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y5i10~00 la: a9 LRND 3 wRTEP. FUND OF THE ROCKIES -~ 3038328106 N0.853 D05 application/permit to account for these facilities. It appears that Amendment B has too much ore production for the submitted facilities to handle. That is unacceptable. CC&V should either reduce production to eliminate the need for these facilities or resubmit Amendment 8 when they have complied with the Rules. CC&V has offered no compelling reason why it has submitted Amendment 8 without these critical features. Even if the company had a compelling reason, the law prohibiu the MLRB's approval of an application lacking such information. Simply put, the MLRB cannot "approve the concept" of an Environmental Protection Facility, it can only approve a ftdly detailed and designed facility. B. The Failure to Analyze the Full Spectrum of Constituents Released from the Valley Leach Faciliri Violates the Mined Land Act and MLRB Rules. The Application bases the "detoxification" of the Valley Leach Facility (VLF) almost exclusively on the attainment of an appropriate WAD Cyanide level. While of course such levels must be met before reclamation and performance requvements can be deemed successful, reliance on such s limited "test" is unacceptable from an environmental end fiscal standpoint. The spent ore that is rinsed must be monitored for CN species in addition to simply WAD-CN. Quite possibly, significant concentrations of SCN, CNO, SO4, NO3, NH3, metals, metalloids, etc. will remain in the VLF after WAD CN rinsing and H2O2 addition. CC&V makes no mention of the potential for these constituents and/or byproducts of designated chemicals (e.g., SCN and CNO aze not determined in routine WAD analyses). Many forms of these compounds are known to be toxie to aquatic life and otherwise harmful to the environment. CCBtV inappropriately disregards the tendency of high pH waters, above pH 8.0, to increase the solubility of many species, especially metal oxyanions, etc. Some of the increase insolubility/ mobility may also result from desorption of certaia metals/metalloids off FeOOH and other particles, which often occtus as pH rises. 'this phenomenon is commonly seen in spent gold ore leachates where the pH may be high. The issue of high pH leaohates is not cleazly covered. A full analysis of such enhanced solubility is required. Due to this inappropriate focus on WAD CN, the monitoring and reclamation plans for the VLF are inadequate. Since it is very possible that mobilization of such constituents may not appreciably occur until after the minimal 4-year monitoring proposed by CC&V is concluded, the monitoring and testing needed to asstare reclaznatiodperformance success and financial warranty mlease must be significantly increased. At a minimum, this increased time period should be based on the full constituent and mobilization analysis noted above. CC&V should ensure that all water quality standards will be met. The MLRB cannot approve an operation unless the applicant has provided evidence that the operation will at all times be in "compliance with applicable federal end Colorado water quality laws and regulations...." Rule 3.1.6. At a minimum, CC&V must analyze, test for, and assure full compliance with, all of the