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Protect Our Water Our Future

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.

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Protect Our Water Our Future

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

  2. Update on Environmental Permits POWOF Community Meeting, Nov. 27, 2012 • ADEQ (State) • Amended APP Request (including commercial operations) • Curis did not answer ADEQ’s Sept. 2011 Deficiency Letter • Suspended review at Curis’s request.

  3. Update on Environmental Permits POWOF Community Meeting, Nov. 27, 2012 • ADEQ (State) • Temporary APP • After the Town denied Curis’s 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 http://www.azdeq.gov/environ/water/permits/index.html

  4. Update on Environmental Permits POWOF Community Meeting, Nov. 27, 2012 • USEPA (Federal) • Ongoing review of Curis’s request for a UIC permit.

  5. Ongoing Litigation Against ADEQ POWOF Community Meeting, Nov. 27, 2012 Southwest Value Partners, Pulte, Town of Florence, Johnson Utilities v. ADEQ Arguing ADEQ’s temporary permit regulation is illegal Permit terms are not part of lawsuit Ongoing dispute

  6. What’s Next? POWOF Community Meeting, Nov. 27, 2012 • ADEQ’s 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 23rd. • ADEQ review, response to comments & “final” decision

  7. Overview & Key Points Curis’s Temporary Aquifer Protection Permit POWOF Community Meeting, Nov. 27, 2012

  8. What Does the Temporary Permit Allow Curis to do? POWOF Community Meeting, Nov. 27, 2012 • 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

  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. Key Points to Know About Curis’s Temporary Permit- Overview POWOF Community Meeting, Nov. 27, 2012 • 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

  13. Key Points Cont’d.Curis’s PTF is Not a Pilot POWOF Community Meeting, Nov. 27, 2012 • 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.

  14. Key Points Cont’d.Curis’s PTF is Not a Pilot POWOF Community Meeting, Nov. 27, 2012 • Curis’s PTF will NOT: • Provide new data needed to prove up the safety of commercial operations • Answer ADEQ’s questions posed in its Deficiency Letters

  15. Key Points Cont’d.Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27, 2012 • 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

  16. Key Points Cont’d.Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27, 2012 • 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.

  17. Key Points Cont’d.Lower Basin Fill Unit (LBFU) POWOF Community Meeting, Nov. 27, 2012

  18. Key Points Cont’d.Hydraulic Control POWOF Community Meeting, Nov. 27, 2012 • 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 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 Curis’s position& will require demonstration of hydraulic control as part of PTF operations.

  19. Key Points Cont’d.Inadequate Well Field Setup POWOF Community Meeting, Nov. 27, 2012 • 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 control • Proposed 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.

  20. Key Points Cont’d.Financial Assurance POWOF Community Meeting, Nov. 27, 2012 • 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 Curis’s 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

  21. Key Points Cont’d.Acidic Solution Claims POWOF Community Meeting, Nov. 27, 2012 • 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 more • Based 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

  22. Key Points Cont’d.Water Quality Parameters POWOF Community Meeting, Nov. 27, 2012 • 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

  23. Key Points Cont’d.Water Quality Parameters POWOF Community Meeting, Nov. 27, 2012 • “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

  24. Key Points Cont’d.Inadequate Monitoring POWOF Community Meeting, Nov. 27, 2012 • 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 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

  25. Key Points Cont’d.Inadequate Monitoring POWOF Community Meeting, Nov. 27, 2012 • 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.

  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. Key Points Cont’d.Inadequate Core Hole Precautions POWOF Community Meeting, Nov. 27, 2012 • 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.

  30. Key Points Cont’d.Inadequate Core Hole Precautions POWOF Community Meeting, Nov. 27, 2012 Permit only requires abandonment 500 feet around the injection well field. Proper abandonment around monitor wells & other site features needed.

  31. Key Points Cont’d.Inadequate Core Hole Precautions 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, 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. Key Points Cont’d.Unrealistic Groundwater Clean Up POWOF Community Meeting, Nov. 27, 2012 • 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.

  34. What Can I Do? POWOF Community Meeting, Nov. 27, 2012 • 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.

  35. What Can I Do? POWOF Community Meeting, Nov. 27, 2012 • 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.

  36. What More Can I Do? POWOF Community Meeting, Nov. 27, 2012 • 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 Department • Governor Brewer • USEPA

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