OHA's comments on closure of the Buckhorn Mine (October 2016)
The purpose of this memorandum is to provide input and recommendations related to water management, reclamation, and closure of the Buckhorn Mine. The memorandum contains Okanogan Highland Alliance’s (OHA) review of Crown Resources Corporation’s (Crown) Hydrologic Closure Plan (the “Plan”), which consists of a cover letter by Kinross Gold Corporation (Kinross), the Czarnowsky Inc Hydrologic Closure Plan, and the Golder Associates, Technical Memorandum, Buckhorn Hydrologic Closure Plan.
OHA submitted extensive comments to Ecology explaining the problems with the 2006 AMP and suggested changes that would make the plan approvable. The AMP Crown/Kinross submitted was very similar to the original document, instead of updating the plan based on the effectiveness of monitoring and the past five years of monitoring data as required.
The National Pollution Discharge Elimination System (NPDES) is a provision of the Clean Water Act that establishes the requirements for discharge of pollutants into the environment. Any “point source” discharge must have a permit. Kinross/Crown must dewater Buckhorn Mountain in order to mine; the water may be used in mining, is treated, and then discharged back into the environment. The Kinross NPDES permit, WA-005243-4, was issued November 2007, expired in October 2012, and was given two administrative extensions. A Draft NPDES Permit was released in September, 2013, with public comments due October 21, 2013. Selected excerpts from OHA's comments are provided below:
Capture Zone Comparison
(click to enlarge)
Pacific Groundwater Group has created a 3D visualization for OHA as part of and in support of the above NPDES comments. It begins with a visualization of the Buckhorn Mine underground workings with relevant faults and monitoring wells. It transitions to show: first the 2006 FSEIS capture zone, then the expansion of the capture zone proposed in the Draft NPDES, and then OHA’s proposed capture zone as seen from the south looking north. OHA’s proposed capture zone consists of the Draft NPDES depiction in the north, south and west and with the 2006 FSEIS depicted on the east side. The visualization then transitions to a view looking southwest from northeast of Buckhorn Mountain, and repeats display of the same sequence of capture zones.
About the 3D Visualization Project: Visualizing how groundwater in Buckhorn Mountain interacts with the mine, geologic faults, and dewatering wells is coming closer to reality with OHA’s 3D Visualization Project, which will increase everyone’s understanding of how water moves underground. At this point we have created a number of animations circling a transparent depiction of Buckhorn Mountain. The color-coded animations include various dewatering and monitoring wells and piezometers in cross sections of interest, with see-through portrayal of the company’s projected faults and underground mine workings. The groundwater levels at key seasons will be added to assist in an analysis of how the dewatering wells are influencing groundwater flow.
Over the years of the mine, OHA has made numerous recommendations to the company that they analyze the actual groundwater monitoring data instead of relying on predictive models, which have not been effective at predicting actual conditions. Early in 2013, OHA initiated a 3D mapping project, which developed into the 3D visualization. OHA is hopeful that this will give everyone another tool to analyze the monitoring data and hopefully see where the gaps are in understanding groundwater flow paths. The end goal is to stop contaminants from escaping the mine.
5. OHA Gold Bowl Water Quality Memo (Sent to Ecology): Comments on the Kinross/Crown Resources June 24, 2010 Letter to the Washington Department of Ecology regarding the Action Plan for Observed Seepage in Gold Bowl Creek. This OHA Memo was sent to Ecology in August 2010.
6. Analysis of Water Quality Impacts at the Buckhorn Mountain Mine and Recommendations for Improvement
This report responds to contaminant increases that triggered adaptive management in Gold Bowl Creek. The increases are more extensive than previously reported. The report provides an overview of: important events at the mine; violations and orders submitted by Ecology; information on water quality standards and exceedences that have occurred but were not noted by Kinross or Ecology; and adverse environmental effects that have occurred and their current status. The report proposes recommendations for actions that could be taken by Kinross to increase environmental protection.
After the first year of mine operation, not only were there were some significant water quality challenges on Buckhorn, but the required annual reporting was incomplete, lacking basic foundational data needed to analyze the mine’s impacts and the accuracy of model predictions. To quantify the inadequacy of the reporting, OHA completed an extensive review of the mine plans and developed a comprehensive matrix of annual reporting requirements. Using this matrix, OHA assessed the degree to which the company satisfied the requirements for Water Year 2008 and presented the results to the Department of Ecology and Kinross.
(Bolster Creek, Surface Water Monitoring SW-13)
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