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of mine waste have leached into groundwater over time. Many homes are on well water within 3 miles of the
<br /> mine, but the application does not mention a potential impact to these groundwater sources.The application
<br /> states there has not been any site-specific study of the aquifer that feeds the area.
<br /> Understanding the full impact to the watershed would necessitate a mapping of the
<br /> proposed underground and surface activity. Even then, rocks can shift and crack in
<br /> surprising ways,as evidenced by the rock work in Boulder Canyon several years ago, in which much more of
<br /> the rock fractured than anticipated by the professional demolition company working on Hwy 119. In many areas
<br /> where mines have filled cavities with a waste slurry,the cavities open as fissures form in shifting rock,and toxic
<br /> waste leaches into water sources. Regarding the mill proposed.The application states the activity will
<br /> necessitate the inclusion of the milling activity,which could impact air quality,water quality,and soil quality.
<br /> However, no such plans are provided here,and applicant is vague about any impacts that operation could have
<br /> on the surrounding environment,especially if any endangered species,such as cutthroat trout,are found in
<br /> Coon Track Creek. Milling activity could lead to even greater environmental concerns than the mine operations,
<br /> with even more chemicals or other hazards present on site.When an application for this mill is received by the
<br /> Division, I would ask that a public notice and public comment period be opened.The application for a mill
<br /> should also include an environmental assessment,completed by a professional third party,and should include
<br /> recommendations from CPW and other relevant entities.
<br /> Regarding Reclamation Plans
<br /> The plans provided are insufficient for exploring the full range of potential detrimental impacts to the
<br /> environment and the public.The aquifer referred to in the application that would potentially be impacted,"has a
<br /> refill rate of 1-500 years".This wide range indicates GIR lack of interest in preserving the aquifer. Mining
<br /> requirements include that the applicant must thoroughly understand the waters they may impact and return the
<br /> land to a natural state after activity ceases.The application also states the reclamation plan is for within 5
<br /> years,then purports that it will only take 3 years.This is because the plans are very basic in nature.They claim
<br /> no need for remediation of any site,simply grade,cover with topsoil,and plant.This is perhaps sufficient
<br /> rehabilitation of land for a road, rock pile,or other areas, but this does not feel sufficient for closing mineshafts.
<br /> The vegetation plans are lacking in biodiversity.The plan states the operator will purchase a bulk grass seed
<br /> mix and add in some yarrow.This is a good start to a vegetation plan but is not by any means sufficient to
<br /> reclaim almost 10 acres(or more if activities occur on the 200+acres requested).
<br /> Surface water diversion methods are to be left in place to deteriorate, including buried water lines that
<br /> discharge from the mine.This does not seem sufficient to restore the land to a natural state.
<br /> Rock shifts and moves over time, meaning closed entryways can re-open,as well as new cracks can open in
<br /> areas expected to be contained.The paste backfill method mentioned could be a huge risk to groundwater if
<br /> rock were to shift and dislodge any toxic material into nearby water sources. Regarding this"pilot project"
<br /> operation. Furthermore,A GIR representative stated,when referencing a new ore processing facility,a septic
<br /> system,and a road to connect the two mines"that the mines were to be GIR's"pilot project,"to serve as a
<br /> template for their future business
<br /> operations."If any approval were to occur, it should be only under strict and frequent monitoring for impacts to
<br /> the environment!
<br /> They are currently testing the efficacy of their wastewater treatment method.The plan mentions"periodic"
<br /> testing of water and wastewater,yet it is unclear how often it will occur.Testing should occur whenever there is
<br /> an out-of-ordinary incident,and at least weekly if not more frequently to ensure any hazards are identified and
<br /> remediated as quickly as possible. If they cannot guarantee reasonably clean water discharge,operations
<br /> should not be allowed to continue. Further,testing should occur on multiple places on the property to ensure
<br /> that no other contamination is occurring,such as oil leaking from parked equipment or ore storage containers.
<br /> The rock currently on-site is non-acidic, however it does not seem the plan includes any methods for further
<br /> monitoring/testing of ore to determine its acidic nature.Given the long-standing history of the environmental
<br /> hazards produced by stoping in other areas of Colorado,operations should not be allowed to continue without
<br /> stringent monitoring efforts to ensure all water coming from mine activity(including but not limited to waste
<br /> piles,settling tanks,container facilities,sheds and buildings, parking lots,water flowing from mineshafts)is
<br /> reasonably clean.
<br /> They are currently testing their paste backfill method,which seems to be crucial to some of their reclamation
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