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Protect Our Water Our Future. Florence Community Meeting November 27, 2012. Update on Environmental Permits. ADEQ (State) Amended APP Request (including commercial operations) Curis did not answer ADEQ’s Sept. 2011 Deficiency Letter Suspended review at Curis’s request. - PowerPoint PPT Presentation
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Protect Our Water Our Future
Florence Community MeetingNovember 27, 2012
POWOF Community Meeting, Nov. 27, 2012 2
ADEQ (State)1. Amended APP Request
(including commercial operations) Curis did not answer ADEQ’s Sept. 2011 Deficiency LetterSuspended review at Curis’s request.
Update on Environmental Permits
POWOF Community Meeting, Nov. 27, 2012 3
ADEQ (State)2. Temporary APP
After the Town denied Curis’s land use requests & Curis was unable to demonstrate zoning compliance for the full projectSeparate application for a Temporary Permit for PTF operations on State landPermit issued & can be viewed at http://www.azdeq.gov/environ/water/permits/index.html
Update on Environmental Permits
POWOF Community Meeting, Nov. 27, 2012 4
USEPA (Federal)Ongoing review of Curis’s request for a UIC permit.
Update on Environmental Permits
POWOF Community Meeting, Nov. 27, 2012 5
Southwest Value Partners, Pulte, Town of Florence, Johnson Utilities v. ADEQArguing ADEQ’s temporary permit regulation is illegalPermit terms are not part of lawsuitOngoing dispute
Ongoing Litigation Against ADEQ
POWOF Community Meeting, Nov. 27, 2012 6
ADEQ’s Public Participation Process
Public Hearing — December 5 from 6:00 to 8:30 at Florence High SchoolWritten Comments to ADEQ — no later than December 23rd.
ADEQ review, response to comments & “final” decision
What’s Next?
POWOF Community Meeting, Nov. 27, 2012 7
Curis’s Temporary Aquifer Protection Permit
Overview & Key Points
POWOF Community Meeting, Nov. 27, 2012 8
Conduct a PTF “Pilot” on a portion of State landOne injection/extraction well field Conduct limited monitoring Construct an SX/EW plant “Limited” duration operation & permit
1 year term & possible 1-year renewal
What Does the Temporary Permit Allow Curis to do?
POWOF Community Meeting, Nov. 27, 2012 9
Project Overview
POWOF Community Meeting, Nov. 27, 2012 10
Curis’s PTF “Pilot”
Blue: Curis’s land holdings
Green: State Land
Orange: PTF Injection Well Field
POWOF Community Meeting, Nov. 27, 2012 11
Curis’s PTF “Pilot”
POWOF Community Meeting, Nov. 27, 2012 12
Not a Pilot ProjectWill not prove that commercial operations will be safe
LBFU versus UBFUHydraulic control still an issueInadequate well field setupInadequate water quality parametersInadequate groundwater monitoring Inadequate precautions for old core holesUnrealistic groundwater clean up assumptions
Key Points to Know About Curis’s Temporary Permit
- Overview
POWOF Community Meeting, Nov. 27, 2012 13
Temporary permit criteria not met.A discharge lasting 6 months? NO!A short-term pilot designed to develop data for the full-scale project’s permit application? NO!
PTF operations necessarily exceed the permit term.ADEQ should deny/revoke the permit.
Key Points Cont’d.Curis’s PTF is Not a Pilot
POWOF Community Meeting, Nov. 27, 2012 14
Curis’s PTF will NOT:Provide new data needed to prove up the safety of commercial operationsAnswer ADEQ’s questions posed in its Deficiency Letters
Key Points Cont’d.Curis’s PTF is Not a Pilot
POWOF Community Meeting, Nov. 27, 2012 15
Curis’s whole premise for safety of their operation and protecting drinking water is WRONG
Acid mining solutions will be injected into the aquifer at same depth as LBFU where groundwater is pulled for drinking water purposes“Clay Aquitard” is completely irrelevant to protecting groundwater from users in the LBFU
Key Points Cont’d.Lower Basin Fill Unit (LBFU)
POWOF Community Meeting, Nov. 27, 2012 16
Curis inaccurately claims that the principal source of groundwater withdrawals is from the Upper Basin Fill Unit (UBFU). Reality is that the LBFU is the principal source for groundwater withdrawals.
Johnson Utilities – well located just over a mile from Curis’s operations, and pulls water from the LBFU at a depth of approximately 597 feet. Well has demonstrated excellent water quality.Other drinking water wells – proposed to serve Merrill Ranch & Florence are planned to be installed within the LBFU.
Key Points Cont’d.Lower Basin Fill Unit (LBFU)
POWOF Community Meeting, Nov. 27, 2012 17
Key Points Cont’d.Lower Basin Fill Unit (LBFU)
POWOF Community Meeting, Nov. 27, 2012 18
Curis’s principal argument for safety and protecting downgradient users is based on concept of hydraulic control
However, Curis expressed views in their application that demonstrating hydraulic control was unnecessary because BHP proved their test was successfulActual BHP test data shows they lost hydraulic control for a 2 to 3 day period with gradient differential documented during a 12-hour period that was greater than 48 feet.
Curis has never addressed this data and inaccurately claims BHP demonstrated hydraulic control
USEPA has rejected Curis’s position & will require demonstration of hydraulic control as part of PTF operations.
Key Points Cont’d.Hydraulic Control
POWOF Community Meeting, Nov. 27, 2012 19
Curis’s PTF “pilot” well field design differs significantly from the design proposed for commercial production.
PTF does not include any perimeter wells to maintain hydraulic controlProposed commercial operations includes perimeter wells hundreds of feet from recovery wells – spacing that provides opportunity for acid mining solutions to escape Curis’s control.
PTF will generate useless data because the PTF design fails to replicate conditions of proposed commercial operations.
Key Points Cont’d.Inadequate Well Field Setup
POWOF Community Meeting, Nov. 27, 2012 20
Financial assurance does not address off-site impacts or injury to neighboring landowners’ property rights & property valuesFinancial assurance is based upon the cost estimates submitted in Curis’s applicationThe temporary permit only requires Curis to maintain financial assurance through the “life of this permit”
Remember that this permit can only last up to 2 years
Key Points Cont’d.Financial Assurance
POWOF Community Meeting, Nov. 27, 2012 21
Geochemistry of PTF vs. Commercial operation will be different – Curis proposed “stacking” or “re-acidification” of solution in commercial permit application, PTF design does not allow for “stacking”Don’t buy into Curis’s claim that solution is akin to vinegar or lemon juice
This solution will release numerous contaminants such as radiochemicals, magnesium, aluminum, and many moreBased on Curis’s own reports, they propose to inject more than 10 BILLION POUNDS of sulfuric acid into the ground over the life of the commercial operation
Key Points Cont’d.Acidic Solution Claims
POWOF Community Meeting, Nov. 27, 2012 22
ArsenicCuris proposed an arsenic standard that exceeded federal drinking water standards (5o ppb vs. 10 ppb)Temporary permit requires compliance with arsenic standard only on a “theoretical” level based on modeling
SulfateCuris proposed sulfate standards that exceeded secondary drinking water standards
Key Points Cont’d.Water Quality Parameters
POWOF Community Meeting, Nov. 27, 2012 23
“Reserved” StandardsFor numerous points of compliance, the permit establishes no ALs or AQLs at all, leaving them to be set during PTF operations and without public comment or input
Key Points Cont’d.Water Quality Parameters
POWOF Community Meeting, Nov. 27, 2012 24
Curis’s proposed monitor wells will not provide new data to prove up the safety of commercial operations.Curis’s Proposed Sampling
In its application, Curis proposed to monitor groundwater contaminants such as heavy metals, arsenic & radiochemicals bi-annually during the 2-year life of the PTF.If the PTF’s purpose is truly to collect data to prove environmental safety, why propose such meager data collection?
Temporary Permit Sampling RequirementsLevel 1 pollutants – quarterly sampling during the 2-year PTF lifeLevel 2 pollutants – semi-annual sampling during the 2-year life
More frequent sampling needed.Compare uranium ISL mines – bi-weekly Level 1 pollutant monitoring
Key Points Cont’d.Inadequate Monitoring
POWOF Community Meeting, Nov. 27, 2012 25
Properly placed monitor wells needed.Compliance wells are located too far away.Contaminants will not be detected in compliance wells until long after the PTF has been completed.
Properly designed monitor wells needed.Several multi-port sampling wells need to be installed at or within the PTF well boundary.Multi-port sampling wells should be sampled at the same depth as proposed injection to evaluate whether contaminants are being released.
Key Points Cont’d.Inadequate Monitoring
POWOF Community Meeting, Nov. 27, 2012 26
Key Points Cont’d.Inadequate Monitoring
POWOF Community Meeting, Nov. 27, 2012 27
Key Points Cont’d.Inadequate Monitoring
Curis proposed & the permit incorporates 4 pre-existing wells as POC wells. These 4 wells are outside the reach of even Curis’s predicted 5-year sulfate plume.
POWOF Community Meeting, Nov. 27, 2012 28
Key Points Cont’d.Inadequate Monitoring
The permit requires one additional monitor well to be located downgradient & near the PTF well field. But its actual location is yet to be determined & its design is not specified.
POWOF Community Meeting, Nov. 27, 2012 29
BHP Pilot showed what other ISL mines have already confirmed — that unabandoned core holes can cause real problems.
In 1999 BHP concluded that exceedances in 2 wells (1 of which is a POC well in the Temporary Permit) were due to communication between the aquifers & cited to 2 open core holes.
Key Points Cont’d.Inadequate Core Hole Precautions
POWOF Community Meeting, Nov. 27, 2012 30
Permit only requires abandonment 500 feet around the injection well field.
Proper abandonment around monitor wells & other site features needed.
Key Points Cont’d.Inadequate Core Hole Precautions
POWOF Community Meeting, Nov. 27, 2012 31
Overwhelming Number of Core
Holes
A closer look of just the number of
known unabandoned core holes is not very
reassuring.
Key Points Cont’d.
Inadequate Core Hole
Precautions
POWOF Community Meeting, Nov. 27, 2012 32
Curis’s PTF Site Plan
The permit only requires core hole abandonment within the 500-foot radius of the PTF well field – here indicated by the hashed line figure.
POWOF Community Meeting, Nov. 27, 2012 33
Unrealistic groundwater cleanup assumptions not corrected in permit.
9 months aquifer “rinsing” 30-day resting period & sampling
Compare Uranium ISL mine experience. Groundwater cannot be restored to pre-mining conditions within 9 months.Contaminant rebound can occur months or years after mining has ended.
Key Points Cont’d.Unrealistic Groundwater Clean Up
POWOF Community Meeting, Nov. 27, 2012 34
ADEQ is listening to our concerns. So continue to voice your thoughts & your concerns to the agencies.
Temporary permit includes some standards related to arsenic – direct response to our concerns.One monitor well added to those proposed by Curis – again in apparent response to our concerns.
What Can I Do?
POWOF Community Meeting, Nov. 27, 2012 35
Stay Vigilant.Review the permit & form your own conclusions.Permit available at http://www.azdeq.gov/environ/water/permits/index.html
Share your thoughts with the relevant agencies.
Attend ADEQ’s Public Hearing on December 5th at 6:00 p.m. at Florence High School & speak up.
What Can I Do?
POWOF Community Meeting, Nov. 27, 2012 36
Submit to ADEQ formal written comments on the temporary permit
Due December 23rd
Continue to share your thoughts by also writing to:
Arizona State Land DepartmentGovernor BrewerUSEPA
What More Can I Do?