It is inevitable that large-scale, cyanide-leach mining will have issues and problems. The Buckhorn Mine is no exception. How a mining company and regulators address the need for change can either limit the problem or cause long-term problems that are difficult to remediate.
Over the years, OHA has raised concerns regarding mining on Buckhorn Mountain with the various incarnations of the open-pit as well as the underground proposals. Once construction and mining commenced, many of OHA’s concerns were realized and became on-the-ground issues that had or still have to be addressed. As the mining project commenced, additional problems and issues have emerged.
OHA's assessment is that Kinross has been in violation of its NPDES permit since shortly after the mine began operating in 2008. After more than five years of gold production at the Buckhorn Mine, the violations of the NPDES and the CWA are well documented in monthly water quality monitoring data. The mine has:
1) Failed to establish and maintain the capture zone
2) Discharged pollutants in excess of water quality limitations
3) Discharged pollutants without permit authority
4) Failed to comply with the Adaptive Management Plan (AMP) for Water Quality
The mine permit requires Crown Resources/Kinross Gold to implement an Adaptive Management Plan for Water Quality to ensure that actions will be taken if problems arise during mine operations. The plans include an early warning system to identify problems. If monitoring shows that mine contaminants exceed background values outside the capture zone, the mining company is required to: inform the Washington State Department of Ecology (Ecology), identify how far contaminants have traveled, and make a plan to stop their spread. The mining company has failed to honor this permit requirement. Instead, since early 2010, even though the company’s own data show values that are consistently above background values, their required monthly reports to Ecology state that no exceedences have occurred. This reporting fails to acknowledge their own data in locations where values have consistently exceeded background values.
Various strategies have been employed to address the issues of pollution in surface and groundwater, to little or no effect. Since April 2013, groundwater monitoring well MW-14 is not only elevated but has exceeded water quality standards for sulfate. While this is commonly known, since the data are contained in the monthly Discharge Monitoring Reports, Crown has failed to officially notify Ecology of the exceedences, and Ecology has not informed the company of its failure to report. Thus, there has been no official recognition that there is something is seriously wrong.
As the Buckhorn Mine approaches the end of its predicted production, OHA seeks increased action to reduce contaminant flow from the mine. The long-term protection of local ground and surface water must ensure that the water emanating from Buckhorn Mountain is not left contaminated when Kinross is done.
More Background on Water Quality
Ongoing Water Quality Issues
The Washington Department of Ecology issued a Water Quality Certification to Crown Resources/Kinross mine under section 401 of the federal Clean Water Act. In so doing it declares that it has reasonable assurance that water quality resulting from the mine will meet standards.
The reporting and analysis of monitoring data is key to preventing problems from developing at the Buckhorn Mine. It is important that problems are identified early so solutions can be developed before larger adverse effects occur. After reviewing the memos and reports, in cooperation with Kinross, OHA found the 2008 annual reporting incomplete and lacking basic foundational data needed to analyze the mine’s impacts or the accuracy of model predictions. Each subsequent year has had issues.
This mine has extensive monitoring requirements to ensure protection of the environment, but without fundamental changes to compel compliance and coordinate the discussion of results and analysis, the effectiveness has been limited.