WMAN Conference 2005

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WMAN Conference 2005
COMPARISON OF PREDICTED AND ACTUAL WATER
QUALITY In Environmental Impact Statements for
major hardrock mines in the U.S. James
Kuipers, Kuipers and Associates, Butte, MT Ann
Maest, Buka Environmental, Boulder, CO Kimberley
MacHardy, Kuipers and Associates, Butte, MT Greg
Lawson, Buka Environmental, Boulder, CO
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Project Background

• Performed by Kuipers and Associates and Buka
  Environmental
• Study of this type/magnitude never performed
  before
• Project funded by Earthworks/MPC with grant from
  Wilburforce Foundation
• 24-month data collection and analysis effort
• Preliminary results presented at SME with final
  results available October 2005
• www.kuipersassoc.com

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Project Tasks

• Define and identify major hardrock mines in the
  U.S.
• Identify NEPA eligibility of major hardrock mines
• Identify and gather NEPA documentation for major
  mines
• Identify and compile water quality predictions
  information from NEPA documents
• Identify other water quality predictions
  information
• Conduct case studies analysis of NEPA process,
  predictions results, and actual water quality
  history
• Analyze NEPA predictions and water quality
  information on a comparative basis and in
  subgroups

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Project Database

• Location
• Ownership
• Commodity
• Operation Type
• Operation Status
• Disturbance and Financial Assurance
• NEPA Documentation
• Record of NEPA document requests and retention
• NPDES Information
• Data provided in Excel database form and
  statistically evaluated in appendices to report

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Major Mines Identification

• Major Mines Criteria
• disturbance area of over 100 acres, and
• financial assurance amount of over 250,000, or
• having a production history (1975 to current) of
  greater than 100,000 ozs Au, 100,000,000 s
  copper, or equivalent in other metal
• In operation 1975 to present
• Sources
• Kuipers, Randol, USGS, Infomine
• 182 major mines identified in U.S.

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Mine Information Statistical Evaluation
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NEPA Mines IdentificationNEPA Requirements

• Location on Forest Service lands
• Location on Bureau of Land Management lands
• Requirement for NPDES permit from EPA
• Requirement for COE 404 wetlands permit
• Location on BIA-administered Indian Lands
• State mandated NEPA equivalent process

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NEPA Mines

• 136 current era NEPA eligible major hardrock
  mines
• ( of total)
• BLM lands 93 (68)
• Forest Service lands 35 (26)
• BLM and Forest Service lands 9 (7)
• COE 404 Wetlands Permits 5 (4)
• EPA issued NPDES permits 3 (2)
• BIA administered Indian Lands 2 (2)
• States requiring NEPA 33 (24)
• CA, MT, WA, WI
• NEPA for both federal and state 22 (16)

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NEPA Documents Collection

• Goal to obtain and review statistically
  significant total of documents for the 136
  current era NEPA-eligible hardrock mines
  identified
• EISs reviewed 64 mines
• EAs reviewed 6 mines
• Total 70 mines

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NEPA/EIS Water Quality Predictions Information

• Classifications Established/ Reviews for
• Mineralization/Ore Associations
• Climate
• Hydrology
• Geochemical Characterization
• Predictive Models Used
• Acid Drainage and Contaminant Leaching Potential
• Groundwater, Surface Water and Pit Water Impact
  Potential
• Mitigations
• Predicted Water Quality Impacts
• Discharge Information

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Climate(Modified Koppen System)
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Surface Water Hydrology
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Groundwater Hydrology
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Acid Drainage Potential
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Contaminant Leaching Potential
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Case Study Priorities

• Long histories of NEPA documentation
• Information on pre-mining water quality
• Representative of a variety of locations
  commodities different proximities to water
  resources different characterization and
  modeling efforts different potentials to
  generate acid and leach contaminants

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Case Study Mines
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Other Mines with Some Operational WQ Information

• American Girl, CA
• Castle Mountain, CA
• Mesquite, CA
• Cortez Pipeline, NV
• Gold Quarry, NV
• 29 mines total with operational WQ info

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Findings

• This study identifies the primary modes by which
  the predictions have failed in terms of actual
  water quality impacts.
• inadequate geochemical characterization
• lack of effective mitigation
• mitigation does not perform
• other causes

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Findings

• Failure Mode
• Inadequate Geochemical Characterization
• Failure to recognize acid drainage or other
  contaminant potential
• Root Causes
• Failure to collect representative samples
• Failure to conduct proper tests
• Interpretation failure
• Modeling failure

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Findings

• Failure Mode
• Lack of Effective Mitigation
• unlined tailings impoundment, springs on site not
  identified, contaminant not identified
• most commonly caused by inadequate geochemical or
  hydrological information
• assumption of low potential for impacts results
  in application of inferior mitigation approach
  (CA)

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Findings

• Failure Mode
• Mitigation Does Not Perform
• Liner leak, tailings impoundment rupture, pond or
  pipeline spill, storm event
• May be due to one or more variables
• Performance Standard
• Engineering Design
• Installation
• Operation

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Findings

• Failure Mode
• Other Failure Modes
• inadequate baseline water quality information
• Recommend minimum 2 years data
• hydrological characterization failures
• accurate identification or existence of shallow
  groundwater (springs or perched water)
• failure to predict greater quantities of water as
  mining expands
• failure to recognize groundwater/surface water
  flow paths.

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Increased Risk Factors forWater Quality Impacts

• Primary Risk Factors Identified
• Geology and mineralization
• Proximity to water resources and climate
• Acid generation potential
• Contaminant leaching potential.
• Significant discrepancies exist between
  identified mineralization and acid drainage
  potential

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Increased Risk Factors for Water Quality Impacts

• Delayed impacts to groundwater at mine sites are
  being ignored in most NEPA evaluations.
• All mines reviewed in detail that had shallow
  depth to groundwater and moderate/high potential
  for groundwater quality impacts had groundwater
  quality impacts
• All but one mine reviewed in detail that were
  close to surface water and had moderate/high AGP
  had some impact to surface water

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Uses by Activists of Both Studies

• EIS reviews or challenges of new and expanding
  mines
• Characterization methods
• Modeling methods
• Mitigation methods
• Water quality failures/successes of similar mines
• Red light/green light inherent factors