Thank you for the opportunity to comment on the Expanded Checklist Environmental Assessment for Tintina Resources Inc. Black Butte Copper Aquifer Test 2014. These comments are submitted on behalf of Earthworks, a non-profit organization dedicated to protecting communities and the environment against the adverse impacts of mining.
The proposed project is located at the headwaters of the Smith River, one of the most treasured streams in Montana for its premier recreational opportunities, beautiful scenery and renowned trout fishing. The Smith is heavily promoted by the State to residents and visitors, and it is an important economic engine for the region – generating over $1.7 million in 2011.
The Sheep creek drainage accounts for 55% of the tributary spawning. FWP has documented rainbow trout from the Missouri River traveling 190 miles round trip to spawn in Moose Creek. This discovery demonstrates the importance of Sheep Creek in supporting or sustaining the Smith River and Missouri River trout fisheries.
Tintina’s proposal involves the disposal of over 1 million gallons of arsenic-laden groundwater, by using a land application disposal (LAD) system to spray it on 40 acres of land. According to the Environmental Assessment (EA), the LAD system will result in zero discharge to groundwater or surface water. Based on that determination, DEQ has selected the agencymodified alternative that approves the LAD system.
We are concerned about the elevated levels of arsenic in the LAD, and the potential for discharge to groundwater. We are unaware of any metal mines in Montana with LAD systems that have resulted in zero discharge, and most have resulted in impacts to water quality. Even the LAD system at the Stillwater mine, where there is extensive experience at land application, has resulted in the breakthrough of nitrogen into groundwater.
Tintina’s proposed land application calculations are inappropriate because they are based entirely on NRCS irrigation requirements for crops, when it appears that the area includes native 1612 K ST. N.W. / SUITE 808 / WASHINGTON, DC 20006 / P 202 887 1872 F 202 887 1875 / WWW.EARTHWORKSACTION.ORG vegetation. It also appears that the LAD system will need to operate in October, given the 90-day time period requirement for the pump tests. Yet, Tintina’s proposal fails to calculate application rates in October when evapotranspiration will be significantly lower due to colder temperatures and shorter days.
It is difficult to predict the chemical and physical impacts of LAD, as we’ve repeatedly seen at mines across the state. As a result, LAD should always be the last resort – particularly in such an important watershed. LAD is not the best method for disposing of pump test water. It is simply the cheapest.
Given the reasonable potential that a discharge to groundwater and violation of water quality standards could occur, we believe the EA is inadequate and the Department should require water treatment at the site to nondegradation water quality standards using proven water treatment technology (i.e., reverse osmosis), and incorporate a far more rigorous monitoring program.
