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2023-09-07_REVISION - M1990057
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2023-09-07_REVISION - M1990057
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Last modified
9/13/2023 8:40:17 AM
Creation date
9/11/2023 9:13:21 AM
Metadata
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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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Responses to Objections 4 <br /> September 5,2023 <br /> Step 3: Cyanide Destruction <br /> Most of the CN used in the process is reclaimed and re-used. However, the CN that cannot be reclaimed <br /> will be destroyed using ferric sulfite prior to disposal in the Filtered Tailings Deposit (FTD). The cyanide <br /> detoxification process is an industry-proven method. CN concentration in the FTD will be at a very safe <br /> level. <br /> Step 4: Filtered Tailings Disposal <br /> Detoxified tailings will be filtered to remove most of the water. The filtered material, moist like beach sand, <br /> will be stacked and compacted on a shallow slope. This design is stable. Further, since the material is not <br /> liquid, as contained in a conventional tailings facility, it will not travel more than a few feet in the unlikely <br /> event a portion of the facility experiences a slump. <br /> The FTD design is prescriptive and must be approved by CDRMS before operations can commence. <br /> Step 5: Containment Sump <br /> The Leadville Mill is designed as a zero-discharge facility. The entire facility is designed to be within a <br /> series of primary sumps to capture and contain leaks should they occur. In the unlikely event the primary <br /> sumps are overwhelmed by a spill; the liquids will flow directly into the secondary containment sump. <br /> The facility design allows all liquids to report to the primary and secondary sumps via gravity flow, so there <br /> is no risk of spillage caused by pump failure. <br /> The Primary sumps are lined to contain liquids. The secondary sump is doubled lined and also has leak <br /> detection and leak capture should the primary liner fail. <br /> In the event that liquids report to the secondary sump, milling operations will stop and the detoxification <br /> system will be used to immediately detoxify the water. Therefore, there will be no long-term sump <br /> containment of cyanide water. <br /> Step 6: Dust Control <br /> Dump material is generally damp. Nevertheless, the material surface will often be dry and dust control <br /> measures will be implemented as required. Roads will also become dusty. Roads will be sprayed with <br /> dust surfactants and water. Trucks will be covered during transportation. Material will be sprayed with <br /> water prior to loading in the crusher bin. The crusher facility will be an enclosed building with negative air <br /> pressure created by a dust collector. The material will be wet from the time it is introduced in the ball mill <br /> until it is deposited on the FTD. Water sprays as well as contemporaneous reclamation of the FTD will <br /> control dust from the tailings. <br /> Step 7: Water Quality <br /> Surface and Groundwater quality has been monitored and will continue to be monitored as required by law. <br /> Baseline water quality has been determined and will be used as the basis of maintaining (or improving) <br /> downstream water quality. <br /> Step 8: Wildlife <br /> The Colorado Department of Natural Resources has reviewed our application and mandated that fencing <br /> and other mitigations be included in the design to protect wildlife. CJK has reached out to DNR to properly <br /> address these measures. <br /> The project has and will continue to provide an economic benefit to Leadville and Lake County. Since 2020, <br /> CJK has spent over$1 million in services from local businesses and local consultants in Leadville. Leadville <br /> and Lake county residents will have priority to all jobs once operations commence. <br /> At CJK Milling,we are committed to transparency and stewardship. As a remediation company,our mission <br /> is to help clean up the environment and we welcome any additional questions you may have. <br /> Sincerely, <br /> For CJK Milling Company <br /> Nick Michael <br />
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