DRMS Comment Objection Intake 9/1/2021 10:39:17 AM

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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--- I 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, I see the following key risks associated with mining operation: WILDFIRE 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"does not explain or quantify anything.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 the entire region.Given the catastrophic possibility of fire, promising a fire prevention plan will be included is unacceptable. WATER DEPLETION RISKS: The 2017 Zephyr 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 cooling,reagent mixing,process make-up,and potable water purposes throughout the plant. Drinking water will be hauled in from the nearby town."The relevant point is that the report specifies 3,258,720 gallons of fresh water will be consumed annually(6.2 gallons*60 minutes*24 hours*365 days)from underground sources. Dr. Emerman's relevant conclusions: #2 The predicted water consumption of 9.8 gallons per minute 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.A more reasonable water consumption would be 100 gallons per minute,which would need to be supplied from groundwater. #3 The predicted regional drawdown from dewatering the underground mine did not take into account the additional groundwater that would be pumped from a supply well.The dewatering calculation also did not consider the long-term impacts of dewatering or the time required to restore the equilibrium of the groundwater system. #5 There is no mention of the possibility of water treatment for the water that is recycled through the mining operation and no analysis of the increase in the dissolved solids content of the process water that could occur due to recycling without treatment. In fact,saturation of the process water could result in precipitation of salts on all contact surfaces and in the tailings filter presses,which would render the filter presses non-functional. In addition,there is no discussion as to how the process water could still function to extract the gold concentrate with a high dissolved solids content. ---end of Dr. Emerman's findings---