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Again, we invite DRMS to view the site conditions first hand during the spring setting, <br />2009. <br />COMMENT #4: Summary of DRMS's Concerns: DRMS identifies the problematic issues <br />surrounding the use of trace metals as `tracers' to define flow pathways. <br />RESPONSE: GGI agrees that the use of trace elements introduces uncertainty when <br />trying to define unique and dynamic flow pathways. The use of other `tracers' such as <br />dye was entertained for this endeavor but the hydrologic setting is not conducive to the <br />use of these types of tools. Unfortunately, the seeps emerge at the mine location with no <br />above-gradient source to spike or release the dye from. In addition, given the fractured <br />geologic formation setting, and the natural acidity (plus mineral load) it would be <br />anyone's guess as to where the dye would eventually emerge or how it would react with <br />the baseline water. Given these site setting characteristics it was realized that inherent <br />tracers had to be used. The established wells provide the first sets of samples within the <br />flow pathways of concern. As noted within the document, we recommend to continue the <br />monitoring in order to reduce the uncertainty of the evaluation, and further study the site <br />setting. <br />From a broad perspective, GGI finds the above comments troubling in that they illustrate a lack <br />of harmony between the actions and expectations of the three primary agencies with whose <br />programs LKA must comply: DRMS, Bureau of Land Management, and Colorado Department <br />of Public Health and Environment. In addition to providing these responses-to-concerns, GGI <br />strongly suggests a multi-agency meeting with LKA to make sure that these agencies at a <br />minimum: 1) are in concurrence concerning the number, exact location, and nomenclature for <br />each "seep"; and 2) have the information with which to consider the various agencies' <br />requirements and expectations of LKA when devising their own compliance strategies. <br />Thank you for the opportunity to assist LKA in this matter. Please feel free to contact me with <br />any questions or comments on the above information. <br />Sincerely, <br /> <br />Stephen E. Glass <br />Cc: Bob Oswald <br />4