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rarKs ana vviiaiite is aatea ii25iluiu ana the response was in relation to a limitea milling program. in the letter <br /> from Colorado Parks and Wildlife dated 1/14/2013(Appendix G)they specifically request that they be asked for <br /> additional information and comments if Zephyr moves toward mining development.Apparently, no such <br /> updated information has been requested.Would it be too much to ask of the applicant that it provide an up-to- <br /> date plant survey as well as other information for the entire 312 acres in this application?) <br /> 6.4.21(1)(c)(iii)]The EPP for FTSF <br /> "As described in the mine plan, mill tailings will be produced at the rate of 300 tpd and placed in the FTSF as <br /> filtered or"dry stack"tailings with a maximum dry density of approximately 15%. Geotechnical classification and <br /> geochemical characterization of tailings did not identify carbonate or sulfide minerals in the tailing's samples. <br /> Minerals detected by XRD include quartz(67.5%)and numerous aluminosilicates, including feldspars <br /> (potassium and plagioclase 6.1%)and mafic aluminosilicates(21.4%),as well as magnetite(0.2%)and goethite <br /> (4.8%). <br /> Geochemical characterization of tailings and supporting buttress material was undertaken in 2021. Details and <br /> results of the program are given in GEM Services'report"Tailings Geochemistry Characterization and Seepage <br /> Quality Estimate,"provided in Appendix B of Zephyr Minerals'mine permit application. <br /> In summary,a tailings and tailings filtrate sample from the processing of altered and unaltered ore were <br /> subjected to acid base accounting(tailings solids)and water quality analysis(tailings filtrate)to determine their <br /> potential to produce acidic drainage and to release metals.Test results indicate both tailing types are non- <br /> potentially acid generating(non-PAG).The tailings filtrate quality meets the groundwater quality standard and is <br /> less than the background groundwater quality at the site." <br /> (And yet on page 49 of the applications appendices it states that,"Geochemical characterization of the Dawson <br /> and Windy Point tailings has not been undertaken.A synthetic sample of Windy Gulch tailings were shown to <br /> be"non-PAG"or"uncertain"potential for acid generation,depending on the evaluation method.Additional test <br /> work will be needed to characterize the geochemistry of the tailings."Which is it...potentially nonacid generating <br /> or uncertain?It really does make a huge difference.) <br /> 6.4.21(4)(a and b)]Other Permits and Licenses <br /> "WQCD will require a storm water and process water discharge permit. <br /> APCD will require Air Pollution Emission Notices(APEN)for GMR sizing equipment,facility fugitive dust and <br /> mine fans. <br /> FCDOT's access permit will require an access with a perpendicular approach to County Road 3A. It is also <br /> likely improvements to County Road 3A will be required." <br /> (BLM will require a R/W application and easement grant for telephone line and electric transmission line where <br /> they cross public lands. Improvements to County Rd.3A on public lands will require an easement modification <br /> with the BLM.An easement for the portion of their present access road to the mine site that crosses BLM will <br /> also require an easement if they continue to utilize it.) <br /> 6.4.21(6)(c) <br /> "Baseline groundwater monitoring indicates that groundwater will be encountered during ramp development. <br /> Ground water was encountered at 55 ft below ground surface on the south side of the permitted area and 175 <br /> ft. below ground surface in the vicinity of the mill building. During mine development,groundwater will be <br /> pumped to the natural drainage that discharges into the Arkansas River." <br /> (What erosion control methods will be utilized in the natural drainage that water is pumped to?) <br /> 13.1 Risks. (Page 49...2016 report in appendices) <br /> "The feasibility of tailings filtration to the optimum moisture content(approximately)has not been proven for the <br /> Windy Gulch or Dawson tailings. Consequently,the tailings filter plant sizing, capital cost,cycle times,operating <br /> costs,etc.are uncertain. Bench-scale pressure filtration test work is recommended in the next study phase. <br /> Geochemical characterization of the Dawson and Windy Point tailings has not been undertaken.A synthetic <br /> camnlP of Windv Gulch tailinns wPra chnwn to hp."nnn-PAC,"nr"iinrartnin"nntPntial fnr acid nanPratinn <br />