2024-03-11_REVISION - M1990057 (31)

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Comment/Objection Narrative* Our key objections regarding the proposed mill operation has to do with its potential impact on water resources and the environment: 1.Water •The upper Arkansas River basin,specifically the Leadville area,faces significant consequences. •Impacts include potential cyanide and chemical contamination of surface and groundwater. •The mill waste pile poses a perpetual risk of water contamination,yet the mill plan lacks provisions for continuous monitoring and waste pile management. •High water consumption may reduce water availability for residential and other uses in Leadville. •These water-related issues alone warrant denying permission for mill operation. 2. Environment: Multiple grounds for objection: •Use of cyanide in processing tailings. •Disturbance and transport of tailings from the East Side of Leadville to the mill site. •Lack of a foolproof method to prevent leakage of cyanide and other chemicals from the proposed dry stack storage of processed materials. •Threat of contamination into the water table and groundwater,affecting wells,fishing, rafting,and irrigation. •Potential environmental catastrophe due to toxic substance leakage(via air or water),impacting residents, visitors,and local economies. •Wildlife habitat destruction and harm to animals and fish along the Arkansas River. •Health risks associated with airborne toxic particulates("fugitive dust"). 3.Arkansas River Impact: Decades of effort and substantial investment have been dedicated to repairing the historic mining impacts in Lake County. •The California Gulch watershed,where the Leadville Mill and targeted waste are located, has been a focus. •As a result,the Upper Arkansas River now boasts the longest continuous stretch of Gold Medal water in the nation1.-https:Hsupreme.justia.com/cases/federa1/us/503/91/ These objections highlight the critical environmental and water-related concerns associated with the proposed mill operation. Key questions that we want answers to before the permit is even considered for approval include: 1.Groundwater Depth and Flow Pathways: •Does the CJK proposal adequately identify groundwater depth and preferential flow pathways at the site? •In the event of a spill, understanding groundwater is crucial. •Groundwater mapping should inform a remediation plan to mitigate risks during emergencies and protect drinking water supplies. 2. Daily Mill Operations and Wildlife Impact: Has CJK addressed concerns about daily mill operations impacting wildlife? This includes both terrestrial and aquatic organisms. *Specifically, have they mitigated exposure to materials with elevated sodium-cyanide? 3. Processed Waste Disposal: •How will CJK handle processed waste throughout the mine's life? •Where will waste be disposed of or remediated to minimize health and environmental impacts? •Is the proposed disposal plan fully effective in a highly sensitive environment? 4. Risks of Disturbing East Side Waste Piles: •Does the CJK proposal address risks related to disturbing the east side waste piles? •Consider potential release of toxic materials into the air,surface water,and groundwater during and after excavation. These waste piles have stabilized over time,and disturbing them may increase erosion risks from wind and water. Permit Number* Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. M1990057 Permitting Action Type Select revision type or leave blank if comment pertains to a new permit application or NOI Permit Type