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

• Permit No: M2021046
• IBM Index Class Name: Application Correspondence
• Doc Date: 9/1/2021
• Doc Name: Comment/Objection
• From: Michael Gromowski
• To: DRMS
• Email Name: TC1
• Email Name: TC1
• Media Type: D

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undetermined amount of water to Grape Creek and the Arkansas River.This helps maintain water levels and
temperatures of the creek and river. He believes it is possible that the mine's consumption of water could
reverse that flow: i.e.to fill an underground void,water could be drawn from the creek and/or river,further
depleting water resources.
The above analysis is acknowledged in the permit application.The following text is from section 2.7.1 of the
application;"The mine is expected to intercept some ground water within that material and will be dewatered to
allow for mining.Accordingly,the mine does have the potential to impact ground water systems in the vicinity of
the proposed mine as a result of the mine dewatering in the form of water level changes in the aquifers.The
ground water level changes have the potential to indirectly impact surface water systems in the form of stream
depletions."
Conclusions and objections:
Zephyr has not accurately stated its water consumption from underground sources, has an insufficient method
of monitoring water depletion,and it does not know how water depletion will be impacted.
WATER POLLUTION:
U.S. Gold Mines:Spills&Failures Report surveys federal and state data and news reports to compile operating
records of 27 operating U.S.gold mines accounting for 93%of national gold production.The study shows:
•Gold mines always spill-Gold mines responsible for 93%of U.S.gold production have accidentally spilled
cyanide,mine waste,diesel,or other hazardous materials.
•Gold mines almost always pollute water-74%of operating gold mines polluted surface and/or groundwater,
including drinking water.
•When gold mines don't pollute water, it's almost always because there's no water nearby-of the mines that
didn't pollute water,only one had a perennial stream in the project area.
Source(2017): New Study:74%of U.S.gold mines pollute water-Earthworks
Dr. Emerman's relevant conclusions:
#4 There is no plan for the treatment of mine water before it is released into the environment.
#6 The application never uses the word"dam"and does not recognize that the structural zone of the filtered
tailings facility would constitute a dam that should conform to dam safety standards.
#7 The structural zone/dam would be constructed using the upstream method in which the dam is built on top of
the lightly-compacted tailings that it is confining. In the event of the liquefaction of the tailings,the dam will
collapse into the underlying tailings. For that reason,the method of upstream construction is illegal in Brazil,
Chile, Ecuador and Peru.
#8 There is no consideration of the susceptibility to liquefaction of the lightly compacted tailings confined by the
structural zone or the circumstances under which liquefaction could occur.
#9 The documents from Zephyr Minerals Ltd include no consideration of the consequences of failure of the
filtered tailings facility.According to a statistical model of past tailings dam failures,following failure of the
tailings dam at the Dawson mine, under the most-likely scenario(loss of 35%of the stored tailings after 5 years
of operation),the tailings will travel 11,905 feet during the initial runout. Under the worst-case scenario(loss of
100%of the stored tailings after 5 years of operation),the tailings will travel 37,098 feet(over 7 miles)to Grape
Creek and then to the Arkansas River and through the center of Canon City during the initial runout.
Subsequent normal fluvial processes will transport the tailings indefinitely down the Arkansas River
#10 Based on Colorado,as well as most national and international dam safety standards,and the potential for
loss of human life and habitat destruction following dam failure,the filtered tailings facility should be designed to
withstand at least 90%of the Probable Maximum Precipitation(PMP).
#11 Although the static stability analysis of the filtered tailings facility indicated an acceptable factor of safety,all
geotechnical input parameters were assumed without justification.The tailings densities were based on
measurements on tailings samples from a different ore deposit(Windy Gulch),an assumed ability to compact
the tailings to 95%of the maximum density within the structural zone,and an apparent confusion between dry
and moist unit weights.There was no mention of the assumed height of the water table or any discussion of the
water table height that would result in dam instability or the circumstances under which such a water table
height would occur.
#12 The diversion channels for the filtered tailings facility would be designed to accommodate a 24-hour storm
with a return period of 10 years during mine operation.On that basis,the probability of rewetting the tailings by
runoff would be 10%in any given year of mine operation and 41%over the five years of mine operation.
Following mine closure,the diversion channels would be reconstructed to accommodate a 24-hour storm with a
return period of 100 years,so that the probability of rewetting the tailings by runoff would be 1%in any given
year of the indefinite period of mine closure.There is no analysis of the consequences of rewetting either in
terms of dam stability or increasing the susceptibility of the tailings to liquefaction.
The design of the channels to accommodate a 24-hour storm with a return period of 100 years after mine
closure means that, in any given year of the indefinite time period following mine closure,the probability of
overtopping of the channels will be 1%. On that basis,the probability that overtopping of the channels will occur
at least once durinq,say,the next 60 years(two human qenerations),is 45%,so that overtoppinq of the