Oral Comments at ADEQ Public Hearing on
Phelps Dodge Sierrita Mine Aquifer Protection Draft Permit
July 27, 2006
By Nancy Freeman
188 Calle del Año
Green Valley

520/207-6506
nanfree24@hotmail.com

I represent the interests of the community with whom I have had a lot of contact through informational meetings and speaking to the various clubs here. On behalf of the community, I want to thank the Department of Environmental Quality for all the hard work they have put into the formulating of this permit and Phelps Dodge for providing all the relevant data. The Permit represents years of work by many people. I know they have done a good job for us.

However, I have to comment on my concerns about the radioactive chemicals and transmitters that are in the groundwater near the tailing impoundment. I did cover this subject in the August 17, 2005 hearing’s comments. I know there has been a discussion over whether they are naturally occurring. As we know from the extensive report on Arizona Mining done by the Washington D.C. Environmental Protection Agency, mining operations can enhance the harmful potential of radioactive materials. Some of this enhancement is done in the processing itself and some of it is done when leach and chemical solutions seep into rock containing uranium. Although the Sierrita mine was covered in the report, unfortunately for our data needs, they only measured in the vicinity of the mill and waste rock piles, none at the impoundment.

I am disappointed that monitoring of the off-site monitor wells MH-11, MH-12, MH-13, MH-25 and MH-26, which would give a better picture of the movement of heavy metals and radioactive chemicals and transmitters, such as Gross Alpha, is not included in the Permit. Since concentrations of radiochems in MH-11, 12, 13 show fluctuations, it's possible that there's a mining-related source of radiochems and not a stable natural source. Unfortunately, although these strategically-located monitoring wells were put into operation in the mid-1980’s, as a result of the comprehensive Mines Task Force Report, there has been little monitoring of them. There are only three samples of radiochemical data—certainly, not enough to draw any conclusions. I don’t think we should abandon the monitoring of these five wells that can provide important data on the presence and movement off-site of radioactive chemicals and transmitters, as well as heavy metals. I also feel that the composition, including radioactive components, of the tailings slurry should be part of the relevant data collected to help with analysis.

I suggest that the radioactive contamination should be considered as a separate entity within the sulfate plume. A study of its characteristics should be conducted to understand the radiochemical behavior in the groundwater surrounding the tailings impoundment. This study and measures for remediation should be an important part of the Permit. As you can see on the attached report, [See Attachment A] the Gross Alpha levels have been creeping up in the tests of Community Water Wells #7 and #8, the ones that have the high sulfate levels--particularly, Well #8 which definitely is associated with the Sierrita sulfate plume.

Further, I am concerned that there is no specification of depths for testing in the monitoring wells. In some cases, it could be advantageous to have testing at more than one depth. As was discovered from the tests of sulfate in MH-25 and MH-26, the testing depths are very important.

In regard to the new monitor wells MH-27, MH-28, MH-29, I am concerned about testing for what is referred to as “ambient water quality” for POC wells. These wells are in areas that have already been contaminated to some extent, so that “current water quality” can be determined, but not “ambient water quality.”

Further, I would like to see some consequences of violations spelled out in the Permit. I feel the Permit Violation section is very weak, only requiring more monitoring and study. Even Phelps Dodge personnel must be weary of more monitoring and studying. What are the consequences of non-compliance?

As for compliance reporting, I suggest having a Standard Form for the monitoring data that is reported from the various labs. In looking over the compliance reports from Phelps Dodge’s Bagdad facility and ASARCO Silver Bell facility, both of which have a partial APP in place, it was noted that the data is compiled in an ad hoc manner. There are different formats from different labs. For example, in one case, the data from 4 POC wells (which could easily be compiled on 4 separate sheets) was scattered through some 30 data sheets, most of which had no data at all. This would make it difficult for the compliance unit to monitor the data that comes in.

In closing, I want to add for the record my continued concern for the lack of bonds for closures of all mines in Arizona. The corporation may have the funds now, but that does not mean they will be available in the future. Didn’t someone pay attention to the potential environmental disaster with ASARCO’s bankruptcy? There are a lot of closure issues in regard to the pit, leach piles and tailings impoundment and I doubt the projected numbers are realistic.

I am confident that we have a competent, reliable group of people working for us, both at ADEQ and Phelps Dodge Sierrita. I just ask of you as you deal with the details and numbers, please don't loose sight of the BASIC FACT: "We as a community want the clean water nature has given us: we do not want mining operations waste in any percentage at all in the water we drink, the water we bathe in, the water our pets drink, and the water we give their plants. This means bottled water and mixing contaminated water with good water are not on our list of possibilities."

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