DRMS Comment Objection Intake - DEV 4/1/2024 (37)

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Comment/Objection Narrative* As a regular outdoor recreationist in the area (mountain biking, hiking, whitewater kayaking) with a BS in Resource Management from CSU, I am very much opposed to this plan to reopen the Leadville Mill and use cyanide to process mine waste piles transported by truck from Leadville's historic East Side mining district for a number of reasons... First and foremost, the impact on the upper Arkansas River basin and particularly the Leadville area is significant. Impacts include potential cyanide and other chemical contamination of surface and groundwater. The mill waste pile will be a potential source of water contamination risks forever, yet the mill plan does not address perpetual monitoring and management of the waste pile. High water consumption may reduce water availability in the Leadville area for residential and other uses. These water issues alone are so significant the mill should not be permitted to operate. Additionally and more specifically, I object to this application on these numerous grounds: use of cyanide in processing tailings; disturbance of and transport of tailings from East Side of Leadville to Mill site; no foolproof method to guarantee no leakage of cyanide & other chemicals from proposed dry stack method of storage of processed materials; threat of leakage into water table of cyanide/other chemicals into groundwater, affecting wells, fishing/rafting industry, irrigation water; potential of environmental catastrophe from leakage of toxic substances (e.g. via air, water) resulting in extreme adverse effects to County residents, visitors and the tourist economies of Lake County and neighboring counties; destruction of wildlife habitats and death of animals, fish in Lake County and beyond along the length of the Arkansas River; health risks associated with airborne toxic particulates ("fugitive dust"). Over the past several decades, countless hours of work and millions of dollars have been spent on repairing the devastating impacts of historic mining in Lake County on the Upper Arkansas River and its tributaries, particularly in the California Gulch watershed where the Leadville Mill and much of the targeted waste is located. As a result, the Upper Arkansas is now the longest continuous stretch of Gold Medal water in the nation. I would ask DRMS to consider if the risks of this project to the Leadville community and the surrounding environment are worth the benefits. In particular, I would ask DRMS to carefully consider the following: Does the CJK proposal adequately identify groundwater depth throughout the site or the preferential flow pathways/rates? In the instance of a spill, it would be necessary to have groundwater defined. Groundwater mapping would also play into a remediation plan in the instance of a spill. Those pathways must be identified and mitigated during an emergency to reduce impacts on drinking water supplies including wells in the area. Has CJK properly addressed concerns around the daily operations of the mill, such as mitigating impacts to wildlife and exposure to materials with elevated sodium -cyanide? This can include both terrestrial and aquatic wildlife/organisms. Has CJK properly addressed the disposal of processed waste throughout the life of the mine? Where will processed waste be disposed of or remediated to reduce impacts on human health and the environment? Does the life cycle of the proposed disposal plan fully mitigate the risks of its location in a highly sensitive environment? Does the CJK proposal address the risks to the community and the environment of disturbing the east side waste piles? The potential for release of toxic materials into the air, surface water, and groundwater must be addressed both during and after excavation. These waste piles have stabilized over time and disturbing them will increase the potential for erosion of freshly exposed surfaces by wind and water. Without this information and the proper safeguards in place (and it's dubious whether such safeguards truly exist to guard this kind of waste in perpetuity) this permit should not even be considered. It's not worth the the risk to the water, the environment as a whole, or to our tourist dollars.