Buckhorn Mt Needs YOUR Comments by January 2, 2007

December 11, 2006

The Washington Department of Ecology is accepting comments on a draft permit that would allow Crown Resources/Kinross to discharge treated mine water and storm water from the Buckhorn Mine project to ground water and surface water.

Written comments will be accepted through Jan. 2, 2007.
Comments should be sent to
Cindy Huwe
Department of Ecology, Central Regional Office
15 W. Yakima Ave., Suite 200
Yakima, Wash., 98902.

Comments may be emailed to chuw461@ecy.wa.gov

The DRAFT permit and fact sheet can be found at:
http://www.ecy.wa.gov/news/2006news/2006-237.html

The Buckhorn NPDES supporting documents can be found at the ftp site: ftp://www.ecy.wa.gov/BuckhornNPDES/

Comment ideas:

NPDES Permit is a hodgepodge of interrelated document with conflicting projections of the impacts of mining and how the discharges would be controlled. The NPDES permit should outline the methods, procedures, and requirements of water monitoring samples and analysis instead of simply referencing other documents.

The water budget for the proposed mine lacks realistic estimates of the likely peak flows that could be expected especially considering the frequency of extreme storm events. It is likely that the permit as written would result in unregulated discharges to ground and surface water causing ecological and environmental harm.

The Hydrologic Monitoring Plan (HMP) would not produce the information needed; to eliminate regulated discharges; to assess how well the actual impacts correlate to the predicted impacts; or to indicate whether groundwater is discharging into surface water. The proposed plan for self monitoring is insufficient to protect the public interest. Ecology should insist that the mining company pay for third party independent monitoring with regular oversight inspections by Ecology throughout the process. OHA requests to be informed, in a timely fashion, of actual monitoring schedules so that citizen may monitor hydrologic monitoring as per Metals Mining Act (78.56.100).

Treated Mine Water and Stockpile Storm Water Monitoring: There should be water quantity limitations in the NPDES that regulate the amount of water that can be discharged to the infiltration gallery as stated in the Adaptive Management Plan "the maximum infiltration rate will be 20 gpm." If the proponent thinks that the facility can handle more water, it could request a permit modification but the permit should not allow the proponent to experiment with the health and well being of public land and resources.

On site chemical analysis of the treatment effluent should continue on a regular basis throughout the operation of the facility to ensure water quality parameters.

Kinross should be required to monitor stormwater regularly during storm events or whenever stormwater runoff is present.

It is likely that groundwater quality at the end of mining and during the 40 years of re-equilibrium and after would not meet water quality standards. Groundwater monitoring wells and piezometers are in the wrong location to provide any meaningful results of ground water quantity or at the infiltration gallery. Piezometers should be placed as close as possible to the project boundary and should be placed incrementally at the extent of the one foot drawdown.

Mine Site Surface Water Monitoring Schedule: Given the close relationship between ground and surface water on Buckhorn Mountain, one surface water monitoring well on the west side of is insufficient to assess if groundwater is discharging to surface water. All Creeks emanating from Buckhorn Mountain should be monitored and additional seeps and springs on the west side of the divide.

Surface water quality monitoring should occur more often than monthly (daily, weekly or bi-weekly) especially during spring runoff and periods of high precipitation. Water quality monitoring should continue on the west side of Buckhorn until the water table reaches equilibrium and the water runs clean.

The Frog Pond should be monitored.

Marias Creek: More water quality monitoring points are needed along Marias Creek in order to get representative sampling. The HMP, Marias Creek Sampling for NPDES (Table 3-3) states; "No" for turbidity sampling for MC-2, yet Table 3-1b list it as a criteria. Turbidity should absolutely be monitored at that location and more locations along Marias Creek should be added. Monitoring should occur more than monthly (bi-weekly at least) especially during spring runoff (April-June). Benthic macro-invertebrates should be monitored as an indicator of the continued health of Marias Creek.

Table 3-3 footnotes reads: Period of monitoring tied to EPPS bond, NPDES permit requirements or actions under Adaptive Management. Assumption in this table is that monitoring terminates at the end of Year 10. Closure is considered to be to year 15 and post-closure another 25 years for a total of 40 years. Water quality problems can take years to develop. Water quality monitoring should continue until water level reaches equilibrium and not terminate once the Gold Bowl fill as per the HMP. The NPDES and all the supporting documents need to be clear that monitoring will continue until the water table reaches equilibrium and water quality standards are being met. Adequate bonding should be retained to maintain a system that would clean up the inevitable water quality problems that would arise if this flawed mine plan were allowed to proceed.

Stormwater Discharge from Portals: Discharge of stormwater should meet water quality standards or be treated to meet standards before it infiltrated back into the ground and groundwater system. Retention ponds should be lined and discharges routed to the treatment facility. Overflow from the retention pond should be routed to the treatment facility.

David Kliegman
Okanogan Highlands Alliance
PO Box 163
Tonasket, WA 98855
509-485-3361
kliegoha@televar.com

"Pure water is more precious than gold!"