2020-10-13_PERMIT FILE - M2020041 (2)

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October 7, 2020 Mr. Means and Mr. Scott Page 4 proposed Phase 1. That is a significant element of the proposed PRR Mine plan that will affect the operations and reclamation at the MCRA Mine. The application for the proposed PRR Mine does not address where the waste fines will be impounded and how the final reclamation will accommodate that waste. Water quality is an additional environmental concern. There is no evidence in Exhibit G — Water Information of Peak's PRR Mine application that the applicant considered/assessed the water treatment requirements for the wash water used in processing the raw materials to be extracted from the PRR Mine at the MCRA Mine. The chemical properties of the fine soils (clay/silt fraction) at the proposed PRR Mine may be different than those at the MCRA Mine and would require different or more aggressive treatment. An inability to treat the wash water from the proposed PRR Mine would be manifested as suspended solids discharged at Outfall 002A, adjacent to the north end of the Love Pit Wetland. That would have a substantial impact on the Love Pit Wetland. The application does not describe how this will be prevented. For these reasons, among others, the application should address the impacts of off-site processing at the MCRA Mine of the raw materials to be extracted from the PPR Mine, especially during the proposed Phase 1. MCRA Mine Permit does not Contemplate or Consider Processing of Oft-Site Materials and Requires an Amendment of the Permit Peak's original application, subsequent Amendments, and Technical Revisions to the MCRA Mine Permit No. M1996-049 do not contemplate or consider processing raw materials from off-site locations, as is proposed by Peak in the PRR Mine application. Figure 2 shows the current mining area, projected future mining cells, and the process facilities as "Lake 6". The 1996 MCRA Mine application states that the expected production schedule for the MCRA Mine will be as follows (Reference 199649 Application,Exhibit D,Page D-2): • Years 27 through 30—Mining of Cell 4 • Years 31 through 38—Mining of Cell 5 • Years 39 through 45—Mining of Cell 6 (Process Plant Area) • Years 46 through 50—Finish lining augmentation pond and demobilize {00101951}