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2021-08-25_REVISION - M1990057
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2021-08-25_REVISION - M1990057
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Last modified
12/28/2024 1:41:57 PM
Creation date
8/26/2021 9:03:02 AM
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Template:
DRMS Permit Index
Permit No
M1990057
IBM Index Class Name
REVISION
Doc Date
8/25/2021
Doc Name
Objection
From
BFW Law
To
DRMS
Email Name
DMC
Media Type
D
Archive
No
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Mr. Dustin Czapla <br /> August 24, 2021 <br /> Page 3 <br /> 1990). Although acute oral doses of cyanide cause cardiovascular,respiratory, and <br /> neurophysiological changes, the brain appears to be the organ most sensitive to <br /> acute cyanide toxicity (IPCS,2004). Several studies of the acute effects of cyanide <br /> in humans, following suicide attempts or accidental poisoning by the oral and <br /> inhalation routes, provide additional details, although most such studies include <br /> only a limited characterization of exposure. Symptoms of severe cyanide poisoning <br /> include vomiting,nausea,weakness,confusion,lethargy,cyanosis,weak and ataxic <br /> movements, increased respiratory and heart rates progressing to coma with <br /> respiratory depression, seizures, cardiovascular collapse, and death. The principal <br /> feature of the acute toxicity profile for cyanide includes lethality by all routes of <br /> administration, with a steep rate-dependent dose-response curve. <br /> (Id. § 4.1.1 at 18.) These hazards are acknowledged in Applicant's proposed Environmental <br /> Protection Plan, which lists the following potential human effects: <br /> • Fatal is [sic] swallowed <br /> • Fatal in contact with skin <br /> • Fatal if inhaled <br /> • May cause respiratory damage <br /> • May cause drowsiness or dizziness <br /> • Causes damage to organs <br /> • Causes damages to organs through prolonged or repeated exposure <br /> m(Environental Protection Plan Table 21-3.) The Application also affirms that sodium cyanide is <br /> "Soluble in water," (id.), meaning it will migrate in groundwater and surface water, and is "Toxic <br /> to aquatic organisms." (Id.) <br /> Due to the exceptionally high toxicity of cyanide, it is listed as a"hazardous waste"under <br /> the Resource Conservation and Recovery Act (6 CCR 100703, Part 261, Appendix V11 (FO07- <br /> FO11 wastes) and Appendix V111 (P030 cyanide,and P106 sodium cyanide)) and as an"extremely <br /> hazardous substance" under the Emergency Planning and Community Right to Know Act. (40 <br /> C.F.R. Part 355, Appendix A.) Cyanide also is a "hazardous substance" under the Clean Water <br /> Act (40 C.R.R. § 116.4 (listing hydrogen cyanide, sodium cyanide, and other cyanide <br /> compounds)). <br /> A chemical as dangerous as cyanide must be handled with the greatest of care and should <br /> not be used and disposed of next to residential properties and domestic wells. However,Applicant <br /> proposes to use 24 tons of sodium cyanide per month. (Mining Plan at 4-11). Applicant also <br /> BURNS FIGA &WILL <br />
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