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Mr. Dustin Czapla <br /> August 24, 2021 <br /> Page 7 <br /> Environmental Protection Plan <br /> The Environmental Protection Plan provides little assurance that the Concerned Citizens, <br /> their properties, and their drinking wells will be protected from harms caused by operation of the <br /> Mill and disposal of wastes in the pit. <br /> • The Environmental Protection Plan ("EPP") asserts, under the heading "Chemical <br /> Handling during Temporary Cessation or Closure", that "reagents will be either sold, <br /> recycled, or disposed of at an approved facility." (EPP at 21-11.) This term should be <br /> clarified to require disposal only at off-site permitted facilities. Leftover reagents should <br /> not be dumped into the disposal pit. <br /> • Run-of-mine ore will be located on a pad that is "designed . . . to contain potential ore <br /> leachate from entering the environment." (EPP at 21-11.) Applicant should be required to <br /> provide design specifications for this pad that clearly demonstrate how leachate will be <br /> contained. <br /> • Purportedly, the disposal pit will contain spills that breach the mill building, (EPP at 21- <br /> 12), but there is no explanation of how spills that breach the building, and thus evade the <br /> sump, will reach the disposal pit. There should be a clearly defined means of preventing <br /> these spills from entering the soil, groundwater, and surface water. <br /> • In several places, the Mining Plan and the EPP assert that only "small quantities" of <br /> chemicals will be used at any given time. This statement needs to be explained in greater <br /> detail. It is not clear whether Applicant intends to include chemicals in vats, such as the <br /> leach vats, as "in use." The Applicant proposes to use almost a ton of sodium cyanide <br /> every day. That is not a small quantity of a highly toxic chemical and does not justify a <br /> claim of environmental management by use of only "small quantities" of chemicals. In <br /> fact, Applicant should be required to develop detailed plans for how sodium cyanide, and <br /> the resulting cyanide waste, will be managed. Moreover, the plan should specify the <br /> maximum amount of each hazardous chemical that will be permitted as throughput in the <br /> system. <br /> • As discussed above, the EPP does not include any capacity to contain the volume of the <br /> single largest vessel on site. Secondary containment that can contain the full volume of <br /> the largest single vessel should be required. <br /> • Acidic and toxic waste material will be dumped into the disposal pit, including any <br /> contaminated debris and fluids from spills. (EPP § 21.7.5 at 21-15.) Wastes will include <br /> ore brought from sources within the California Gulch Superfund site that are acid <br /> producing that contain arsenic, lead and other hazardous constituents. Applicant should be <br /> required to provide analysis of the compatibility of these wastes and every other waste that <br /> will be placed into the disposal pit. Applicant also should be required to demonstrate the <br /> compatibility of the liner material with the wastes to be deposited into the disposal pit. <br /> BURNS FIGA & WILL <br />