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Introduction
Protect Our Water Our Future
We are a consortium of local business representatives, community leaders, adjacent property owners and residents who believe that the proposed Florence Copper Mine Project is directly incompatible with the overall intent and spirit of our community.
As residents of Florence, our goal is to protect the water resources and grow our community in a sustainable, safe manner. Our wide range of community members feel this process is too risky, untested, and unsustainable to be so close to our community, our water resources, and our families.
Curis Resources is requesting a MAJOR GENERAL PLAN AMENDMENT that would substantially alter the Town’s voter adopted General Plan vision for the community.
Curis is proposing changing from Residential and Commercial type uses to an Overlay District, with a concurrent rezoning case , which would allow for a highly controversial In-Situ Mining process to occur and ancillary industrial uses associated with the mine.
OWNERSHIP EXHIBIT
MERRILL RANCH –8,737 ACRES
Curis’ property is within the boundaries of the Merrill Ranch Master Planned Community, which was the result of years of planning, community involvement, and millions of dollars in investments by both private development and the Town of Florence.
The Curis property was envisioned to include approximately 4,000 residential home sites, two K-8 school sites, one public facilities site, various open space and park systems, and over 50 acres of commercial /mixed use.
The proposed mine will be located within 1.5 miles of existing homes and within less than a ½ mile of future planned residential homes.
There are no comparable in-situ mining projects in the U.S. that are in such close proximity to existing residential developments, and that will utilize the same water source that is shared by residents for potable uses.
The current General Plan allows for greater economic development and growth in the future than a risky mining operation.
Mining is not compatible/safe with the recent and future residential and commercial developments.
Water resources should be put to safer and more productive and economical uses.
For the proposed Florence Copper Mine Project, wells would be drilled through a drinking water aquifer into the ore body and sulfuric acid would be pumped underground to extract the copper.
ECONOMIC SUMMARY
REVIEW OF ECONOMIC SUMMARY PREPARED BY EDPCO CONCLUDED:
Over estimates impact to State, County, and Town by $80.4MM over life of project.
Over estimates indirect job creation by 248%, or 650 too many jobs
The impact from the FCP to the Town of Florence is approximately $654,000 annually, compared with approximately $1,800,000 for residential and commercial build out.
ENVIRONMENTAL
RISKS AND INCONSISTENCIES
CURIS CLAIM:―Clay aquitard acts a protective barrier to water quality in upper ground water zone‖
―Natural geology prevents water movement between aquifers‖
―Aquitard acts as a natural barrier to water movement‖
YET, WORK PERFORMED BY BROWN AND CALDWELL ON THIS PROJECT IN 1996 TELLS A DIFFERENT STORY…..
EXCERPT FROM B&C REPORT:
“The LBFU is the principal source of groundwater beneath the Site. The groundwater elevations and testing data generated from the wells in the mine block area at the Site indicate that the presence of the MFGU does not exert significant control on the circulation of water between the UBFU and the LBFU (underline added). The hydrologic characteristics measured at the site reflect conditions that are comparable to a relatively unconfined aquifer with significant connection into the bedrock intervals where mine block wells are constructed”(Brown and Caldwell, Volume II of V, Site Characterization Report, January 1996; Also presented in 2007 Closure Plan).
EXCERPT FROM B&C REPORT:
“The maximum difference in head between the vertical gradient contours between the LBFU and the bedrock oxide zone is plus or minus 2 feet. These observations are interpreted to mean that the LBFU and bedrock zone are in hydraulic communication” (Brown and Caldwell, Volume II of V, Site Characterization Report, January 1996).
WHAT DOES THIS MEAN?
Based on Brown and Caldwell’s past reports, the clay aquitard DOES NOTprevent the movement of water between the Upper and Lower basins.
In addition, the site is riddled with thousands of core holes that provide further conduits for water to move between the zones.
FLORENCE COPPER PROJECTFigure
1
Southwest Ground-water
Consultants, Inc.
March 30, 2011 Project B.1816
Map Source: Curis Resources Ltd. February 2011
Presentation
CURIS CLAIM:―ISCR operations will exclusively pump water from the bedrock aquifer beneath the basin fill aquifers‖
―Near-surface aquifers used for potable water will be unaffected by the Florence Copper Project‖
―ISCR operations will exclusively use deeper, groundwater sources not currently used for drinking water‖
IN REALITY:Curis will be injecting acidic solution directly into the ore body that is in direct communication with the aquifer used for regional drinking water purposes.
Future wells planned to provide water resources to Merrill Ranch and the region will be drilled to an approximate depth of 800-1,200 feet, which is the same approximate depth as the ore body Curis will be injecting the acidic solution into.
CURIS CLAIM: ―A low PH solution is injected into a soluble copper orebody.‖
―Solution strength is comparable to standard household vinegar.‖
IN REALITY …. Curis is proposing to recirculate extracted fluids multiple times to increase copper content, basically re-injecting heavy-metal laden mining solutions back into the aquifer. At this point, the solution will clearly not be akin to ―lemonade‖ or ―household vinegar‖
CURIS CLAIM:―ISCR technology and practices have been shown to have no long-term effects on water quality‖
IN REALITY:ISCR technology has historically been proven to affect ground water quality in a great majority of cases, including both Pinto Valley and San Manuel here in Arizona, as well as nearly all In-Situ Uranium mines in Texas and other parts of US.
IN REALITY:No North American in-situ mine has restored groundwater to pre-mining conditions.
Opposition to this form of mining is growing.
BHP’s test project, relied upon by Curis as proof of the process’s safety, is not an adequate indicator. Pilot test was 1-2% the size of the proposed FCP.
CURIS IN PUBLIC:
Curis describes their company as being ―associated with‖or ―a part of‖ the HDI group of companies.
IN REALITY:
HDI is simply a shareholder in Curis, and does notfunction as a ―parent‖ company that can be looked to in theevent of financial difficulty.
There will be no recourse to HDI should Curis incur financial hardships or cause damage to the environment or water supply. Curis is a stand-alone company whose only asset is the Florence Copper Project.
CURIS CLAIM:
―The State of Arizona will ensure that sufficient bonding or other financial sureties are in place to responsibly close and reclaim the Florence Copper Project at any stage of its operating life‖
IN REALITY:
Curis is proposing to provide a single financial assurance mechanism, insurance, for both the UIC and APP financial assurance requirements.
Curis proposes a policy with automatic renewals, contingent upon payment of premiums.
HOWEVER ….
The financial assurance is contingent upon payment of premiums. If Curis or its successor fails to pay the premiums due to insolvency or for other reasons, there are no funds with which to pay remediation and closure costs.
Although USEPA and ADEQ may receive notice from the insurer that the policy has been cancelled, it would be too late if Curis already has gone into bankruptcy, transferred its assets, or otherwise acted to protect itself from liability.
ADEQ and USEPA do not receive notices of bankruptcy or other notices warning them of action by Curis that might affect the financial assurance requirements.
CURIS CLAIM: ―A comprehensive reclamation and closure plan must be approved by the State of Arizona before Curis can initiate ISCR operations at Florence‖
IN REALITY: Curis describes the ―Closure and Post-Closure Plan‖ submitted with its APP Application to the State of Arizona as a ―closure strategy‖ rather than a closure plan.
As Curis recognizes in the application materials, an applicant is required only to submit a ―closure strategy‖ with an APP application.
A complete closure plan is required to be submitted only after the permittee has decided to permanently close all or part of a facility. Negotiation and approval of Curis’ ultimate closure plan, 20 or 30 years from now, is not subject to public hearing or comment.
Admittedly, it can be difficult to predict the life of an economically feasible mine. For this reason, mining companies prefer open-ended mine life projections and open-ended terms regarding the timing of closure and reclamation.
The lack of a standard in applicable permits, however, permits mining companies to routinely leave mines ―open‖ long after economically feasible operations are no longer possible. This helps the company avoid the cost of closure and reclamation.
Curis has not committed to a particular mine life in the APP permit. Instead, it states that mining will continue ―until economically recoverable copper has been removed from all of the permitted ISCR area.‖
Decisions regarding operational unit closure and reclamation likely will depend more upon economic factors and business conditions than upon ambiguous permit conditions.
CURIS CLAIM:―When ISCR operations at the Florence Copper Project are complete, the property may be returned to agricultural, residential or other land uses.‖
―ISCR is a temporary land use. Following the completion of ISCR operations at the Florence Copper Project, the property will be reclaimed and returned to productive use for residential development, agriculture, recreation or a combination of land uses.‖
IN REALITY:
Curis has NOT committed to return groundwater to pre-mining conditions.
Curis does not propose to return all chemical constituents in groundwater to pre-mining concentrations.
Rather, Curis plans to remediate only as necessary to return concentrations to ―a level that meets either the Arizona Water Quality Standards (AWQS) or pre-operational background concentrations,‖ whichever is higher.
Curis has NOT committed to return soils at the site to residential levels.
Arizona law requires contaminated soils to be cleaned to residential or non-residential standards, as appropriate. Non-residential standards are easier and cheaper to meet.
Curis has told the public the site can be used for residential purposes after mining, but has not committed to remediate to residential levels in the application.
OTHER ITEMS TO CONSIDER:Groundwater monitoring wells will remain in place for 30 years. As a practical matter, access must be maintained around each well for operation, maintenance, and sampling.
Underground sumps and other concrete structures, septic tanks, and retention pond liners will be buried onsite.
The six large evaporation ponds will be closed with their liners in place. Other liners and leak collection, removal systems, and demolition debris could be placed back into excavations and buried on site.
CURIS CLAIM:
There will be no impacts to groundwater.
CURIS IN PERMIT:
Ignored existing and planned drinking water wells.
Groundwater will be cleaned up to water quality standards or pre-mining background concentrations, whichever is higher.
Minimal sampling based on average sulfate levels.
Minimal monitoring network.
CURIS CLAIM:
Extraction wells surrounding injection well will control and contain injected mining fluids.
CURIS IN PERMIT:
It is not economic to control mining fluids with extraction wells because too much groundwater will be sent to processing plant. Will control contaminants through perimeter wells at the edges of the mining area.
COMPARABLE PROJECTS
Groundwater at Pinto Valley mine has been contaminated by Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM).
Data from groundwater monitoring at the mine indicates that radioactive materials have leached into groundwater at concentrations above federal and state limits.
In 2008, Pinto Valley mine was the 10th largest polluter in Arizona, releasing over 2 million pounds of chemicals, metals, and other contaminants into the soil, air, and water.
Despite nearly 25 years of commercial ISL uranium mines in the United States (all using alkaline leaching solutions), regulators are yet to review or approve a report on the full scale restoration of groundwater at these sites . . . .‖ Gavin Mudd, An Environmental Critique of In Situ Leach Mining, at
vii (July 1998).
After reviewing groundwater data for uranium ISL mines in Texas, the USGS concluded that none of the mines were able to restore groundwater to pre-mining conditions. Similar conclusions have been found in regard to ISL mines in Wyoming, Colorado, and other states.
San Manuel, Arizona
Dissimilar leaching operation over crushed ore and historical open pit mine areas.
Impossible to determine impacts of in-situ leach mining due to decades of underground and open-pit mining.
Groundwater was flowing toward open-pit, preventing contamination outside of mine area, but owner has no solution for the contaminated lake created in the pit.
Texas In-Situ Uranium Mines-2009 USGS Survey22 well fields at 13 different uranium ISL mines:
NONE had returned groundwater to pre-mining conditions.
10 of 26 contaminants exceeded pre-mining levels at more than half of these well fields.
State regulators routinely amended permits to increase target levels and remediation standards. Permitted sulfate levels increased up to 1,685% Permitted arsenic levels increased up to 1,438%
Contaminant trends began to increase again after groundwater restoration efforts stopped.
TAKE ACTION
Review application for administrative completeness—done.
Technical review—in process.
Prepare draft permit with input from applicant.
Issue draft permit for public comment, hearing.
Respond to comments and make decision on permit.
Review application for administrative completeness—done.
Technical review—in process.
Prepare draft permit with input from applicant.
Issue draft permit for public comment, hearing.
Respond to comments and make decision on permit.
ADEQ-APP Permit 101704
Michael Fulton
Water Quality Division Director
USEPA-UIC Permit AZ396000001
David Albright
Manager, Ground Water Office (WTR-9)
Public Hearing Schedule
1st Hearing with the Planning and Zoning Commission -September 15, 2011. (Anthem at Merrill Ranch Sun City Community Center – 3925 North Sun City Boulevard at 5:30 PM)
2nd Hearing with the Planning and Zoning Commission – October 6, 2011. (Town Hall Council Chambers – 775 North Main Street at 5:30 PM.)
Town Council hearing – November 7, 2011 (Town Hall Council Chambers – 775 North Main Street at 6:00 PM.)
The Town Staff, Planning & Zoning Commission, and Mayor & Town Council need to hear your voices and see that you are against the Curis Florence Copper Project.
Please sign the petition, send e-mails, mail letters, telephone, and attend the Town public hearings.
The Town of Florence reference case numbers are
Major General Plan Amendment for a Text Amendment (Application No. – PZC-32-11- MGPA).
Major General Plan Amendment for a Land Use Amendment (Application No. – PZC-33-11- MGPA).
PUD Rezoning Application (Application No. – PZC-34-11-PUD)
For more information and updates go to:
www.protectourwaterourfuture.com
or email:
