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amounts of storm-water. The established evaporative sump has been sufficient since the onset of <br />mine operations to control and evaporate any contained flows. In addition, sampling of the sump <br />bottom materials indicates that the sump is compacted fines and has a low permeability. In light of <br />the fact that LKA Int./GGI will begin the process of waste rock removal this year, there are no <br />proposed amendments to the existing best management practices since the amount of surface <br />area available for storm-water contact will begin to diminish immediately at the onset of the <br />construction season. <br />Page 2, Bullet Item 7, entire bullet. The information contained within this bullet indicates that <br />storm-water is being released over the waste rock face and causing erosional rills. This is incorrect <br />information taken out of context in relation to mine operations. It should be noted that Level 6 <br />activities have occurred since the 1980s. The observed 'rills' were created pre-LKA Int./Au Mining <br />operations. Close observation should have proven to the site inspector that the rills were 'pre- <br />storm-water bmp implementation' put in place in 1998 by Au Mining. The rills are cross-cut by <br />contouring efforts and well aged. There are no erosional rills along the face of the slope related to <br />uncontrolled storm-water flows that have occurred during LKA Int./Au Mining operations. <br />Page 3, Second Full Paragraph, Fifth Sentence stating "However, the Division understands that <br />these interim measures were not effective in reducing flow from the seeps at the toe of the waste <br />rock pile, which continue to discharge into Deadman's Gulch." This statement is inaccurate. GGI <br />personnel have conducted site visits to the Golden Wonder on a routine basis. Flows from the toe <br />seeps were non-existent in October, November and December of 2007. Photo documentation of <br />the seep points of discharge is provided in Attachment A. If the Division has contrary information, <br />we respectfully request documentation of these releases. <br />Page 3, Third Paragraph, entire paragraph. As previously described (from initial documentation <br />provided to CDPHE outline the chemical trace studies completed on the site to establish the <br />hydrologic setting, and documentation within this deliverable) LKA Int./GGI do not feel that site <br />conditions warrant the need for an Individual Industrial Wastewater Discharge Permit. The waste <br />rock toe seeps have been defined using chemical constituent tracing to be associated with <br />Deadman Gulch base flows. Those flows have since been managed with the placement of the <br />diversion channel. The channel should effectively eliminate flows from contacting the waste rock <br />thereby eliminating 'contact' condition which defines the setting as having Process Water. <br />Furthermore, the waste rock is to be removed from the Gulch path. These two water management <br />practices will remove flows from contacting waste rock thereby eliminating the Process Water <br />condition. In addition, storm-water retained on the waste rock pile does not connect to the 'point <br />source' (waste rock toe seeps) as defined within the chemical trace study and as noted throughout <br />the years of storm-water management onsite. The forthcoming waste rock removal effort will also <br />remove this perceived pathway. <br />Page 6 of 37