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5. The application states that only 10 gpm of new water supply is needed to meet the 40 <br />gpm demand for mine operations, as over 30 gpm is recovered from tailings filtration. <br />There is no discussion on how contaminants that will concentrate in the return flow will <br />be managed, or how the waste stream (containing all the contaminants) from the <br />necessary treatment will be managed. Water will likely have metals contamination, high <br />nitrates from mine explosives, high total dissolved solids, and high suspended solids, all <br />in excess of stream standards. The application says that no treatment facilities will be <br />needed or waste streams will be created, how is this possible? <br />6. Only one acre -foot of storage (Augmentation Pond) and two 10,000 gallon raw water <br />tanks are discussed with 9.51 gpm of average water use over 250 days, so it is unknown <br />where the contaminated tailings return flows will be stored prior to treatment. Water <br />from underground workings is planned for filling the augmentation pond, and this water <br />will be released via pipeline as required to the La Plata River to meet augmentation <br />requirements. How will this water quality be controlled if no treatment capacity is <br />provided? The water balance seems simplistic and incomplete. <br />7. The application has no discussion of methods of containment or use of mill process <br />water. <br />8. The application has no substantive discussion of how process chemicals and process <br />slurries will be managed and contained to prevent environmental release. <br />9. The application states that all site power to be provided by on -site generators, there is <br />no discussion of fuel delivery, storage, or containment of generator operations to <br />prevent release of diesel fuel. <br />10. There is no discussion of how water will be managed during mining operations inside <br />the mine to ensure that water is not migrating thru rock fissures and is not tributary to <br />the La Plata River. <br />11.100 tons of ore will be extracted per day at maximum. How will fines and dust be <br />controlled so they don't end up in road runoff and ultimately into the immediately <br />adjacent La Plata River? <br />12. There is no mention of the amount for reclamation bonds or bonding needed in the <br />event the mine operator abandons the site in an un- reclaimed and unstable state. If the <br />mine operator abandons the site and abandoned mine operations releases <br />contaminants to the La Plata River, this threatens the water supply for the LDWA. <br />13.2 percent of rock excavated will be hauled off site as ore for processing. Where and <br />how will the 98 percent of excavated rock after milling be stored above grade so <br />contaminated runoff from the piles does not reach the La Plata River? <br />14. The application states that disturbed areas will be reclaimed as soon as possible, but no <br />water is available in water balance for irrigation or reclamation. <br />15. Lack of water in existing excavated mine tunnels (aka disposal facility) may indicate a <br />direct drainage path to groundwater. Hydraulic testing of excavated mine areas is <br />needed prior to placement of excavated rock materials to ensure that drainage of <br />dissolved metals and chemical contaminated waters do not have a direct conduit to <br />groundwater that is tributary to the La Plata River. Text says extent of rock fracturing is <br />unknown, and groundwater levels are unknown. When the rock fracture analysis is <br />completed prior to placement of materials underground, who will receive copies of that <br />report for review and comment? <br />