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Protect Our Water Our Future Florence Community Meeting November 27, 2012.

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Presentation on theme: "Protect Our Water Our Future Florence Community Meeting November 27, 2012."— Presentation transcript:

1 Protect Our Water Our Future Florence Community Meeting November 27, 2012

2 ADEQ (State) 1.Amended APP Request (including commercial operations) Curis did not answer ADEQs Sept Deficiency Letter Suspended review at Curiss request. Update on Environmental Permits POWOF Community Meeting, Nov. 27, 20122

3 ADEQ (State) 2.Temporary APP After the Town denied Curiss land use requests & Curis was unable to demonstrate zoning compliance for the full project Separate application for a Temporary Permit for PTF operations on State land Permit issued & can be viewed at Update on Environmental Permits POWOF Community Meeting, Nov. 27, 20123

4 USEPA (Federal) Ongoing review of Curiss request for a UIC permit. Update on Environmental Permits POWOF Community Meeting, Nov. 27, 20124

5 Southwest Value Partners, Pulte, Town of Florence, Johnson Utilities v. ADEQ Arguing ADEQs temporary permit regulation is illegal Permit terms are not part of lawsuit Ongoing dispute Ongoing Litigation Against ADEQ POWOF Community Meeting, Nov. 27, 20125

6 ADEQs Public Participation Process Public Hearing December 5 from 6:00 to 8:30 at Florence High School Written Comments to ADEQ no later than December 23 rd. ADEQ review, response to comments & final decision Whats Next? POWOF Community Meeting, Nov. 27, 20126

7 Curiss Temporary Aquifer Protection Permit Overview & Key Points POWOF Community Meeting, Nov. 27, 20127

8 Conduct a PTF Pilot on a portion of State land One 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, 20128

9 9 Project Overview

10 POWOF Community Meeting, Nov. 27, Curiss PTF Pilot Blue: Curiss land holdings Green: State Land Orange: PTF Injection Well Field

11 POWOF Community Meeting, Nov. 27, Curiss PTF Pilot

12 Not a Pilot Project Will not prove that commercial operations will be safe LBFU versus UBFU Hydraulic control still an issue Inadequate well field setup Inadequate water quality parameters Inadequate groundwater monitoring Inadequate precautions for old core holes Unrealistic groundwater clean up assumptions Key Points to Know About Curiss Temporary Permit - Overview POWOF Community Meeting, Nov. 27,

13 Temporary permit criteria not met. A discharge lasting 6 months? NO! A short-term pilot designed to develop data for the full-scale projects permit application? NO! PTF operations necessarily exceed the permit term. ADEQ should deny/revoke the permit. POWOF Community Meeting, Nov. 27, Key Points Contd. Curiss PTF is Not a Pilot

14 Curiss PTF will NOT: Provide new data needed to prove up the safety of commercial operations Answer ADEQs questions posed in its Deficiency Letters POWOF Community Meeting, Nov. 27, Key Points Contd. Curiss PTF is Not a Pilot

15 Curiss 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 Contd. Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27,

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 Curiss 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 Contd. Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27,

17 Key Points Contd. Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27,

18 Curiss 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 successful Actual 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 Curiss position & will require demonstration of hydraulic control as part of PTF operations. Key Points Contd. Hydraulic Control POWOF Community Meeting, Nov. 27,

19 Curiss PTF pilot well field design differs significantly from the design proposed for commercial production. PTF does not include any perimeter wells to maintain hydraulic control Proposed commercial operations includes perimeter wells hundreds of feet from recovery wells – spacing that provides opportunity for acid mining solutions to escape Curiss control. PTF will generate useless data because the PTF design fails to replicate conditions of proposed commercial operations. Key Points Contd. Inadequate Well Field Setup POWOF Community Meeting, Nov. 27,

20 Financial assurance does not address off-site impacts or injury to neighboring landowners property rights & property values Financial assurance is based upon the cost estimates submitted in Curiss application The 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 Contd. Financial Assurance POWOF Community Meeting, Nov. 27,

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 Dont buy into Curiss claim that solution is akin to vinegar or lemon juice This solution will release numerous contaminants such as radiochemicals, magnesium, aluminum, and many more Based on Curiss 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 Contd. Acidic Solution Claims POWOF Community Meeting, Nov. 27,

22 Arsenic Curis 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 Sulfate Curis proposed sulfate standards that exceeded secondary drinking water standards Key Points Contd. Water Quality Parameters POWOF Community Meeting, Nov. 27,

23 Reserved Standards For 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 Contd. Water Quality Parameters POWOF Community Meeting, Nov. 27,

24 Curiss proposed monitor wells will not provide new data to prove up the safety of commercial operations. Curiss 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 PTFs purpose is truly to collect data to prove environmental safety, why propose such meager data collection? Temporary Permit Sampling Requirements Level 1 pollutants – quarterly sampling during the 2-year PTF life Level 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 Contd. Inadequate Monitoring POWOF Community Meeting, Nov. 27,

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 Contd. Inadequate Monitoring POWOF Community Meeting, Nov. 27,

26 POWOF Community Meeting, Nov. 27, Key Points Contd. Inadequate Monitoring

27 POWOF Community Meeting, Nov. 27, Curis proposed & the permit incorporates 4 pre- existing wells as POC wells. These 4 wells are outside the reach of even Curiss predicted 5-year sulfate plume.

28 POWOF Community Meeting, Nov. 27, Key Points Contd. 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.

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. POWOF Community Meeting, Nov. 27, Key Points Contd. Inadequate Core Hole Precautions

30 Permit only requires abandonment 500 feet around the injection well field. Proper abandonment around monitor wells & other site features needed. POWOF Community Meeting, Nov. 27, Key Points Contd. Inadequate Core Hole Precautions

31 Overwhelming Number of Core Holes A closer look of just the number of known unabandoned core holes is not very reassuring. POWOF Community Meeting, Nov. 27, Key Points Contd. Inadequate Core Hole Precautions

32 POWOF Community Meeting, Nov. 27, Curiss 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.

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 Contd. Unrealistic Groundwater Clean Up POWOF Community Meeting, Nov. 27,

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,

35 Stay Vigilant. Review the permit & form your own conclusions. Permit available at Share your thoughts with the relevant agencies. Attend ADEQs Public Hearing on December 5 th at 6:00 p.m. at Florence High School & speak up. What Can I Do? POWOF Community Meeting, Nov. 27,

36 Submit to ADEQ formal written comments on the temporary permit Due December 23 rd Continue to share your thoughts by also writing to: Arizona State Land Department Governor Brewer USEPA What More Can I Do? POWOF Community Meeting, Nov. 27,


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