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cooling, reagent mixing, process make-up,and potable water purposes throughout the plant. Drinking water will <br /> be hauled in from the nearby town."The relevant point is that 3,258,720 gallons of fresh water will be consumed <br /> annually(6.2 gallons*60 minutes*24 hours*365 days)from underground sources. <br /> Dr. Emerman's relevant conclusions: <br /> #2 The predicted water consumption of 9.8 gallons per minute is 18.4%and 6.6%of the average for the gold <br /> mining industry, based on ore production and gold production, respectively,even after adjusting industry <br /> averages for the reduction in water consumption resulting from filtered tailings technology.A more reasonable <br /> water consumption would be 100 gallons per minute,which would need to be supplied from groundwater. <br /> #3 The predicted regional drawdown from dewatering the underground mine did not take into account the <br /> additional groundwater that would be pumped from a supply well.The dewatering calculation also did not <br /> consider the long-term impacts of dewatering or the time required to restore the equilibrium of the groundwater <br /> system. <br /> #5 There is no mention of the possibility of water treatment for the water that is recycled through the mining <br /> operation and no analysis of the increase in the dissolved solids content of the process water that could occur <br /> due to recycling without treatment. In fact,saturation of the process water could result in precipitation of salts on <br /> all contact surfaces and in the tailings filter presses,which would render the filter presses non-functional. In <br /> addition,there is no discussion as to how the process water could still function to extract the gold concentrate <br /> with a high dissolved solids content. <br /> ---end of Dr. Emerman's findings--- <br /> A local geologist has stated that the underground water sources today supply some undetermined amount of <br /> water to Grape Creek and the Arkansas River.This helps maintain water levels and temperatures of the creek <br /> and river. He believes it is possible that the mine's consumption of water could reverse that flow:i.e.to fill an <br /> underground void,water could be drawn from the creek and/or river,further depleting water resources. <br /> The above analysis is acknowledged in the permit application.The following text is from section 2.7.1 of the <br /> application;"The mine is expected to intercept some ground water within that material and will be dewatered to <br /> allow for mining.Accordingly,the mine does have the potential to impact ground water systems in the vicinity of <br /> the proposed mine as a result of the mine dewatering in the form of water level changes in the aquifers.The <br /> ground water level changes have the potential to indirectly impact surface water systems in the form of stream <br /> depletions." <br /> Conclusions and objections: <br /> Zephyr has not accurately stated its water consumption from underground sources, has an insufficient method <br /> of monitoring water depletion,and it does not know how water depletion will be impacted. <br /> WATER POLLUTION: <br /> U.S. Gold Mines:Spills&Failures Report surveys federal and state data and news reports to compile operating <br /> records of 27 operating U.S.gold mines accounting for 93%of national gold production.The study shows: <br /> •Gold mines always spill-Gold mines responsible for 93%of U.S.gold production have accidentally spilled <br /> cyanide,mine waste,diesel,or other hazardous materials. <br /> •Gold mines almost always pollute water-74%of operating gold mines polluted surface and/or groundwater, <br /> including drinking water. <br /> •When gold mines don't pollute water, it's almost always because there's no water nearby-of the mines that <br /> didn't pollute water,only one had a perennial stream in the project area. <br /> Source(2017): New Study:74%of U.S.gold mines pollute water-Earthworks <br /> Dr. Emerman's relevant conclusions: <br /> #4 There is no plan for the treatment of mine water before it is released into the environment. <br /> #6 The application never uses the word"dam"and does not recognize that the structural zone of the filtered <br /> tailings facility would constitute a dam that should conform to dam safety standards. <br /> #7 The structural zone/dam would be constructed using the upstream method in which the dam is built on top of <br /> the lightly-compacted tailings that it is confining. In the event of the liquefaction of the tailings,the dam will <br /> collapse into the underlying tailings. For that reason,the method of upstream construction is illegal in Brazil, <br /> Chile, Ecuador and Peru. <br /> #8 There is no consideration of the susceptibility to liquefaction of the lightly compacted tailings confined by the <br /> structural zone or the circumstances under which liquefaction could occur. <br /> #9 The documents from Zephyr Minerals Ltd include no consideration of the consequences of failure of the <br /> filtered tailings facility.According to a statistical model of past tailings dam failures,following failure of the <br /> tailings dam at the Dawson mine, under the most-likely scenario(loss of 35%of the stored tailings after 5 years <br /> of operation),the tailings will travel 11,905 feet during the initial runout. Under the worst-case scenario(loss of <br /> 100%of the stored tailings after 5 years of operation),the tailings will travel 37,098 feet(over 7 miles)to Grape <br /> Creek and then to the Arkansas River and through the center of Canon City during the initial runout. <br /> Subsequent normal fluvial processes will transport the tailings indefinitely down the Arkansas River <br /> #10 Based on Colorado,as well as most national and international dam safety standards,and the potential for <br /> loss of human life and habitat destruction following dam failure,the filtered tailings facility should be designed to <br />