DRMS Comment Objection Intake 8/26/2021 8:46:17 AM

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Your Phone Number* Used only to follow up. 7193453098 Extension Alternate Phone Number Used only to follow up. 7193312194 Alternate Phone Extension Connection to Operation Select all that apply ✓ Land Owner of affected land Structure Owner within 200' of affected land Mineral Owner Nearby Resident Adjacent Land Owner ✓ Concerned Citizen Government Agency Other DESCRIPTION OF COMMENT OR OBJECTION (Please be as specific as possible' Comment/Objection Narrative The following objections are provided in relation to the subject application, but are applicable to the entire permitting process as indicated below. Surface water contamination--leachate chemicals include Potassium Amyl Xanthate, Methyl IsoButyl Carbinol, and"generic"anionic emulsion flocculent.Xanthates are highly soluble,and animal studies indicate xanthates are linked to chronic damage to the liver and neurological system after long-term elevated exposure. (see the National Industrial Chemicals Notification and Assessment Scheme(NICNAS)Sodium ethyl xanthate assessment report, May 1995,for further information). Furthermore,Xanthates have been shown to bioaccumulate in organisms(Xu et al., 1988). For example,the disappearance of xanthate from water(conc. 0.025 pg/ml)has been found to be enhanced by addition of the aquatic plant duck weed (Lemna minor),which accumulates xanthates,and bioaccumulations factors(BCF)as high as 1000 have been reported for plant material(Xu et al., 1988).Xanthates have also been found to enhance the bioaccumulation of heavy metals(Boening, 1998)as they may form hydrophobic complexes with di-or trivalent heavy metals such as Zn,Cd, Pb and Cu.Those complexes facilitate uptake through organism cellular membranes and,by way of example,a ten-fold increase of Cd in trout gill tissue has been observed at xanthate levels as low as—0.2 pg/I (Block&Part, 1986). Finally,the ore bearing rock was supposedly tested by the mining company and found not to contain carbonate or sulfide compounds"in quantity."This is counterintuitive,as"gold commonly occurs in sulfide minerals"(USGS Circular 612,page 1). From their own geological characterization in the exhibit documents filed June 30,2021,"The mineralization is comprised of native gold along with 1 to 5 modal percent (average less than 3 percent)disseminated pyrite and minor chalcopyrite."These are sulfide minerals which generate acid runoff when exposed to water and air. Until actual large scale samples of ore bearing rock are analyzed for acid generating potential,the risk of acid mine drainage and all the attendant impacts must be considered as likely.Zephyr dismisses this possibility by claiming the rock is not potentially acid generating (non-PAG),but core samples are extremely limited and this assertion is unfounded,given the chemistry of gold- bearing ores and their own assays.The operation is directly in the watershed that supplies drinking water for Canon City, Pueblo(Pueblo Reservoir), Colorado Springs,and many downstream municipalities and should be disapproved because of the likelihood of surface water impacts. Inadequate remediation and reclamation plans--The amount of funding set aside to remediate the site, $261,813, is grossly inadequate to provide for restoration in a rugged area of unique character.The tailings pile alone will require an enormous effort to move,grade,and provide revegetation. Furthermore,the permit has already been expanded several times,and there is no guarantee that the current footprint will also not expand. Funding requirements for restoration should be estimated independently by a commercial firm that accomplishes such remediation,and the remediation escrow requirement should be increased to at least that