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Commenting to the EPA: 11 questions

"A single, well-supported comment may carry more weight than a thousand form letters." - EPA's "Tips for Submitting Effective Comments"

The deadline for submitting comments on the EPA's Proposed Determination for restrictions in Bristol Bay is on September 19, 2014.

There are many ways to submit your input, including online at Regulations.gov (remember to add your name and contact information unless you want to submit anonymously).

Questions the EPA has posed to readers:

  1. Comments regarding whether the proposed determination should become the recommended determination and ultimately the final determination, and any corrective action that could be taken to reduce adverse impacts of discharges associated with mining the Pebble deposit.
  2. Additional information on the likely adverse impacts on fish and other ecological resources of the receiving waters that would be directly or indirectly affected by mining the Pebble deposit (including the South Fork Koktuli, North Fork Koktuli, and Upper Talarik Creek and downstream reaches of the Nushagak and Kvichak Rivers).
  3. Additional information on the water quality, flora, fauna, and hydrology of the waters identified in No. 2, above, and information on the fish species that would be affected by aquatic ecosystem changes if discharges from mining the Pebble deposit were to occur.
  4. Additional information about wildlife species that would be affected if discharges from mining the Pebble deposit were to occur.
  5. Additional information about recreational uses of the project area and how they would be affected if discharges from mining the Pebble deposit were to occur.
  6. Additional information about drinking water (including public water supplies and private sources of drinking water such as streams and/or wells) and how they would be affected if discharges from mining the Pebble deposit were to occur.
  7. Additional information on the potential for mitigation to be successful in reducing the impacts of mining the Pebble deposit.
  8. Comments regarding the approach used to define the potential disposal site, including how EPA Region 10 weighed the factors discussed in Section 2.2.3 and whether there are other factors or approaches EPA Region 10 should consider in defining the potential disposal site.
  9. Whether the discharge of dredged or fill material associated with mining the Pebble deposit should be completely prohibited, restricted as proposed, restricted in another manner, or not restricted at all at this time. In particular, EPA Region 10 is seeking comment on whether environmental effects associated with other mine stages or scenarios (e.g., environmental effects from mining approximately 2.0 billion tons of ore over 25 years) could provide a basis for alternative or additional restrictions.
  10. Comments on the definitions of "loss," "contiguous," and "dewatering," provided in Section 5 (p. 168).
  11. Comments on whether and how EPA Region 10’s proposed action under Section 404(c) should consider discharge of dredged or fill materials beyond those associated with the min pit, TSFs, and waste rock piles and include such discharges associated with the construction of other mine infrastructure (e.g., wastewater treatment plants, transportation corridors).

Read the Pebble Watch overview of the Proposed Determination

Read our guide to public comment for the Proposed Determination

Tailings pond breach at Canada mine puts safety at the forefront of Pebble discussion

The Pebble Partnership in the past has pointed to western Canada’s Fraser River watershed as an example of mining and healthy fisheries successfully co-existing. But earlier this month a tailings pond at the Mount Polley mine failed and discharged contaminants with an estimated 2.6 billion gallons of waste water and 1.3 billion cubic yards of tailings into the watershed in the Polley Lake/Hazeltine Creek area, a tributary of the Fraser River. (Photo still below from aerial footage taken by Cariboo Regional District.)

Polly-sm

While currently stabilized, the breach had not been entirely contained as of Aug. 25, and its cause is still unknown. Investigations into the cause will reportedly take several months.

According to a fact sheet from government officials, debris build-up from the spill has caused an unstable blockage at Polley Lake, which could result in another breach.

Communities in the area were initially advised not to use the water for drinking or bathing while water tests were conducted. Most tests came back within normal levels, so officials rescinded the ban for all but those in the impact zone directly affected by the breach. However, the sediment plume in Quesnel Lake has been moving, so residents who get their water from the lake have been advised to filter out the sediment.

The timing of the breach coincides with the annual salmon runs to the Fraser River. This year’s salmon run has been greatly anticipated, since they are the spawn from an abundant 2010 run. This is normally the busiest time of the year for catching and preparing fish for winter and local officials were concerned that salmon might be affected by the tailings pond breach. 

mapPolleyCanada's Interior Health Department issued a statement Aug. 12 deeming all fish outside the "Do Not Use" water advisory as safe for human consumption. According to government officials, "the tailings liquid initially released from the impoundment moved very quickly through the system and was diluted greatly by the water in [Quesnal] lake, the Quesnel River and ultimately the Fraser River. As such, fish exposure was limited and not long enough for uptake into tissues."

However, the Ministry of Environment will continue to conduct long-term sampling of several fish species. Additionally, First Nations Health Authority (FNHA) staff will conduct salmon tissue sampling in the confluence areas of the Quesnel and Fraser rivers. Those samples will be compared with salmon from last year to determine whether there are any negative effects from the breach.

One impact of the breach includes the loss of 42 mining jobs, many held by local residents. Other locals have been able to find work on cleanup crews.

Mount Polley, one of several large open-pit mines in the Fraser River watershed, is a copper-gold mine owned by Imperial Metals Corp. Its tailing ponds were designed by Knight Piésold, an engineering firm that, according to the Pebble Partnership, is part of a “world-class mine development team” assembled to “design and permit the Pebble Project.”

Knight Piésold, the initial Engineer of Record for the tailings dam, posted a statement Aug. 8 on its website saying the company has not been involved in the Mount Polley project since February of 2011. The company is backing away from responsibility for the tailings storage facility, maintaining that, "Significant engineering and design changes were made subsequent to our involvement, such that the tailings storage facility can no longer be considered a Knight Piésold Ltd. design.”

Government officials had repeatedly issued warnings to Imperial Metals regarding the height of water in the tailings pond, most recently in May.

Pebble Limited Partnership (PLP) CEO Tom Collier addressed the Mount Polley breach Aug. 12 during comments he made to the EPA regarding proposed restrictions on disposal of dredge/fill materials at the Pebble site in Bristol Bay. He cautioned against jumping to conclusions for either the cause of the Mount Polley breach or the impact it may have on salmon or the mining industry going forward, saying that PLP has called for scientific studies for both the root cause and for impacts to the Fraser river salmon fishery. 

The Government of British Columbia, with support of the Soda Creek Williams Lake Indian Bands, has ordered an independent engineering investigation and inquiry regarding the breach, as well as third-party reviews of dam safety inspections for all permitted tailings ponds in British Columbia. The independent panel appointed to lead the investigation includes Dirk Van Zyl, a professor at the University of British Columbia who also served as a peer reviewer for EPA’s recent Bristol Bay Watershed Assessment.

Additional investigations are being conducted by Imperial Metals Corp., the Ministry of Energy and Mines (MEM), and the Ministry of Environment (MoE).

As more details emerge from the Mount Polley tailings breach, it does offer additional context for discussing the proposed Pebble mine, now and during any future permitting phase:

  • How can safety standards be ensured long-term if tailings storage facility (TSF) engineers change? Who is ultimately responsible? Is there a public process involved when the Engineer of Record changes?
  • The Mount Polly breach was unexpected and authorities/mine owners do not know what caused it. What kind of safe guards will Pebble developers put into place to “expect the unexpected”?
  • Aftermath of the Mount Polley breach requires engineering to stop the flow of waste material, as well as emergency management, public information, and water quality testing. What emergency action plans would ensure a quick and efficient response at the Pebble site?

Before and after aerial view of Mount Polley mine (NASA Earth observatory)

Pebble Partnership tv ad – Fraser River

Knight Piesold part of Pebble’s mine development team

Fact Sheets: Mount Polley mine incident

 

More news reports:

Dam failure: Toxic mine wastes dumped into Fraser River watershed

Mount Polley mine tailings breach followed years of government warnings

Production boost preceded tailings breach at Mount Polley

Tribes deeply concerned for Frasier River salmon

First Nations health officials start salmon testing after B.C. mine spill

B.C. mining company pumping water from lake to prevent second tailings blowout

Mount Polley mine spill, an aerial view

 

Pebble-related public meetings to be held this week

Public meetings related to development of the proposed Pebble mine will be held this week in Anchorage and in communities in Bristol Bay:

Public Forum on Bristol Bay Forever Initiative

On Wednesday, Aug. 13, from 7 p.m. to 9 p.m., in the Wilda Marston Theatre of the Z.J. Loussac Public Library in Anchorage, voters will hear experts discuss the pro and con positions regarding the "Bristol Bay Forever" public initiative. The Anchorage Public Libraries and the League of Women Voters of Anchorage are cosponsoring the event. More information.

EPA public meetings on proposed Bristol Bay restrictions

Members of the public can comment in person on EPA's Proposed Determination - a document that details its recommended restrictions on large-scale mining at the Pebble deposit in Bristol Bay.

First up is the Anchorage meeting, scheduled for 2 p.m. Tuesday, Aug. 12, at the Egan Civic and Convention Center in downtown Anchorage. This meeting is expected to run for several hours.

EPA has provided the following questions to consider for those wishing to provide comments:

  • Do you think the Proposed Determination should be recommended and finalized? Why or why not?
  • Do you have additional information on potential impacts on the North Fork Koktuli River, South Fork Koktuli River and Upper Talarik Creek watersheds, and downstream reaches of the Nushagak and Kvichak rivers resulting from mining of the Pebble deposit? Specifically information about: 

    • Fish and other ecological resources
    • Water quality, flora, fauna and hydrology
    • Wildlife species
    • Recreation
    • Drinking water
  • Can you suggest potential mitigation actions that could compensate for the damage caused by mining the Pebble deposit?
  • Should the discharge of dredged or fill material be completely prohibited, restricted as proposed, restricted in another manner or not restricted at all at this time?

Additional meetings will be held in these Bristol Bay communities:

New Stuyahok: Wednesday, Aug. 13, at 5 p.m.
Cetuyaraq Community Center

Nondalton: Wednesday, Aug. 13, at 5 p.m.
Nondalton Community Center

Kokhanok: Thursday, Aug. 14, 5 p.m.
Community Center

Dillingham: Thursday, Aug. 14, at 5:30 p.m.
Middle School Gymnasium

Iliamna: Friday, Aug. 15, at Noon
Community Center

Igiugig: Friday, Aug. 15, at Noon
Tribal Hall

 

New from Pebble Watch: two guides related to EPA's Proposed Determination

guideproposeddeter
guidepublicinpu
 
 
 
 
 
 
 
 
 
 
 
 
 
 

The U.S. Environmental Protection Agency is currently receiving public comments on its Proposed Determination for restrictions at the Pebble deposit site in Bristol Bay. Public meetings are coming up August 12-15.

Find out what you need to know about the Proposed Determination and public input opportunities in these two guides from Pebble Watch.


Overview of Proposed Determination - Highlights, chapter guide, terminology and a timeline of the 404(c) process.


Guide to Public Comment on EPA's Proposed Determination
 - Meeting schedule, tips for preparing comments, and more.

 

 

 

 

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About Pebble Watch

Pebble Watch is an impartial, educational and fact-based initiative of the BBNC Land Department to disseminate information regarding the proposed Pebble Mine project to BBNC shareholders and interested parties. 

Produced by
the BBNC Land Department

Questions? Call
(800)426-3602