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channels will essentially be an expected event for the grandchildren of the current residents of Canon City.
<br /> As before,the available documents include no discussion of the consequences of overtopping of the diversion
<br /> channels, including possible impacts on the stability of the filtered tailings facility or the possibility of liquefaction
<br /> of the lightly compacted tailings. In summary,the proposed water management infrastructure for the filtered
<br /> tailings facility is entirely inadequate.
<br /> ...the method of upstream construction is the most dangerous because, if the underlying tailings undergo
<br /> liquefaction,the dam will simply fall backwards and downwards into the liquefied tailings,even if the dam itself
<br /> does not liquefy.(P42)
<br /> The filtered tailings facility crest would be 6495 feet,6523 feet,and 6541 feet after one,three,and five years of
<br /> operation, respectively(see Figs. 11-12). Based on a minimum elevation of 6420 feet for the filtered tailings
<br /> facility...,the tailings dam heights would be 75 feet, 103 feet, 121 feet,and 153 feet for the one-year,three-
<br /> year,five-year,and ultimate configurations,respectively....
<br /> Although the water balance diagram...shows a"Water Treatment Plant"before"Treated Water to Discharge,"
<br /> the available documents do not include any plan for a water treatment plant, including no discussion of the
<br /> contaminants that would need to be removed or how they would be removed. (P37)
<br /> In other words,the main body of the application(Environmental Alternatives,2021 a)states categorically that no
<br /> water treatment will be needed,while the appendices(Environmental Alternatives,2021 b)see the need for
<br /> water treatment as a later decision to be decided based upon the results of water quality monitoring. (P38)
<br /> ---end of Dr, Emerman's comments---
<br /> My water pollution summary and conclusion:
<br /> The limited water quality analysis conducted by Zephyr for the permit application shows that manganese will
<br /> increase in ground water as a result of mining operations; however,state and federal requirements forbid any
<br /> degradation of existing ground water quality and there is no discussion of how this contamination will be
<br /> addressed.The application also reveals that nickel and selenium in the discharge water will exceed surface
<br /> water quality standards for Grape Creek,yet the treatment of these constituents is not envisioned,as the
<br /> application simply states that a sediment pond will be constructed.
<br /> DRMS must require a more robust analysis on these points and HB19-1113 requires that an end date to the
<br /> treatment plan be demonstrated.Another faulty assumption is made when Zephyr states that the development
<br /> rock will be non-acid-generating without recognizing that the downward development of the mine will pass
<br /> through unknown zones containing sulfide minerals;there appears to be no analysis of this material at all,and,
<br /> as the mine pool develops,a degradation of water quality is likely to occur that is unacceptable. (Source:
<br /> Appendix to Dawson Gold Mine application, Section 2.1, p.3:"Development rock did not undergo long term
<br /> leach testing due to the absence of sulfides and its associated potential for accelerated metal release due to
<br /> oxidation.")
<br /> Zephyr plans to use a very high-risk method of upstream construction for the filtered tailings. Heavy rains
<br /> (similar to July 23,2018)could cause liquefaction of the tailings stack and release chemically treated tailings
<br /> into Grape Creek and then the Arkansas River.Where is the water treatment plant?Since tailings densities
<br /> were based on measurements on tailings samples from a different ore deposit(Windy Gulch),the application's
<br /> conclusions are not valid.
<br /> RECREATION:
<br /> Fremont County prides itself on its efforts to change the area's reputation from"mining and prisons"to a tourism
<br /> and recreation center.Over the past 10+years,the County,City,and other entities(e.g. Fremont Adventure
<br /> Recreation[FAR], Bureau of Land Management[BLM])have worked very hard and invested significant funds
<br /> toward this goal.
<br /> The potential mining operation puts our recreation opportunities along the Grape Creek and Arkansas River
<br /> corridors at risk.The Grape Creek area is a favorite spot for outdoor activity, including hiking,cycling,and
<br /> equestrian trails,as well as fishing. Local people and others who travel a considerable distance cherish the
<br /> quiet,scenic,natural landscape and the pristine features of the area. It is not uncommon to meet people who
<br /> have traveled to Ecology Park from Boulder(a solid three hour drive), Denver,Colorado Springs, Pueblo and
<br /> even the western slope just to be here.The hiking and bicycling trails in the area are beginning to receive
<br /> national recognition.
<br /> Grape Creek is well known for providing local anglers and tourists with opportunities to catch healthy rainbow
<br /> and brown trout.The wilderness character brings return tourism and long-term economic stability for outfitters
<br /> and businesses. Mining operation noise would severely affect the joy of fishing in the Grape Creek area and
<br /> would have a negative economic impact.
<br /> Any water pollution and any water depletion in Grape Creek will affect the fishing habitat and population.We
<br /> already face statistically hotter summers than in the recent past,something we have no control over.We do,
<br /> however, have control over approval of a gold mine that risks damage to this world-class fishing area.
<br /> Mining activity will create unavoidable disturbances and heavy traffic which will result in lower quality fishing,
<br /> decreased recreational use,and less local spending.
<br /> WILDLIFE:
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