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October 7,2020 <br /> Mr. Means and Mr. Scott <br /> Page 3 <br /> The basis for our objection is described below. <br /> Water Treatment and Water Quality Effects on Love Pit Wetland from Process Water Treatment <br /> As noted above, Eagle's Nest Mountain Ranch includes a large constructed wetland,known as <br /> the Love Pit Wetland. Construction of the Love Pit Wetland was completed by Everist Materials in <br /> 2003 as mitigation for wetland disturbance associated with the Love Pit Mine. Figure 1 (attached to <br /> this letter) shows the extent of the Love Pit Wetland and its close physical proximity to the MCRA <br /> Mine processing facility (aka Lake 6), the water treatment facilities, the CDPHE Outfalls, and the <br /> mining areas for the MCRA Mine. The close proximity of the water treatment facilities and Outfall <br /> 002A to the northern end of the Love Pit Wetland raises serious environmental impact concerns. <br /> Peak's application for the proposed PRR Mine, and its supporting exhibits, do not address the <br /> potential environmental impacts resulting from the additional processing of raw materials to be <br /> extracted at the PRR Mine. <br /> The wet mining method currently used at the MCRA Mine is similar to the proposed Phase 2 <br /> of the PRR Mine, using drag-lines to pre-wash the raw material and leaving fine soils in the mine pit. <br /> However, there is no such pre-washing during the proposed Phase 1 of the PPR Mine. Exhibit I — <br /> Soils Information of Peak's PRR Mine application states that the principal raw materials will be <br /> Handran Gravelly Loam and Sandy Loam. Sandy Loam, according to the USDA soils classification <br /> system can contain as much as 20% clay or as much as 50% silt, neither of which is a desirable <br /> component of marketable aggregates. The drill logs provided in Section 7.2 of Exhibit D —Minim <br /> Plan of Peak's PRR Mine application list sand and gravel as the expected raw material for the PRR <br /> Mine, but that classification can contain up to 20 percent of clay and silt. Section 5.0 of Exhibit D— <br /> Minim Plan of Peak's PRR Mine application states that the expected production rate will be 400,000 <br /> tons per year. Therefore, without pre-washing the raw materials at the PRR Mine site, as much as <br /> 80,000 tons of clay per year or as much as 200,000 tons of silt per year(or a combination of clay and <br /> silt) must be hauled with the gravel and removed by processing at the MCRA Mine during the <br /> proposed Phase 1. Silt and clay in the sand and gravel raw materials are commonly called"fines"and <br /> constitute a waste stream from processing. In hard-rock mining that waste stream is called "tailing" <br /> and is closely regulated by DRMS at other mines in Colorado. Potentially up to 100,000 cubic yards <br /> of such waste must be washed from the PRR Mine's raw material each year, for three years during the <br /> {00101951) <br />