2024-04-04_REVISION - M1990057 - Laserfiche WebLink

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April 1, 2024 Page 3 . In addition, the District is concerned that the Applicant has not demonstrated that it has significant experience working and processing ore with cyanide. Showing a high level of expertise should be required before approving the permit conversion. Airborne Contaminants The Applicant's expanded operations and handling of ore threaten to impact the District's wastewater treatment facility with airborne heavy metals and toxic particulates in the form of fugitive dust leaving the Applicant's property. To the District's knowledge,although the Leadville Mill may have been permitted to process 200 tons per day, it rarely ran continously at anything near that amount of throughput. The amount of particulates leaving the Mill property will be much higher than it ever was in the past. The Application indicates that there will be at least two ore stockpiles, one topsoil stockpile, and one ECS overburden stockpile. Section 4.2.7 of the Application, Exhibit D, addresses dust control, but only within the Crusher and Mill buildings. The District is concerned that the transport and handling of large amounts of ore outside the buildings will lead to dust blowing onto its polishing pond and aeration basin, potentially impacting its water quality, operations, and permit compliance. Even small amounts of additional particulate matter containing mercury, cadmium, or zinc entering the polishing pond could jeopardize the District's compliance with its strict permit limits. Dust from the road running near the District's property boundary and polishing pond is also a concern. At a minimum,this road should be paved. The District is already hard pressed to meet compliance limits imposed by CDPHE. See JVA Memo. Filtered Tailings Deposit The Application includes a Filtered Tailings Deposit (FTD) instead of a Tailings Storage Facility (TSF). The operations will still, however, involve a significant amount of cyanide. Moreover, the FTD will be located uphill and even closer to the District's polishing pond. The District is concerned that runoff or seepage from the FTD could affect the District's operations and water quality. See JVA Memo. Seismic Impacts The District is also concerned about the potential damage to its facilities from the Applicant's seismic activity. The District's wastewater treatment facility consists of a headworks for screening and grit removal, two aeration basins, two covered clarifiers, a polishing pond, and a chlorine contact chamber for disinfection. The Applicant's operation of crushing equipment next door to the District's infrastructure threatens to crack foundations and pipelines that the District needs to operate its water treatment facilities. See JVA Memo. The Application, Exhibit S, Appendix 19-6, acknowledges the potential for localized seismic activity from the proposed Mill operation to have detrimental impacts on the sewer line and sanitation facilities. The Application