Sulfide Mining

Minnesota Trout Waters at Risk From Sulfide Mining

Minnesota Trout Waters at Risk From Sulfide Mining

Polymet – New Type of Mining Could Harm Coldwater Fisheries Across NE MN
and in Lake Superior
The long awaited environmental review document for what could become Minnesota’s first non-ferrous sulfide mine, the Polymet mine near Hoyt Lakes, MN, was released recently for public review and comment. This Supplemental Draft Environmental Impact Statement (SDEIS) is a 2,200 page document exploring most of the potential impacts from the proposed Polymet mine. Sulfide mining is a new type of mining with waste rock and wastewater, which has the potential to harm coldwater fisheries for many, many generations. This is the same type of mining which has left thousands of miles of Western waters polluted and threatens Bristol Bay. All trout and steelhead anglers need to spend some time examining this issue and adding their voice to the public discussion of whether and with what constraints this new type of mining will be allowed in Minnesota. This webpage will be updated as we work through the SDEIS and future blog postings will flag newly added material.  You can also read the article in the MNTU Newsletter Here.

Ready to Comment Now?  Comments on the Polymet Mine Are Due By Thursday March 13

Here Are Links to On-line Tools and Resources:

Minnesota TU supports science-based decision making and we have therefore supported the public education effort of several partners.  The Mining Truth website does a good job of presenting objective factual information to spur thoughtful public discussion.  See http://www.miningtruth.org/  The Watery Legacy website also does a very good job.  See http://www.waterlegacy.org/  Both sites have links enabling you edit or add to draft comment letters, then send them in directly using the built in on-line tool.  You can send several separate sets of comments to cover separate issues of concern to you.

In addition, the Water Legacy has a good video overview on how to prepare comments on the SDEIS, found at http://waterlegacy.org/node/159

The SDEIS can be found on the DNR website at www.mndnr.gov/polymet  The website also includes an executive summary, and a series of fact sheets and documents designed to help the public understand the proposed project.

A good source for objective reporting on new developments is the MPR website: http://minnesota.publicradio.org/

POLYMET DETAILS

Location of proposed mines
The Polymet site is located in northeast MN, and straddles both the Lake Superior and Rainy River basins. Click HERE to see a map. Similar mines are proposed across northeast Minnesota.

Coldwater fisheries in harm’s way – North Shore rivers, Lake Superior, and inland lake trout lakes
The Polymet site straddles the divide between the Lake Superior and Rainy River basins. It is but the first of many mines being proposed across Northeast Minnesota. Runoff from several proposed sites will flow into the interconnected lakes in and near the Boundary Waters Canoe Area Wilderness which are home to our rich heritage of native inland lake trout. Exploratory drilling is occurring or planned for the headwaters of several storied North Shore rivers. Some of our best native brook trout fisheries could be impacted, as well as key wild steelhead populations. Ultimately, the health of Lake Superior’s coldwater fisheries is at stake as well. In short, the vast majority of trout waters in northern Minnesota could be impacted by decisions made in the review and permitting of this first sulfide mine.

Major concerns
Our primary concern is preserving clean water. While Minnesota Trout Unlimited appreciates mining’s important place in Minnesota’s economy and culture, we believe all mining should be done through environmentally safe mining practices that protect Minnesota taxpayers. Nonferrous metal mining projects in sulfide ore bodies in northern Minnesota must have adequate protections to prevent pollution and adequate financial safeguards to ensure any future pollution will be fully remediated. We are closely analyzing the SDEIS to determine whether water pollution can be prevented. In the interim, our major concerns are twofold:

1. Clean water and clean fish
Minnesota TU’s concerns center on the substantial long term risk which nonferrous sulfide mining will pose to water quality and fish consumption. It appears likely that acid mine drainage will occur and will require monitoring and water treatment for at least several centuries. There is a high potential for mercury methylation from wastewater discharges and seepage into wetlands, lakes and rivers. This form of mercury (a persistent toxin) is easily taken up by fish, especially long lived lake trout, making them hazardous to eat.

A new type of mining and wastewater
The proposed mines are not Minnesota’s traditional iron ore and taconite mines, but a new type of toxic-producing mines, which would extract minerals such as copper and nickel from sulfide ores. The character of the rock in which iron is found is very different from sulfide bearing rock where nonferrous metals are found. When rain and snowmelt run off the waste from iron mining, they create rust, whereas when rain and snowmelt run off waste from nonferrous sulfide mining, they create sulfuric acid. This acid in turn leaches out toxic heavy metals and pollutes nearby lakes and streams. This type of hard rock mining and its toxic aftermath are what plague many Western rivers and what TU is fighting to keep out of the Bristol Bay watershed.

Persistent mercury contamination
Pollution risks also include elevated levels of harmful sulfates, which ultimately can lead to mercury contamination of fish. The wastewater generated by the Polymet site would drain to Lake Superior, where mercury levels are already high enough to trigger fish consumption advisories. Other sulfide mines being proposed would drain into our native inland lake trout lakes, including their last strongholds in the BWCAW. Other sites being explored for sulfide mines are in the headwaters of several storied North Shore rivers.

2. Adequacy of financial assurances to address very large, long term threat
Even a cursory scan of the Polymet SDEIS raises serious concerns for our water resources and coldwater fisheries. Roughly 99% of the huge volumes of rock removed would be “waste” rock capable of leaching sulfuric acid and other heavy metals. Assuming the engineered containment measures would in fact continue working for hundreds of years, the collected waste water would need to be continuously treated for many hundreds of years at least. Any failure in the containment measures would be very costly to clean up. The costs for wastewater treatment for a minimum of several hundred years will be very large. Unless truly adequate “financial assurances” are required up front (essentially a multi-million dollar damage deposit) taxpayers could be left bearing this ongoing cost of the mine long after its 20 year operating life. If funds for monitoring or cleanup are not found in the future, our waters and fisheries will be harmed. The article on the front page of business section of the December 8, 2013 issue of the Star Tribune is well worth reading.

Trout Unlimited remains a leader in efforts to clean up acid mine pollution around the United States. The history of bankrupt companies leaving taxpayers to clean up the mess is well known to TU. Consequently, we support efforts to create greater incentives both to prevent water pollution and to ensure it is cleaned up in the future. In 2009 Minnesota Trout Unlimited supported efforts in the Minnesota Legislature to strengthen financial assurances. While the bill failed, we expect the release of the Polymet SDEIS will spur renewed efforts to protect Minnesota taxpayers.

Link to the DNR webpage containing the SDEIS
You can review and comment on the SDEIS through the DNR website at www.mndnr.gov/polymet
The website also includes an executive summary, and a series of fact sheets and documents designed to help the public understand the proposed project.

Text of DNR Press release on Dec 6, 2013:
State and federal agencies release NorthMet Supplemental Draft Environmental Impact Statement, opening public comment period
(Released December 6, 2013)
A comprehensive environmental analysis of Minnesota’s first proposed copper-nickel mine has been released for public review and input.

This begins a critical phase of the environmental review process for PolyMet Mining Inc.’s revised NorthMet copper-nickel mining project and proposed land exchange. State and federal agencies are seeking public review and input on a document called the Supplemental Draft Environmental Impact Statement (SDEIS).

The proposed mining project has been substantially revised since a 2009 Draft EIS, and the SDEIS
includes information on those changes, the land exchange, and additional and revised analyses of potential project impacts. Publication of the SDEIS provides the first opportunity for the public to review and comment on the revised project, located in northeastern Minnesota near Hoyt Lakes and Babbitt.

“I am inviting Minnesotans to participate in the environmental review process by reviewing the document and providing thoughtful, informed input on the environmental analysis during the public comment period,” said Department of Natural Resources Commissioner Tom Landwehr. “The DNR and other agencies have used their most objective and best scientific expertise to review this project. Now we need all interested parties to give us their comments.”

The SDEIS is now available on the DNR’s website (www.mndnr.gov/polymet), and review copies are available at select libraries and public offices around the state. Public meetings will be held in January in Duluth, Aurora and St. Paul.

The 2,200-page document is an intensive, scientific examination of environmental, social and economic aspects of the project. This includes in-depth analyses of potential impacts on wetlands, air and water quality, and wildlife. The document describes proposals to reduce impacts through project modifications, mitigation and alternative actions.

The SDEIS also examines how the company would address mine-site reclamation and provides information on the financial assurances needed during and after mine operation. The document thoroughly analyzes the proposed land exchange between the company and the U.S. Forest Service that would be needed for PolyMet to implement its mining proposal.

Prepared by the DNR, the U.S. Army Corps of Engineers (USACE) and the U.S. Forest Service (USFS), known collectively as the co-lead agencies, the document details more than 3 years of scientific study and analysis of the project. It is an updated and revised analysis of the 2009 Draft EIS.The SDEIS will be published in the Minnesota Environmental Quality Board Monitor on Monday, Dec. 9 and in the Federal Register on Friday, Dec. 13. A 90-day public comment period will begin on Dec. 14 and end on March 13.

The public can review and comment on the SDEIS through the DNR website at
www.mndnr.gov/polymet. The website also includes an executive summary, and a series of fact sheets and documents designed to help the public understand the proposed project.

The proposed NorthMet mine project would be located in the St. Louis River watershed on the eastern edge of the Mesabi Iron Range, about 6 miles south of Babbitt and about 1 mile south of the existing iron-ore Northshore Mine. Processing of the ore would take place at a former industrial site, the LTV steel plant in Hoyt Lakes. Neither the proposed mine nor the processing facility is in the watershed containing the Boundary Waters Canoe Area Wilderness.

The total project area would include the open pit mine, a processing plant, tailings basin and an existing 7-mile-long railroad corridor for the transportation of ore between the mine and the processing plant.

PolyMet’s proposed project remains in the “environmental review” phase. This is the extensive process used to identify and analyze the potential environmental, social and economic impacts of the proposed project. Public input on the SDEIS is an important component of this phase.

Environmental review is not the approval phase of the project, which occurs during the permitting process.

At the state level, if the DNR determines the EIS is adequate, the next phase – the permitting process – would evaluate if the project can comply with all applicable environmental regulations and would set out the required measures that would need to be taken to avoid, minimize or mitigate impacts and provide the required financial assurance. The permitting phase also involves opportunities for public review of draft permits.

Similar to the state, the USFS issues a record of decision that completes its environmental review, and is followed by permitting and implementation. Unlike the other two co-leads, the USACE issues a record of decision that both completes its environmental review and renders its permit decision. For PolyMet’s proposal, this involves wetlands permitting for the USACE, while the USFS is focused on the proposed land exchange transaction process.

Comments on Polymet Mine Are Due By Thursday March 13

On-line Tools Make Commenting Fast and Easy.

Public comments concerning the Polymet mining project are due Thursday March 13 by 4:30 p.m.  There are numerous on-line tools that make it extremely easy to quickly send in comments.  You can select one or more environmental issue, obtain suggested comments on a ready-to-submit form, and customize or add content.  Links are found at the bottom of this page.  For background on the sulfide mining issue visit our webpage http://mntu.org/sulfide-mining/

Purpose of comments:   

The current environmental review process is intended to provide decision-makers and the public with objective facts about the significant environmental, social, and economic effects of a proposed project, look at ways to avoid or minimize the significant effects, and examine alternatives.  This is your opportunity to ask critical questions and challenge the three lead agencies to ensure the best projections, not the most optimistic ones, are public debated.

The agencies prefer comments which are informed, specific and substantive.  You can comment on whether the information presented is accurate, adequately examines all potential impacts, and thoroughly explores how these impacts can be avoided.  Your comments should flag problems with flawed assumptions, flawed methodology, omissions (missed treatment of some impacts), failures to consider all reasonable alternatives, and failures to look at additional mitigation measures.

Web tools help you generate focused comments on problem areas:

The SDEIS document is large and complex.  Thankfully, several on-line tools are available which give you the ability to quickly send comments on areas of concern.  You can select areas you are concerned about, view sample comments and quickly edit them to reflect your perspective.  Once satisfied with the content, simply enter your address and you can send your comments directly to the agencies.  Two of the better sites (developed after extensive review of the data by experts) are listed at the bottom of this page.  There you can explore the many well researched fact sheets and resources.  While we need not duplicate these tools, we suggest you consider commenting on the several of the major areas of concern listed below.

Major areas of concern:

1.  The groundwater flow model is flawed and must be re-run using corrected data.  The model, used to assess the impacts on water resources and how to minimize them, relies upon incorrect assumptions about the amount of groundwater at the site.  Numerous media reports explore this issue, including on the MPR website below.  The model uses a base flow estimate which significantly underestimates flow.  As a result, the model likely underestimates the amount of sulfates and heavy metals carried to the Partridge River and Lake Superior.

The model also assumes that the bedrock underlying the mine tailings basin is not fractured and will not permit seepage of contaminated water into the groundwater and surface water systems.  This is not the case.  And since this tailings dump is not lined, seepage through bedrock fractures will not be collected and treated.  The model’s predicted impacts are thus flawed.  The SDEIS will remain inadequate until these unfounded assumption are corrected and the model re-run.

2.  The SDEIS lacks a detailed monitoring plan and detailed analysis of what adaptive actions could be undertaken if various assumptions prove incorrect.  The DNR is willing to delay consideration of monitoring details until the permitting process.  However, these should be considered in the SDEIS since the scope and effectiveness of monitoring efforts can determine the amount of contaminated water reaching streams undetected.  The SDEIS should examine the environmental consequences of several scenarios now, with varied locations and numbers of monitoring wells evaluated.

3.  The SDEIS fails to address additional alternatives designed to capture all seepage from the mine and tailings sites.  The project plan fails to ensure that all seepage is captured and treated.  As a result, the SDEIS does not examine the impacts of this contaminated water on ground and surface waters.  The following alternatives should be examined:

a. lining the tailings basin (rather than relying upon assumptions of unfractured bedrock);

b. lining the category 1waste rock pile at the mine site;

c. building a water containment system  around the category 1 stockpile and mine site, like the one proposed for tailings basin site (essentially a “gutter system” from the bedrock up);

d. placing all waste rock back into the completed mine pit.

4.  The SDEIS does not adequately examine the alternative of operating an underground mine, rather than an open pit mine.

5.  The SDEIS does not adequately consider the impact of PolyMet’s plans to “pirate” groundwater and surface water in the area for a decade (years 11 to 20) and send the water to the East Pit to cover waste rock.

6.  The SDEIS is deficient because it fails to include detailed information on financial assurances.  The lack of truly adequate resources can lead to decisions to forego appropriate pollution prevention or remediation efforts.  The SDEIS’s projections of future pollution impacts rest upon the assumption that adequate resources will be available for the most effective (not the lowest cost) measures.  It assumes that diligent, well-funded personnel tirelessly looking for seepage and modeling errors will have the resources to take whatever actions are needed to protect our resources (no matter how expensive).  The SDEIS should provide information for the public to assess whether the rosy scenarios used throughout are realistic and what additional impacts are likely under less well funded scenarios.

7.  A more thorough examination is needed of the impacts of the mine on mercury contamination levels in fish.  This must include an examination of long term impacts on long lived species such as lake trout in Lake Superior and other lakes and streams located “downwind” of the power plants supplying energy to the mine operations.

8.  A primary justification of the land exchange is to re-unite surface and subsurface (mining) property rights.  However, many of the lands which the USFS will receive would also have their mining rights severed.  The potential impact of accepting as full “replacement” lands which will be subject to the threat of future mining needs to be thoroughly assessed.

9.  The prospect of needing perpetual water quality treatment.

10.  The lack of adequate time for members of the public to closely review more than 2,000 pages of often technical information and provide detailed comments.  You should specifically request that the comment period by extended for at least an additional 30 days.

Express your heartfelt, informed opinion on permit issuance

The agencies prefer that you to keep comments narrowly focused on the procedural question of whether the SDEIS document adequately examines all potential impacts.  However, this is likely the best opportunity which you will have to express your opinion about the permitting decisions.  If you have reached a decision about whether or under what conditions this project should be permitted, it makes good sense to include this input now at the end of your comments.  You should feel free to tell the MNDNR whether or not it should grant this project a permit to mine, and tell the USACE whether or not it should issue a 404 permit allowing the destruction of hundreds of acres of wetlands, and impacts to thousands more.

Links to on-line tools and resources:

Minnesota TU supports science-based decision making and we have therefore supported the public education effort of several partners.  The Mining Truth website does a good job of presenting objective factual information to spur thoughtful public discussion.  See http://www.miningtruth.org/  The Watery Legacy website also does a very good job.  See http://www.waterlegacy.org/  Both sites have links enabling you edit or add to draft comment letters, then send them in directly using the built in on-line tool.  You can send several separate sets of comments to cover separate issues of concern to you.

In addition, the Water Legacy has a good video overview on how to prepare comments on the SDEIS, found at http://waterlegacy.org/node/159

The SDEIS can be found on the DNR website at www.mndnr.gov/polymet  The website also includes an executive summary, and a series of fact sheets and documents designed to help the public understand the proposed project.

A good source for objective reporting on new developments is the MPR website: http://minnesota.publicradio.org/

 

How to comment on the SDEIS
Public comments on the SDEIS can be submitted electronically at NorthMetSDEIS.dnr@state.mn.us or by mail to:

Lisa Fay, EIS Project Manager
MDNR Division of Ecological and Water Resources
Environmental Review Unit
500 Lafayette Road, Box 25
St. Paul, MN 55155-4025

Public review copies of the SDEIS are available at the following locations: the DNR/MPCA Library, 520 Lafayette Road, St. Paul; the DNR Regional Office at 1201 East Highway 2, Grand Rapids; the DNR-Division of Lands and Minerals Regional Office at 1525 Third Avenue East, Hibbing; the Hoyt Lakes Public Library at 206 Kennedy Memorial Drive, Hoyt Lakes; the Babbitt Public Library at 71 South Drive, Babbitt; the Duluth Public Library, 520 West Superior Street, Duluth; and the Minneapolis Public Library, 300 Nicollet Mall, Minneapolis.

All written comments become a part of the Final EIS record and are public information. Written comments will be accepted until 4:30 p.m. on March 13, 2014.

Following the public comment period, the DNR and co-lead agencies will review all comments, respond to substantive comments, adjust the SDEIS if needed, and ultimately publish a Final EIS for public review.