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2023-04-19_REVISION - M1990057 (34)
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2023-04-19_REVISION - M1990057 (34)
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Last modified
3/26/2024 9:17:23 AM
Creation date
4/19/2023 10:51:38 AM
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Template:
DRMS Permit Index
Permit No
M1990057
IBM Index Class Name
Revision
Doc Date
4/19/2023
Doc Name
Comment/Objection
From
Christopher Lamson
To
DRMS
Type & Sequence
CN2
Email Name
LJW
LJW
Media Type
D
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Comment/Objection Narrative* <br /> Collegiate Peaks Chapter of Trout Unlimited(CPCTU)would like to express concern over the CJK Milling <br /> Company application to reopen the Leadville Mill to process existing slag piles from around Lake County using <br /> sodium cyanide. <br /> CPCTU is a local 501(c)3 conservation organization whose mission is for current and future generations of the <br /> Upper Arkansas River Valley to enjoy,appreciate,and cherish our waters,and to carry on the mission of <br /> protecting the quality watershed for present and future generations.CPCTU volunteers have been working to <br /> preserve and protect the Upper Arkansas River watershed since 1985. <br /> Over the past several decades,countless hours of work and millions of dollars have been spent on repairing the <br /> devastating impacts of historic mining in Lake County on the Upper Arkansas River and its tributaries, <br /> particularly in the California Gulch watershed where the Leadville Mill and much of the targeted slag is located. <br /> As a result,the Upper Arkansas is now the longest continuous stretch of Gold Medal water in the nation. <br /> We would ask DRMS to consider if the risks of this project to the Leadville community and the surrounding <br /> environment are worth the benefits.Of particular note,we would ask DRMS to carefully consider the following: <br /> •Does the CJK proposal adequately identify groundwater depth throughout the site or the preferential flow <br /> pathways/rates?In the instance of a spill, it would be necessary to have groundwater defined.Groundwater <br /> mapping would also play into a remediation plan in the instance of a spill.Those pathways must be identified <br /> and mitigated during an emergency to reduce impacts on drinking water supplies and Evans Gulch. <br /> •Has CJK properly addressed concerns around the daily operations of the mill,such as mitigating impacts to <br /> wildlife and exposure to materials with elevated sodium-cyanide?This can include both terrestrial and aquatic <br /> wildlife/organisms. <br /> •Has CJK properly addressed the disposal of processed slag throughout the life of the mine?Where will <br /> processed slag be disposed of or remediated to reduce impacts on human health and the environment?Does <br /> the life cycle of the proposed disposal plan fully mitigate the risks of its location in a highly sensitive <br /> environment? <br /> •Does the CJK proposal address the risks to the community and the environment of disturbing the slag piles? <br /> The potential for release of toxic materials into the air,surface water,and groundwater must be addressed both <br /> during and after excavation.These slag piles have stabilized over time and disturbing them will increase the <br /> potential for erosion of freshly exposed surfaces by wind and water. <br /> The Upper Arkansas River is a treasured resource that supports the recreational economy of many towns along <br /> its banks,as well as supplying irrigation and drinking water to millions of downstream Colorado residents.Any <br /> project with the potential to destroy this resource at its headwaters must be examined with the utmost diligence <br /> to ensure that its operation and its legacy wastes cannot harm the local community or the environment upon <br /> which so many depend for their quality of life and livelihoods.Thank you for taking our concerns into account as <br /> you review the CJK permit application. <br /> Sincerely, <br /> Chris Lamson <br /> President <br /> Collegiate Peaks Chapter of Trout Unlimited <br /> Permit Number* <br /> Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. <br /> M1990057 <br /> Permitting Action Type <br /> Select revision type or leave blank if comment pertains to a new permit application or NOI <br /> Permit Type <br /> County <br /> Lake <br /> Enter one county only <br />
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