application remain incomplete. <br />Finally, the Letter requests "a report outlining the findings from the evaluation (describing <br />the associated drainages for the facility), a plan for remediating pollution sources <br />associated with the Facility if necessary; and c) a time schedule for completing the <br />remedial activities. (much of this information was previously provided within the <br />SWMP and Chemical Trace documentation initially supplied to CDPHE. However, <br />additional information is provided within Documentation provided within <br />Attachment D. Copies of the correspondence documenting the waste rock removal <br />activities, and associated time line is provided in Attachment D). It should be noted <br />that LKA Int./GGI and the BLM have reached a consensus on the next steps to be taken in <br />regards to the waste rock pile at the Golden Wonder. The pending removal of this pile will <br />eliminate the 'point source' (waste rock toe seeps). In addition, it should also be <br />recognized that CDPHE has assumed there are no current BMPs in place that control <br />Deadman Gulch flows from contacting the waste rock pile. This is an incorrect assumption. <br />The diversion channel which routes Deadman Gulch flows away from the pile was <br />completed in September, 2007. This channel should manage the'point source' (waste rock <br />toe seep) from occurring. CDPHE needs to acknowledge the fact that the diversion <br />channel in combination with the pending waste rock removal effort will effectively eliminate <br />the point source. <br />The Advisory Letter states that there were no revised best management practices in place during a <br />site visit conducted on June 8, 2007 and that LKA Int. would be considered out of compliance <br />unless these measures were implemented within a 30-day time period following receipt of the <br />letter. It should be noted that the Deadman Gulch diversion channel has since been completed <br />(September, 2007) and represents a significant portion of the BMP concerns raised by CDPHE. <br />Documentation for the construction and completion of the channel is provided in Attachment A. As <br />discussed with Kelly Morgan, current site conditions render access and construction extremely <br />problematic and un-safe due to winter weather. Furthermore, LKA Int./GGI has reached an <br />agreement with the BLM that will involve the removal of the waste rock pile from the Deadman <br />Gulch flow pathway. Removal activities will begin when weather permits in 2008 and likely continue <br />through 2010. These activities will address the concerns brought forth within the Advisory Letter <br />including the outstanding BMPs as well as the control of Deadman Gulch Flows and the need for a <br />point source discharge permit (which will be eliminated). Documentation of the correspondence <br />between LKA Int./GGI and the BLM is provided within Attachment D. Since the waste rock pile is <br />to be removed (and accepted by the BLM as documented within their 'Termi nation of <br />Noncompliance Order, effective date of November 10,2007 - copy provided in Attachment D), <br />certain aspects of the SWMP will be inapplicable as requested within the Advisory Letter. <br />In summary, this letter and the associated attachments are provided in response to CDPHE's <br />outlying concerns surrounding the Golden Wonder mine site conditions associated with the <br />management of both storm-water and the point source discharge as defined by CDPHE located at <br />Page 2 of 37
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