2009-10-29_HYDROLOGY - M1978091UG

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LKA International, Inc. 3724 47th Street Ct. NW Gig Harbor, WA 98335 (253) 851-7486 kabrahamOlkaintl.com October 28, 2009 Kelly Morgan, Enforcement Unit Water Quality Control Division CDPHE 4300 Cherry Creek Drive S. Denver, CO 80246 RE: Compliance Advisory dated October 13, 2009 Dear Ms. Morgan, I'm responding to the above "Compliance Advisory." My responses are included below and intended to address your concerns. Before I start I'd like to say that since I took over responsibility for this issue late last year, it has never been our intention to avoid any of our obligations per the State's (CDPHE) water quality regulations. As evidence of this I'd like to point out the measures that we've taken to achieve compliance since I personally took charge of this matter. To the best of my recollection they include the following; • Hire independent engineers to design a system for diverting gulch water as well as entrapping and filtering any surface or subsurface water that would find its way into the gulch below our permitted working area. (Admittedly, the system/project was originally designed to satisfy DRMS and BLM requirements but it is also intended to assist in meeting CDPHE requirements.) • Meeting with Scott Klarich early in the year to get a good understanding of CDPHE expectations and explain why we believed that our completed system/project would likely be a solution to insure water quality in the gulch downstream from our working area per CDPHE specifications. We also discussed possible additional measures that may be necessary if our project failed to meet this objective. • Submission of a new discharge permit application. • Numerous discussions via telephone and e-mails, pictures, etc. (from me, supervisory engineers as well as DRMS) to keep CDPHE fully apprised of our construction progress and its ultimate completion. • Provided verification from independent engineers that the project/system was constructed per design specifications.