Written Comments on Aquifer Protection Permit for Sierrita Mine Note: Sorry--all attachments are not available on-line---yet... Following are my comments on the serious deficiency of the proposed Aquifer Protection Permit for Sierrita Mine.
My biggest concern is that many of the levels set as the Maximum Contaminant Level for toxic regulated chemicals have already been exceeded at the Points of Compliance, particularly for the Radioactive Chemicals. This is a clear indicator that something has to be done immediately. It will cost money now, but it will save money in the future. It’s the simple folk wisdom: “A stitch in time saves nine.” It is simply inconceivable and unacceptable that the Department of Environmental Quality has allowed this continued destruction of a natural resource, especially water in a desert state and in a sole source aquifer. Something has to be done NOW! THE EXPANDING SULFATE PLUME The plume has been growing, is growing, and will continue to grow. 1) Community Water is no longer pumping 2 acre feet per year out of the plume. Attached are two maps of the sulfate content in groundwater. I realize that both of these maps are quite dated—I don’t know why ADEQ has not asked for more current ones. The more complete analysis on Attachment A (1982) shows that the impact of the plume is not in simple concentric rings as shown on Attachment B. Although the levels have increase at the monitor wells at the dam berm some 300 to 400 mg/ltr and some 250 at monitor well MH-12, the greatest change has been the size and the northern movement of the plume. The maps also indicate that The Experanza Well Field and Community Well #7 are more likely being impacted by the Twin Buttes operations. Attachment A: Sulfate Content in Water from Wells in Vicinity of the Duval Sierrita Pond (Fall 1982) EFFECTIVE METHODS FOR CLEANING AND CONTAINMENT OF SULFATE PLUME We need effective methods for the plume’s containment that are not heavy water users. The drawdown on the aquifer is now 2 to 3 feet per year. Almost half of the usage is from Phelps Dodge mining operations. It is insane to use high water volumes to attempt to control pollution in a sole source aquifer—especially, when the Interceptor Wells are not working effectively. It is simply not logical to start putting money into cleaning up the plume when its existence has been known and measured since 1980 (Mines’ Task Force). It is partially ADEQ’s responsibility that Phelps Dodge Sierrita has had to keep throwing money into monitor wells and reports, rather than doing something about the problem. Two effective ways of cleaning and containing the plume that do not use copious amounts of water:
MONITORING FOR TOXIC CHEMICALS AND RADIOACTIVE CHEMICALS 1) There are regular spills of Sulfuric Acid at the plant. The officials claim that they move the contaminated soil. Where do they move it to? What is the impact on Groundwater? I have attempted with no success to have ADEQ and EPA look at the figures to determine if they were what were causing the spikes in the sulfate data at all the Community Water Company Wells. I noticed these spikes and wondered what caused them. They did not appear to be testing errors because The problem in analyzing the data was finding the time that the sulfuric acid would flow from the leach area to the wells. I finally found the magic number! 2) The use of toxic chemicals in the Flotation Process. These chemicals are hydrocarbons with complex configurations, but some are as simple as kerosene. It is claimed that the volatile organics used in the Flotation Process do not go into the slurry that goes into the tailings impoundment because they are filtered out before the slurry goes to the impoundment. This is not a sound analysis. a) Filtration is not a treatment technology for volatile organics. Treatment is pushing air the solution which releases the volatile chemicals into the air. See Attachment F: Tailings Slurry Water Chemicals Used in Flotation Process
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