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Mr. Dustin Czapla <br /> August 24, 2021 <br /> Page 2 <br /> Leadville Mill Permit Application <br /> Union Milling Company,LLC seeks a 112d permit so that it can reopen the Leadville Mill, <br /> after a decade of dormancy, with a newly added cyanide leaching process. It also seeks to add <br /> 12.7 acres of land to its permitted area and to increase operating capacity from 200 tons per day to <br /> 400 tons per day. This proposed operation threatens the drinking water wells and the general <br /> health, safety, and welfare of the Concerned Citizens. <br /> The Leadville Mill site is not an appropriate location for cyanide leaching operations. The <br /> site is bordered by residential properties and those properties obtain their drinking water from <br /> wells. Thus, neighboring residents will be exposed to fumes from the leaching process and their <br /> drinking water will be threatened by potential releases of cyanide and other hazardous materials at <br /> the Mill. Moreover, the proposed operating and waste management plans would not protect the <br /> community from releases of cyanide and other toxic chemicals. Therefore,the Concerned Citizens <br /> urge the Board to deny the Application. If the Board does not deny the Application,the Applicant <br /> should be required to revise its plans to include controls that provide protections consistent with <br /> the extreme hazards associated with cyanide leach operations. <br /> Objections to Permit Application <br /> Discharges of Toxic and Acidic Materials <br /> The proposed new process will utilize toxic and acidic materials, which could be <br /> discharged into the environment, and which will be disposed of on-site in a disposal pit. These <br /> materials will include sodium cyanide, sodium bisulfite, copper sulfate, lead nitrate, zinc oxide, <br /> borax,diesel fuel,and other chemicals. (Mining Plan § 4.2.4 at 4-10 thru 4-12.) An operation that <br /> relies upon, and ultimately disposes of, these chemicals, sodium cyanide in particular, should not <br /> be permitted so close to residential properties and drinking water wells. <br /> Cyanide, the principal process chemical for the proposed operation, is deemed"extremely <br /> toxic to humans" by the United States Environmental Protection Agency ("EPA").1 In its <br /> Toxicological Review of Hydrogen Cyanide and Cyanide Salts, EPA observed that: <br /> The effects of acute, high-level exposure to cyanide (CN—) are well characterized <br /> (reviewed in ATSDR, 2006; IPCS, 2004; U.S. EPA, 1992; and Hall and Rumack, <br /> https•Ilnepis e_pa gov/Exe/ZyNET exe/PlOOZHOL TXT?ZyActionD=ZyDocument&Client=EPA&Index=2016+T <br /> hru+2020&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntrv=&OField= <br /> &QFieldYear=&QFieldMonth=&QFieldDay=&IntQ Field Op 0&Ext Fie]dOp=O&Xm1Query=&File=D%3A%5Czy <br /> files%5CIndex%20Data%5C16thru20%5CTxt%5C00000019%5CP100ZHOL txt&User=ANONYMOUS&Passw <br /> ord=anonymous&SortMethod=h%7C- <br /> &MaximumDocuments=1&FuzzyDegree=O&ImageOuality r75g8Jr75g8/x150v150g16/i425&Dis121ay=h12fr& <br /> DefSeekPag_e=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&MaximumPaaes=1& <br /> ZyEntr�1&SeekPag_e=x&ZyPURL <br /> BURNS FIGA & WILL <br />