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2024-03-12_REVISION - M1990057 (17)
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2024-03-12_REVISION - M1990057 (17)
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Last modified
4/1/2024 1:32:23 PM
Creation date
3/12/2024 9:30:12 AM
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Template:
DRMS Permit Index
Permit No
M1990057
IBM Index Class Name
Revision
Doc Date
3/12/2024
Doc Name
Comment/Objection
From
William Cincilla
To
DRMS
Type & Sequence
CN3
Email Name
LJW
THM
Media Type
D
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Comment/Objection Narrative* <br /> I am a State of Colorado Registered Professional Engineer,graduate of the Colorado School of Mines and <br /> practicing mining engineer with over 40 years of relevant professional experience. I have also been engaged by <br /> CJK Milling to provide guidance and design support covering a wide area of the Leadville Mill project water and <br /> waste management programs.Of the hundreds of domestic and international mining and mineral waste projects <br /> that I have personally participated in over the course of my career,this one is particularly unique in that the <br /> developers of the projects have maintained a level of sensitivity to community and environmental performance <br /> that I have rarely experienced. From the very beginning of my engagement with Gary and Nick,they impressed <br /> on me their objective to conduct their business with the highest levels of integrity,transparency and professional <br /> care.This project is also unique in that while it has mineral processing focus, meaning extraction of valuable <br /> residual metals from the historic Penn Group waste dumps,the net result of the process is an intended benefit <br /> of the remediation of mine scarred lands and elimination of all of the long-term negative effects from sediment <br /> runoff and potential leaching of metals into local groundwater,with full restoration of the land to near its original <br /> pre-mining era conditions.All of this is financed privately,and no tax-payer subsidies or grants are involved. <br /> The project in its essence is a privately funded environmental remediation project at NO COST TO THE <br /> PUBLIC and the local community of Leadville that only accrues benefits.This project is a win for all parties <br /> involved.My professional expertise,as a subject matter expert, is in the area of mineral waste management. <br /> The current process flowsheet for the mill involves the use of cyanide to recover gold.Cyanide is a widely used <br /> industrial chemical and after the extraction process is completed,any residual cyanide or cyanide constituents <br /> are completely detoxified so that nothing will leave the indoor controlled environment of the plant and the <br /> process residue or tailings that are created can be safely disposed of. In the case of the tailings form the <br /> Leadville Mill,they will be filtered to remove most of the entrained water and can be managed in a similar way <br /> that sand is managed in a typical aggregate operation.This filter cake will be placed in thin lifts inside of a <br /> double lined landfill and compacted to form a stable engineered fill that will be reclaimed concurrently as the <br /> filling operation proceeds.Chemical analysis of the material, unlike almost all mineral wastes that I have been <br /> involved with, meets all USEPA and CDPHE standards as a NONHAZARDOUS waste,even to the point <br /> where it could be acceptable for placement in a typical solid waste landfill in the state of Colorado.Ther is NO <br /> "tailings dam"so to speak as there is no liquid impounded and all the recovered liquid from the filtration of the <br /> tailings is returned to the process for beneficial use,thus reducing the need for fresh water.As a final note, I am <br /> both personally and professionally very proud of the work effort that I have been involved with at the Leadville <br /> Mill project.The CJK organization has gone well above and beyond in their efforts to be good neighbors,and to <br /> advance their project in a manner that is truly admirable.Considering the huge negative toll that some historic <br /> metal mining and milling has taken on numerous Colorado communities,this type of project should be <br /> welcomed with open arms anywhere it is being proposed as an approach to cleanup of mine scarred lands and <br /> provide a wide range of economic benefits to the local community. I therefore fully support CJK and happy to <br /> endorse the project and provide any additional professional perspective as a practicing professional engineer. <br /> Permit Number* <br /> Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. <br /> M1990057 <br /> Permitting Action Type <br /> Permit Revision <br /> Select revision type or leave blank if comment pertains to a new permit application or NOI <br /> Permitting Action Sequence* <br /> 1 <br /> Permit Type <br /> 112 <br /> County <br /> Lake <br /> Enter one county only <br /> Site Name <br /> Leadville MITI <br /> Perm ittee/Operator Name <br /> CJK Milling Company, LLC <br />
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