2021-08-30_REVISION - M1990057 - Laserfiche WebLink

Home Browse Search

August 24, 2021 Page 3 near that amount of throughput. The amount of particulates leaving the Mill property will be much higher than it ever was in the past. Section 4.2.6 of the Application addresses dust control, but only within the Mill buildings. The Application also indicates that two ore stockpiles will be located immediately to the west of the District's polishing pond. Application, Exhibit C, Figure 3-3. The District is concerned that handling large amounts of ore outside will lead to dust blowing onto its polishing pond and aeration basin, potentially impacting its water quality and operations. Dust from the road running next to the District's property boudary and polishing pond is also a concern. At a minimum,this road should be paved. The District is already hard pressed to meet compliance limits imposed by CDPHE. See JVA Memo. Tailingsge Facility The Application indicates that the TSF will be completed in the spring of 2021. Was it? It will also be based on stability analysis performed by CTL Thompson a decade ago. Application, Exhibit D, Section 4.3, and Appendices 22-5 and 22-6. The District has concerns about whether the work was done according to plan and whether such old engineering is sufficient. Moreover, the technical specifications for the TSF, including its liner, are not as robust as those for solid waste facilities elsewhere that contain materials less hazardous than those the Applicant will be handling. The District is concerned that the TSF could fail, leading to leakage of contaminants into groundwater and the District's collection system. See JVA Memo. The Application states that a leak detection system for the TSF will be installed in the spring of 2021. If cyanide leachate is detected in groundwater, then the groundwater will be pumped back into the impoundment and DRMS will be notified within 48 hours. Section 4.3.6 of the Application does not say anything, however, about stopping operations or fixing the leak. The District also understands that there was a recent rain event that caused one of the Applicant's ponds partially to collapse. Such an incident concerns the District about the Applicant's ability to build and operate expanded milling in a way that will not affect the District's facilities. Seismic Impacts The District is also concerned about the potential damage to its facilities from the Applicant's seismic activity. The District's wastewater treatment facility consists of a headworks for screening and grit removal, two aeration basins, two covered clarifiers, a polishing pond, and a chlorine contact chamber for disinfection. The Applicant's operation of heavy crushing equipment next door to the District's infrastructure threatens to crack foundations and pipelines that the District needs to operate its water treatment facilities. The District is further concerned