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pumping rate. Granted the ADR will still process at the current rate of 14,900gpm so no <br />additional processing facility is proposed at this time. The additional pumping rate will go <br />through the enrichment tanks located west of the ADR and will be applied somewhere on <br />to the pad. The model is supposed to predict when that solution will report to the pregnant <br />pond and allow some lag time so when it does report to the pregnant ponds, it will still be <br />under the 80 % maximum operational capacity. Can CC&V explain why this model is any <br />different than applying solution on to the pad and waiting for the solution to report as <br />pregnant solution in to the ponds and be pumped to the ADR, for gold recovery? Even <br />under the current pumping rates,(14,900gpm) on numerous occasions in the past, CC&V <br />had to take emergency pumping measures to transfer solution from one pond area to <br />another pregnant pond area, due to the levels getting closer to the 80% maximum operating <br />permit condition. In order to satisfy the Division's concerns, the DRMS would like to see <br />how the wettest years on record as reported in the Rigi station ( the station should have <br />good recorded data since 2000) correlate with the pregnant pond levels.. The data for the <br />pond levels should be available because CC&V keeps a good record of such data in the <br />ARD building control room for the ponds. The pond levels should mimic the results from <br />the model projections. The model assumes a 30% porosity for the ore to derive the pore <br />volume yield. Dori t the lower lifts have an already established preferential path flow? If <br />not, is each time a lift added and solution applied, does a different flow path become <br />established? Please explain <br />Z. Most of the drainage plan for the storm water hydrology was approved under Amendment <br /># 8. The criterion used to evaluate the AM-09 area is the same as was approved in <br />Amendment # 8. The only exception was a higher curve number used for the East Cresson <br />overburden storage area due to the proposed engineered design with low infiltration cover. <br />The Division agrees with the higher curve number. The Division also agrees with the use of <br />the two 10 year 24 hour events to design the storm water BMP ponds. CC&V plans to <br />enhance some of these ponds and leave some of them in place post mining as stock ponds. <br />Prior to the Division, allowing these ponds to remain in place post mining, CC&V will have <br />to contact the State Engineer's Office to make sure loss due to evaporation from these ponds <br />is applied for by the land owner (CC&V) in their water substitute supply plan. It would <br />assist the public and any reviewer if the sub watershed delineation maps were at a scale of <br />1 inch to 800 feet. The sub water delineation maps as submitted are very hard to follow <br />even for those people who are familiar with the project. Please provide a sub-watershed <br />delineation map as requested. <br />VII) Exhibit H- Wildlife Information-Rule 6.4.8 <br />A. The DRMS has forwarded comments from the Colorado Division of Wild Life. Does CC&V <br />Agree with the suggested recommendations? Please acknowledge. <br />VIII) Exhibit L-Reclamation Costs-Rule 6.4.12 <br />CC&V provided a detailed reclamation cost estimate utilizing the cost estimate based on the <br />Caterpillar Performance Handbook (33-36th edition) for backfilling and grading costs which is <br />in line with DRMS bonding calculation program. Calculations for revegetation costs are based <br />on the actual seed mixes. Demolition costs are taken directly from the latest versions of R.S. <br />Means Heavy Construction Cost Data for 2008, then using dimensions of the structures and <br />simply applying an appropriate cost per unit volume. The detoxification cost, as in the past, <br />utilized two pore volumes of water rinse with a series of resting and rinsing periods followed <br />14