DRMS Comment Objection Intake 8/31/2021 7:06:13 PM

Home Browse Search

Dr.Steven Emerman(Hydrologist)analyzed the permit application. Dr. Emerman has a B.S. in Mathematics from The Ohio State University, M.A.in Geophysics from Princeton University,and Ph.D. in Geophysics from Cornell University. Dr. Emerman has 31 years of experience teaching hydrology and geophysics, including teaching as a Fulbright Professor in Ecuador and Nepal,and has 70 peer-reviewed publications in these areas. He reports:"The application for the Dawson gold mine includes three fundamental flaws that require rethinking of the project from the very beginning.The first fundamental flaw is the underestimation of the water consumption of the gold mine by an order of magnitude. In summary,at the present time,there is certainly no assurance that mine dewatering could supply the probably necessary 100 gallons of water per minute.The predicted water consumption is 18.4%and 6.6%of the average for the gold mining industry, based on ore production and gold production respectively,even after adjusting industry averages for the reduction in water consumption resulting from filtered tailings technology.This is what is meant by a fundamental flaw that requires rethinking from the ground up. If there is no adequate source of water,then there is no way to construct a gold mine at the proposed location. It would be completely unacceptable for a regulatory authority to allow a mining project to go forward that was going to consume ten times as much water as it claimed that it was going to consume." "The second fundamental flaw is the assumption that water could be endlessly recycled through the mining operation with no chemical water treatment and no adverse effects.These adverse effects arising from a build- up of the dissolved solids content of the process water could include precipitation of salts onto all contact surfaces,clogging of pipes,clogging of the filter presses,and most importantly,the potential inability of the process water to function for the extraction of the gold concentrate. Finally,there is the problem of what to do with all of the saline process water when the mine is closed and the recycling of water ceases.The introduction of chemical water treatment into the mining circuit is not a minor matter and requires rethinking from the ground up" "The third fundamental flaw is the failure to acknowledge that the structural zone of the filtered tailings storage facility would constitute a dam and should conform to dam safety standards.This is not simply a matter of,say, the mining company agreeing to add a layer of rockfill as armor on the outer embankment of the structural zone.Thus far,there has not even been any consideration of state, national or international guidelines for dam safety.On that basis,at the present time,there is no way to know whether it is even possible to construct a safe tailings storage facility at this particular location.As with the other fundamental flaws,the means for safe permanent tailings management needs to be rethought from the ground up." ---end of Dr. Emerman's findings--- We see a fourth fundamental flaw. Because the Dawson tailings sample size was limited to two samples,this results in a lack of knowledge of the acid-generating potential of the tailings.The source for this conclusion is from the GEM Services study appendix B dated June 2021 where it states:"Short term metal release was assessed using the shake flask extraction procedure(MEND,2009)for the development rock and analyzing the filtrate from the two tailings samples by ICP-MS."How can Zephyr satisfy any of the many state requirements regarding prevention of acid mine drainage if they don't even know whether the tailings are potentially acid- generating? In addition to fundamental flaws,we see the following key risks associated with mining operation: WILD FIRE RISKS: More than 800 homes lie within 1.5-4 miles east of the planned gold mine location,downwind(winds are normally westerly). Downtown Canon City,a town of 17,141, is 4 miles away. The planned gold mine area is a semi-arid region with abundant amounts of fuel for a wildfire.A single spark can ignite and destroy acres of forest, homes, businesses,and wildlife country. The application doesn't adequately address fire risks. •The application states, "Bottom portion of the filtered water tank will be dedicated to storing sufficient volume of water for firefighting".(2.4.3.4.2)Sufficient?The amount of water stored and dedicated strictly for firefighting should be specified. •The application states that a fire prevention plan will be submitted. However,there is no fire prevention plan currently included. How can government entities approve the application without an assurance of being able to mitigate a fire before it becomes a wildfire?An application should provide absolute assurance of the ability to mitigate a fire before it becomes a wildfire.The mine location is in a semi-arid juniper forest,on rugged terrain which is essentially a tinder box.With 13,000 pounds of explosives(replenished per week)and 8,400 gallons of diesel fuel onsite,and with no established fire protection plan,a fire could quickly explode into an inferno that destroys an entire region. Given the catastrophic possibility of fire,promising a fire prevention plan will be included is unacceptable. WATER DEPLETION RISKS: The 2017 Technical Report(which can be provided)states:"the plant will require 135 gpm of process water to operate while over 90%recycle rate will minimize fresh water usage. It is estimated that the mine will supply 3.6 gpm of water in the form of ROM moisture and mine water,and 6.2 gpm of fresh water will be required for