A Section from Alternative One Public Commentary on the SDEIS
Read the Recreation and Tribal Issues Commentary Section
In response to the June, 2009 letter that the Environmental Protection Agency submitted as commentary regarding the DEIS for the Montanore Mine plan, the SDEIS names Alternative 3, the Agency Mitigated Poorman Creek Impoundment Alternative, as preferable to Alternative 4, the previously preferred Agency Mitigated Little Cherry Creek Impoundment.
The SDEIS and permitting agencies take this as tacit approval for a less invasive but still critically flawed plan for disposing of mining waste, human waste, and chemical waste. The fact that the KNF chose a location within the proposed Poorman site to develop as a gravel pit gives credence to their tacit acceptance of this tailings impoundment location.
We adamantly disagree that Alternative 3 is a viable plan, and have identified several critical difficulties with the concept of the Poorman Impoundment proposal as described in the document.
Imprecise and Incomplete
Because the SDEIS contains no design specifics for the Poorman site, stating on page 47 that the design “is conceptual only and is based on limited geotechnical investigations,” MMC has at least one additional SDEIS in its future. Its proposal certainly should not be permitted based on a promise to provide details at an unspecified later date.
A field exploration program must be completed upon which to base a safe and effective containment facility for mining waste, and there can be absolutely no credible reason that the corporation did not complete this essential step prior to declaring the SDEIS complete.
Public scrutiny of the final impoundment plan along
with the opportunity to submit oral and written commentary on the design is
mandated under NEPA. 
MMC seems to believe that the tailings dam eyesore would actually become a scenic point of interest
Montanore Minerals Corp. has cut corners to an
unacceptable degree in its plan for the tailings impoundment under Alternative
3. On page 45 of the SDEIS, Volume I, it
states, “Waste rock developed extending the Upper Libby Adit and the new Libby
Adit would be hauled to a waste rock stockpile within the Poorman Tailings
Impoundment footprint, the location of which would be determined during final design.”
This begs the question, why hasn’t the corporation commissioned the final design of this critical component of the milling operation? A final design plan is a critical omission in a document evaluating environmental impacts.
Further statements in this section of the SDEIS underscore the imprecise and incomplete nature the mine proposal: “If monitoring results or other waste rock testing indicated water treatment would be necessary, the waste rock stockpile would be lined with clay or a geomembrane to achieve a permeability” (p. 45). This is a totally unacceptable plan, given the fact that by the time testing is completed, the stockpile would already have leaked heavy metals into the watershed. The agencies should demand a professionally drafted plan that includes a lined storage area that will preclude any leakage from the outset.
The most environmentally acceptable alternative to the Poorman Creek Tailings Impoundment is transporting the tailings to a processing facility outside the KNF.
As presented in the SDEIS, seepage of contaminant-laden water from the tailings impoundment not captured by the facility’s underdrain system would be around 25 gallons per minute (p. 327, SDEIS Vol. 1) – 36,000 gallons per day – at the mine’s closure. Contaminant leakage would purportedly decrease to around 17 gpm – 24,480 gallons per day – after ten years’ time, then 5 gpm – 7,200 gallons per day – “in the long term,” according to SDEIS projections, directly into the water table. (p. 332)
Given the fact that no design for the actual tailings impoundment yet exists, these predictions regarding seepage and flow are at present pure speculation, and are likely to be much more conservative than they would be if based on a professionally rendered design.
While Montanore’s conceptual and preliminary tailings impoundment model would theoretically capture the majority of contaminated water before it can mix with groundwater, the historic performance of other hard rock waste dumps and tailings impoundments tells a different story. A study by the U.S. National Research Council Committee on Hardrock Mining of Federal Lands concludes that nearly all waste containment systems of the type described in the Montanore proposal are permeable; in other words, they leak. Additionally, “impacts on water quality, vegetation, and aquatic biota often extend beyond the immediate area of the mine site.”
We believe that the entire SDEIS is based on the most positive depiction of an as-yet non-existent tailings impoundment plan. This best-case scenario contrived by the authors of the SDEIS does not present an accurate account of potential problems with leakage of polluted waste into the natural water system of the Kootenai National Forest.
We contend that such a nebulous scenario cannot be the basis of any final decision for permitting the Montanore Mine, and that until MMC provides the agencies with a complete design for the tailings impoundment that includes a contingency plan for containing leakage of polluted wastewater into the watershed, no operating permit should be granted.
Visual Impairment
Who would want a bird's eye view of a toxic dump site?
The long-term legacies of the proposed Poorman Creek Tailings Impoundment Alternative would be not only perpetually polluted waterways, with a minimum of 7,200 gallons of toxic water leaking into the creeks every day in virtual perpetuity, but a tailings dump site the height of a 36 story office building that covers nearly two miles of denuded forest, sitting like a supersized burial mound in plain view of recreationalists visiting the Kootenai National Forest.
Not only does the SDEIS gloss over this long-lasting legacy of its disembowelment of the Cabinet Mountains, but MMC seems to believe that such an eyesore would actually become a scenic point of interest:
MMC would design and construct a scenic overlook with information and interpretive signs on NFS road #231 (Libby Creek Road) downstream of the Midas Creek crossing with views of the tailings impoundment. MMC would develop two interpretative signs, one on the mining operation and another one on the mineral resource and geology of the Cabinet Mountains. Parking would be developed in cooperation with the KNF. (p. 43, SDEIS, Volume 1)
Rather than an added bonus to the
wholesale destruction of the Kootenai National Forest within the proposed
Montanore operational boundaries and beyond, we consider such a concept to be
invasive and extremely ill-thought-out. Who would want a bird’s eye view of a
toxic dump site? 
We vehemently protest the development of such a “scenic overlook.” Similarly, we protest the development of any other Key Observation Points in the Kootenai National Forest. As far as the interpretive signs mentioned in the SDEIS, we have had our fill of MMC’s insistence on the “importance” of the work they are doing. Again, we protest such an installation in our federally owned lands.
We also fail to appreciate the value of MMC becoming involved in any way in other recreational areas of the KNF. For example, the idea of MMC “funding a volunteer camp host…at Howard Lake Campground” is horrifying. By the way, how can one “fund” a volunteer?
Montanore Mine Proposal Tailings Impoundment Plan Critically Flawed (cont. from left)
The Backfilling Alternative
Montana DEQ commissioned a study in 2008 entitled “Backfilling Pre-Feasibility Study Montanore Project” that considers the “environmental, economic, and geotechnical implications” of putting the mine tailings back into the bowels of the mountain from whence they came.
The study is basically flawed in its focus on backfilling as a function of the unaltered Montanore proposal, with no provisions considered that, while requiring changes to an as yet unimplemented plan, would facilitate the success of a backfilling program:
These evaluations were made based on the assumption that backfilling would take place without modification to the currently proposed mining method or the mining excavation geometries. (p. iii)
We believe that wetlands are too critical to the overall health of the Kootenai National Forest to dismiss a thorough exploration of any plan, no matter the cost, that would minimize their destruction.
Why would the study designers limited their research with such artificially imposed parameters? Based on the paste model for backfilling, the study concludes that this option for tailings storage would reduce the volume of waste rock sent to the Poorman impoundment by between 33 and 48 percent (p. 9), but would only reduce the tailings “footprint” by 20 percent. However, it does not say how much the height of the impoundment would be reduced. ( p. iv)
On page 99 of the SDEIS, it states that “if the volume of tailings requiring surface disposal could be reduced by 33 to 40 percent [by backfilling], effects on wetlands and other waters of the U.S. would be reduced. This is virtually the only statement in the document that actually refers to an option for minimizing the effects to wetlands that would be brought to bear by the Montanore project. Minimization of wetland destruction is a prime consideration that must be fully explored prior to mitigating this destruction with replacement wetlands, according to the EPA Executive Order, as discussed in the Endangered Species section of our written commentary.
However, as is true in many other sections of the SDEIS, this viable option to minimize wetland destruction in the Kootenai National Forest is summarily dismissed because “backfilling at Montanore would result in significantly greater capital and operating costs than would normally be associated with room-and-pillar mining projects.”
Because “significantly greater” is not quantified in terms of dollars and cents, this dismissal of backfilling is meaningless. We believe that wetlands are too critical to the overall health of the Kootenai National Forest to dismiss a thorough exploration of any plan, no matter the cost, that would minimize their destruction.
In section 2.1 of the Backfilling Pre-feasibility Study, dry placement of tailings in the mine void is briefly considered and discarded, because of “the costly dewatering, labor-intensive transportation requirements and the inefficient use of backfilling space.” However, no comparative information is provided that determines how the cost of this type of backfilling option would compare to the tailings impoundment model.
In section 2.2, the study briefly considers and discards the option of pneumatic transport of tailings to the mine void: “Because of the costly dewatering, limited transportation distances and limited placement rate, AAI believes pneumatic placement of tailings is not technically applicable to or cost-effective for the Montanore project.”
Is there a reason no one but AAI is privy to the actual numbers upon which they based these conclusions? It is impossible to compare costs due to the lack of specifics in this report. Besides, we would like to know the standards by which tailings backfill would be “too costly,” given the extremely high environmental cost represented by the Poorman Tailings Impoundment Alternative.
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Tailings Impoundment Plan cont. from left
In section 2.3, hydraulic transport of tailings to the mine void is also considered and discarded, because it would not leave enough “sand-sized tailings…for construction of the dam surrounding the surface tailings impoundment, necessitating that MMC obtains more sand at additional cost.” First of all, this constitutes circular reasoning, since if the majority of tailings were backfilled, the size of the dam needed to contain non-backfilled waste would be considerably reduced. Secondly, we hardly agree that the plan can legitimately be discarded because MMC would have to purchase some sand.
The study concludes, perhaps erroneously as far as we can determine from the information provided, that the only backfill method that would be suitable for the Montanore project is paste backfill in which the fine tailings would be mixed with cement prior to transport to the mine void.
Despite objection upon objection that the study raises with this backfill model, paste backfill is practiced successfully by several Canadian mines, according to this report. If those mines have overcome difficulties and objections to this method of tailings disposal, so can Montanore, with considerably less damage to the natural waterways and scenic quality of the Kootenai National Forest.
The objection voiced on page 11 of the study, that “the addition of backfill is not likely to significantly improve ground conditions inside the mine void, is simply irrelevant, as is the objection on page 12 that backfilling is not necessary to prevent sinkholes.
It states on page 12 of the study that the calculations are based on the plan for the Little Cherry Creek Tailings Impoundment, an Alternative that has already been deemed non-viable by EPA. Therefore, this entire study is not applicable to the current Montanore proposal. In fact, given that it is based on a defunct Alternative, the entire study is rendered irrelevant.
We believe that the backfilling Alternative to the current Poorman Creek Tailings Impoundment plan must be revisited and a new study commissioned based on site-specific data. Actual costs in U.S. dollars, reasonable cost comparisons of backfilling vs. impoundment of all tailings, and a basis in fact using an as-yet undeveloped Poorman impoundment design is the only way that the permitting agencies can definitively evaluate whether backfilling as an environmentally preferable alternative to a toxic tailings edifice.
Because backfilling would reduce the Poorman Impoundment footprint by 33 to 48 percent, it would significantly minimize the wetlands area that Montanore would destroy, and by federal law, backfilling must be given further consideration and study.
Modified Alternative One
By far the best and most environmentally acceptable alternative to the Poorman Creek Tailings Impoundment is transporting the tailings out of the Kootenai National Forest to a processing facility located on private property such as the Libby Industrial Park.
We believe that KNF and DEQ would be remiss in permitting the location of a toxic dumpsite some three stories high on federally protected lands. To permit the Poorman Tailings Impoundment would facilitate the pollution of the area’s natural water resources, destruction of essential wetlands, further decimation of threatened species and severe impairment of the public’s recreational enjoyment of the Libby Creek area.
Ore should be trucked directly from the adit to an offsite milling facility and from there to a contained tailings dump where seepage would not endanger publicly-owned natural resources.
Read about the Cumulative Environmental Effects of Two Massive Mines Operating Simultaneously
