2021-08-30_REVISION - M1990057 - Laserfiche WebLink

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August 24, 2021 Page 2 analyze effluent for the following pollutants: arsenic,cadmium,chromium,copper,lead,mercury, molybdenum,nickel, selenium, silver, zinc, cyanide, and phenols. The District spends significant amounts of time and money trying to comply with its discharge permit and cannot afford to have its operations jeopardized by any nearby activities that might impact its ability to meet CDPHE's strict permit limits. The District is also operating under Cease and Desist Order No. DO-181109-1 dated November 9, 2018, issued by CDPHE and requiring the District to comply with permit effluent limitations, specifically for the 30-day average mercury limit of 0.077 µg/L. Low level mercury is present throughout Leadville in the soil, water, and air due to historic mining operations. The District is concerned that the Applicant's proposed increased operations will only make it more difficult to meet the CDPS permit limits and comply with CDPHE's Cease and Desist Order. See JVA Memo. In addition, as noted in the JVA Memo, the Applicant proposes in Table 5-2 to report contaminants in mg/L. The District's permit limits are stated in µg/L. The Applicant's testing may miss reporting some contaminants that are not detected because the reporting limits are not as refined. The Applicant should also test and report in µg/L. Cyanide Although processing gold ore with cyanide may be standard in the industry,it is not without risk. The Material Safety Data Sheet("MSDS") for sodium cyanide shows it to be identified with the following hazards: corrosive to metals, acute oral toxicity, acute dermal toxicity, acute inhalation toxicity, and specific target organ toxicity(single exposure). It is fatal if swallowed, in contact with skin, or inhaled. It is also "[v]ery toxic to aquatic life with long lasting effects." Application, Appendix 21-2. There have been a number of serious incidents around the world involving cyanide spills and leaks. The amount of sodium cyanide the Applicant proposes to use, 1,600 pounds per day, is not insignificant. Application, Exhibit D, Table 4-6. The mere fact of the next door neighbor using so much cyanide gives the District concern. In addition, the District is concerned that the Applicant has not demonstrated that it has significant experience working and processing ore with cyanide. Showing a high level of expertise should be required before approving the permit conversion. Air Quality The Applicant's expanded operations and handling of ore threaten to impact the District's wastewater treatment facility with airborne heavy metals and toxic particulates in the form of fugitive dust leaving the Applicant's property. To the District's knowledge,although the Leadville Mill may have been permitted to process 200 tons per day, it rarely ran continously at anything