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2023-09-07_REVISION - M1990057
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2023-09-07_REVISION - M1990057
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Entry Properties
Last modified
9/13/2023 8:40:17 AM
Creation date
9/11/2023 9:13:21 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1990057
IBM Index Class Name
Revision
Doc Date
9/7/2023
Doc Name Note
Response to Objection to Application
Doc Name
Response to Objection to Application
From
CJK Milling
To
DRMS
Type & Sequence
CN2
Email Name
LJW
THM
Media Type
D
Archive
No
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Burns Figa&Will 5 <br /> September 5,2023 <br /> Wildlife <br /> The Colorado Department of Natural Resources has reviewed our application and mandated that <br /> certain mitigations be included in the design to protect wildlife. CJK has reached out to DNR to <br /> properly address these measures and is working with them to determine how best to implement <br /> those mitigations. <br /> County (CUP) Issues <br /> Some of your concerns in this section are regulated/managed by the County. As such, they may <br /> not be specifically addressed in the CDRMS permit, but will be addressed at the County level <br /> under the required Conditional Use Permit (CUP) which cannot be submitted until the State <br /> Reclamation Permit is approved. The below responses to your concern (and other CUP-level <br /> concerns expressed by others therefore may change). Please keep in mind that all residents will <br /> also have the opportunity to voice these concerns in public during the CUP process. <br /> • Sound /Vibration <br /> Leadville ordinance mandates 75dba at the property line. The process design addresses this <br /> requirement. The crusher will be the primary contributor to vibration. However, the crusher is <br /> small and calculations show that vibrations will be imperceptible and no threat to structures or <br /> public well-being. CJK is in the process of installing noise, dust and vibration monitors on the <br /> facility property near the neighboring homes. Data will establish baseline values and assist in any <br /> design modifications that may be required to meet county requirements. Also, there will be no <br /> truck traffic after dark. Note that CJK has reached out to Leadville Sanitation with respect to their <br /> concerns. <br /> Reclamation <br /> Mine closure and reclamation is a permit requirement. A comprehensive reclamation plan is <br /> required for both normal closure or closure if the operation has to stop unexpectedly for any <br /> reason. This plan is reviewed and approved by CDRMS prior to permit approval. Additionally, <br /> CDRMS will determine the cost for closure and require a cash bond be posted for that amount <br /> before construction and operations can commence. <br /> The Penn Mine permit accounts for approximately 500,000 tons of material to be removed. The <br /> mill is being permitted to process these tons, and the capacity of the proposed filtered tailings <br /> deposit is for these 500,000 tons. The mill project life proposed in the amendment application is <br /> for this quantum and is expected to be between 3-5 years at a nominal rate of 400tpd and <br /> accounts for weather as well as unforeseeable events. Placing more than about 500,OOOtons in <br /> the FTD will require a permit modification. The origin of the 18-year mine life assumption yielding <br /> the 2.6million ton value is not known. <br /> Operation of the Site <br /> • The mill will function 24-7. While there are sound restrictions, such a facility operating in <br /> one's back yard would still have an impact on the normal peace and quiet found in the <br /> woods. <br /> As discussed above, mill operation requirements are proposed, but will be determined during the <br /> CUP process. While the mill is proposed to operate 24-hours per day, 7 days per week, it is also <br /> proposed that truck traffic and crushing operations be limited to daylight hours. In all instances, <br /> county-mandated noise limits remain in place. <br /> • Probably the most disingenuous action that CJK took in the most recent application is to <br /> change the boundaries of their project to ensure the residences are not within the 200 ft. <br /> boundary. A reading of the regulations makes it clear that all this action does is relieve <br />
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