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Mr. Wallace H. Erickson <br />Response to September 27, 2011 Cazier Memorandum <br />October 11, 2011 <br />Page 7 <br />Attachment D -4, Chief Drainage and Portal Work Plan and Lamb Affected Area <br />Little Deadwood Gulch <br />Adequacy Issue No. 11. <br />a. The response is unacceptable. DRMS cannot allow mining to proceed while mine <br />waste is disturbing the prevailing hydrologic balance (pursuant to C.R.S. 34-32 - <br />116(g)) in Little Deadwood Gulch. Regardless as to whether the applicant can <br />demonstrate removal of the existing mine waste material will destabilize the Chief <br />Portal and adjacent bench, an alternative means of stabilization shall be provided by <br />the applicant that includes the removal of the mine waste material from Little <br />Deadwood Gulch. <br />i. DRMS will require the applicant provide a geotechnical /stability <br />analysis to demonstrate that the proposed alternative means of <br />stabilization will in fact stabilize the Chief Portal and adjacent bench <br />with an appropriate factor of safety. <br />b. The applicant states that all mine waste will be removed during reclamation. <br />However, the referenced drawing Figure F -5A, does not in fact show all the mine <br />waste being removed, even at reclamation. Future submittals shall show all the <br />mine waste is to be removed from Little Deadwood Gulch both during operations <br />and after reclamation. <br />Response to Adequacy Issue No. 11. <br />See Response to Adequacy Issue No. 10, September 28, 2011 Cazier <br />Memorandum. <br />Attachment D -6, Augmentation Pond Work Plan <br />Adequacy Issue No. 12. <br />The response is inadequate. The applicant's revised Attachment D -6, Figure D -2 and <br />response to Adequacy Issue No. 12 does not adequately address the August 22, 2011 <br />comment and raises additional questions: <br />a. The applicant's response states wattles will be installed during construction. No <br />wattle locations are shown on the revised Attachment D -6, Figure D -2. Please <br />provide locations where these wattles will be installed. <br />b. The applicant' s response states a down gradient perimeter ditch and catch basin will <br />be installed to collect and divert stormwater and snow melt. The new diversion <br />ditch (labeled "DD ") shown on the revised Attachment D -6, Figure D -2 appears to <br />collect runoff from the facility area (warehouse, office, access roads, etc) and <br />diverts it to the north, crossing the access road west of the augmentation pond and <br />routing it uphill towards the crest of the pond. Furthermore, the reference drawing <br />DEN 97,627,904v1 10 -11 -11 <br />GREENBERG TRAURIG, LLP ® ATTORNEYS AT LAW NI WWW.GTLAW.COM <br />