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i - • • III IIIIIIIIIIIII III STATE OF COLORADO ss9 Roy Romer, Governor DEPARTMENT OF NATURAL RESOURCES °~'OR~ DIVISION OF WILDLIFE c. o AN EQUAL WPOpNNIiY EMVLOYEP Perry D. Olson, Director pENVER E o , ,,• w ~ fiOfiO Broadway pFFIC . Denver, Colorado 00216 ~ N ' ~ T¢lephone: {303) 29]-1192 ~ 1 N ~t"' August 23, 1994 La Plata County Planning Dept. 1060 E. 2nd Avenue Durango, CO 81301 RE: Incas Mine Dear Carolyn: For wildlife For People I reviewed the plans provided and also spoke with the US Forest Service about the project. Please accept the following comments: While much of this project will also be regulated by the Colorado Department of Minerals and Geology, it seems appropriate that La Plata County take a keen interest in the project's entirety and not just "mainly for approval of visual aspects and size." Although not specifically mentioned in the project narrative, this application is for a cyanide leaching processing site [o be established. Cyanide poses serious envvonmental risks if not properly used and contained. It was unclear from the narrative exactly how the process will work and what safeguards will be utilized to prevent off site migration. I could not tell from the narrative if any of the cyanide processing facilities will be outside of the new building but if they are it would be necessary to not only fence the site but to place netting or similar material over it to prevent birds from using it. On page 4, paragraph 3 of the narrative, the applicant mentions Little Deadwood Gulch as the nearest stream. Although "this stream does not supply water to the La Plata River on a continuous basis" there are still concerns about overflow or accidental releases from the processing area into Little Deadwood Gulch when it is flowing. Little Deadwood Gulch does flow into the La Plata River. Fish populations are present below the mine site. Also, south of Red Mesa is a population of round-tail chubs - an endangered fish species. Although we are not knowledgeable about toxicity of cyanide over long distances in various flow regimes, we feel consultation with the US Fish and Wildlife Service should be required. In that same paragraph the applicant also mentions that "during the summer months, the water from Little Deadwood Gulch is all adsorbed by the ground strata and does not surface flow into the La Plata River." Has any information been provided which discusses the presence or absence of underground water movement into the La Plata River? Does such water, when adsorbed, remain in that location or flow elsewhere? Again, our concern is over contaminated water successfully entering the river system. DEPARTMENT OF NATURAL RESOURCES, James Lochhead, Ex¢cutive Director wI LOLIFE COMMISSION, Thomas M. Eve, Chairman ~ Mil liam R. Hegbarg, Member Eldon Cooper, Member • Mark Le Valley. Member ~ Rebecca L. Frank, M¢mbar Louts F. pwiFt, Member ~ Arnold Salazar, Member • J. Langston Boyd, Member