Buckhorn Bulletin
November 2004 Vol. 2 No. 3

Draft Supplemental EIS Delayed Until May
The overly ambitious schedule for the release of the draft SEIS has fallen victim to the same kind of delay for which this ill-fated mine proposal is noted. Washington State Department of Ecology and the USDA Forest Service have chosen to take a more conservative approach and recognize the 2000 ruling of the Pollution Control Hearings Board that derailed the open pit proposal. They predict that the draft SEIS will be out in May; given the amount of work and additional testing that needs to be done to understand the impacts of the current proposal, this is very optimistic. Additional tests and work include: hydrograph separation, recharge, permeability, water budget, groundwater modeling, and humidity cell tests.
Toronto-based Kinross Gold Corporation purchased Crown Resources and the rights to the Buckhorn deposit, last January but issues at the Securities and Exchange Commission have delayed final approval. Kinross had previously purchased Echo Bay Minerals near Republic, WA.
Crown’s current plan would transport the ore down Marias Creek Road to the Echo Bay Mill near Republic, via Toroda Creek Road and the Kettle River Road. The company has stated that at least one large ore truck would pass every 7 minutes, with more before and after spring thaw for the 7.5 year life of the mine.

Mountain of Documents
Documents are beginning to pile up as the agencies prepare for the draft and eventual final Supplemental Environmental Impact Statement (SEIS). Already in 2004 at least 40 new documents have been submitted to the agencies by Crown/Kinross or consultants, compared to four in 2003. This is in addition to the 140+ documents being reviewed from the now defunct Crown Jewel Proposal created between 1992 and 2001. Topics include: air quality and climate, aquatic biology, hydrology and hydrogeology, geotechnical/geochem, heritage resources, mining and underground stability, reclamation, recreation and socio-economics, terrestrial biology, transportation and access, vegetation, wetlands, and the Crown Jewel Mine Plan of Operations. Some of these documents are available at www.buckhornseis.net. The agencies have told OHA that more will be available soon.

Troubled Water Tailings Expansion
TAILINGS IMPOUNDMENT
Echo Bay’s Key Mill near Republic is currently Kinross’ tailings impoundment. It covers 94 acres and has a capacity of 8.5 million tons. It is almost full. There is space left for about 1.5 million tons of cyanide leach tailings. The processing of gold ore from Buckhorn Mountain would produce about 4.5 million tons.
The last tailings dam expansion added 12 feet to the 175-foot-high dam perched above the North Fork of the San Poil River, and was done in 2001. This is in addition to the 25 foot expansion in 1995. Both utilized the structurally inferior upstream type expansion where the dam is partially built on semi-dry tailings with 45% moisture content. The current proposal looks at adding almost another 30 feet of height to the dam.
The “Engineering and Environmental Aspect Analysis Assessment of Alternatives for Additional Tailings Storage” for Kinross’ Kettle River Tailing Impoundment analyzes four options:
• Alt. 1 - A single upstream lift to the existing tailingsfacility.
• Alt. 2 - Multiple, smaller upstream lifts to the existing tailings facility.
• Alt 3 - A new tailings impoundment on Kinross land south of the North Fork of the San Poil River
• Alt 4 - A smaller upstream lift of the existing tailings facility and a new impoundment south of the river.

CYANIDE LEACH PROCESS
Kinross uses a vat-leach cyanide process to extract microscopic gold from ore at the Key Mill. This involves crushing and grinding millions of tons of ore per year to the consistency of talcum powder, then mixing it with a diluted cyanide solution in large vats where the gold separates from the ore. The waste from this process is called “tailings”. The tailings are spread in thin layers on an engineered liner for permanent storage. In the past Key Mill has processed approximately 500,000 tons of ore each year.

Groundwater Problems - Out of sight but not out of mind
Water quality monitoring wells for Kinross’ Key Mill and tailings pond show an increasing trend for nitrates, total dissolved solids (TDS), magnesium, calcium, alkalinity, and sulfate concentrations. The well located closest to the mill has regularly exceeded ground water quality criteria for TDS, and periodically exceeded standards for nitrates.
Some of Kinross’ other mines, including K2 and Key Project, do not meet groundwater standards and have negative trends. The Department of Ecology has given Kinross “interim” standards for the next 4 years. Within a year Kinross will have to submit a hydrogeologic engineering report updating and evaluating “All Known Available and Reasonable methods of prevention, control and Treatment” (AKART) to Ecology for sources contributing pollutants that degrade ground water quality. They will have two years to implement the AKART measures and remediation alternatives, and then another year to evaluate the results.

BEGGING FOR TROUBLE
The engineering report for the tailings prepared for Kinross by AMEC Earth & Environmental Inc. of Sparks, NV raises many questions.
AMEC goes to great length to explain why the USGS seismic hazard map for ground motion (which is the basis for the International Building Code 2000) was not used for calculating the seismic risk of the proposed dam. They say it is overly conservative and that a lesser value should be used to determine the characteristics and distribution of seismic sources. The report makes the argument to use a lesser value, presumably, because the upstream expansion they proposed would be more expensive, or would not meet the more conservative standard.
Of the various tailing dam expansion techniques, the proposed upstream method is the most vulnerable to failure. This would be the second upstream lift placed on top of the original tailings dam. The first upsteam lift is 12 feet high. The second lift would be an additional 29 feet high. The foundations of both of these upstream lifts would be built on the tailings themselves. These upstream extensions built on top of the original dam are the most vulnerable to seismic failure. The toe of the original 187-foot-tall tailings dam, which is of conventional construction, is currently 400 feet from the North fork of the San Poil River and approximately 10 miles upstream from the town of Republic.
The AMEC report uses four exploratory test holes to categorize the geotechnical stability of the tailings on which the upstream dam embankments would be built. This is an inadequate basis to draw its conclusions on. Uncertainties might arise by using a small number of samples to characterize the long-term stability of the tailings on which the dam would be constructed. The upstream dam would also require meticulously managed construction in order for the dam to perform as designed. If there is a mistake in data interpretation of the test hole samples, or in construction monitoring, the chances of dam failure increase.
The report recommends a single lift rather than multiple smaller lifts, even though smaller lifts would allow the weight of the dam to settle into the existing tailings and be more stable. Upstream dam construction is not recommended by any regulatory agency, and is seldom proposed today because of the inherent risks in this type of construction. Upstream dam construction is a bad practice held over from the early days of mining. It only remains as an option today because it is the cheapest way extend the height of a tailings dam.

Kinross Transportation Issues
Noise, light, and air pollution can disturb local residents and wildlife, thereby constraining recreational opportunities. The noise and dust from 30+ ton trucks making 50 round-trips each day up and down Marias Creek Road, would resonate through the Toroda Creek area for over 12 hours per day. Road dust would obscure views and impact public health. This would detract from the quality of life, and compromise the health and well-being of residents.
The increased traffic on rural roads in the Okanogan Highlands from transporting ore long distances on roads would not only affect local residents, but recreation and tourism. This could become a real detriment to current and future economic development plans. Transporting hazardous material through the narrow, twisty, often icy roads poses risks to fish, wildlife, local residents, and recreationists.
Kinross held two public meetings in 2004 to talk about their transportation plans. People living along the Kettle River who supported the mine in the past and tried to work with the company told heart wrenching stories of being woke up by noisy trucks and jake brakes at 4:30am, even though the hauling is suppose to be between 6am to 6pm. People made various requests, such as no trucking on weekends and covering loaded trucks. The company said it would consider these requests.

Appeal of Teck Cominco’s Pend Oreille Mine
OHA, along with WashPIRG and The Lands Council, appealed the National Pollutant Discharge Elimination System Waste Discharge Permit (NPDES) for the Pend Oreille Mine issued by Washington State Department of Ecology. Teck had been operating under a permit issued in 1977 for dewatering the mine shafts, allowing a maximum mixing zone. (A “mixing zone” is the area where pollutants can be diluted into a river to achieve water quality standards.) The waste discharge permit would have expired in 1981 but has been administratively extended ever since then.
At issue in the appeal is that Ecology is allowing both chronic and acute discharge from the mine to be diluted by the Pend Oreille River. Ecology failed to make the company complete the prerequisites necessary to permit a mixing zone. Under WA State law “A discharger shall be required to fully apply All Known, Available, and Reasonable methods of prevention, control, and Treatment (AKART) prior to being authorized a mixing zone.” Washington State Antidegradation Law also require that “All wastes and other materials and substances discharged into said waters shall be provided with AKART before discharge.”
This means that if reasonable technologies exist to prevent, or at least reduce, the use of a mixing zone to meet water quality standards they should be employed. The last AKART was conducted in 1993. It failed to fully analyze treatment alternatives or look at new technologies. Mining technologies have grown by leaps and bounds since then; consequently a new AKART must be conducted. Ecology should, but has not, required that a new AKART be completed.
The State of Washington officially listed the Pend Oreille River in April of 2000 as water quality impaired. This means that both until and after a Total Maximum Daily Load (TMDL) has been implemented, the Pend Oreille River will have specific restrictions on what may be discharged into it. Without a TMDL, human actions are not allowed to further lower the water quality.
The NPDES permit fact sheet states that in summer months mixing may cause an increase in temperature and pH. The bull trout, a species residing in the Pend Oreille River, has been listed as endangered by the Endangered Species Act. The US Fish and Wildlife Service is in the process of designating critical habitat for the bull trout, and the Pend Oreille River will undoubtedly be a crucial component. Allowing a mixing zone in the river will harm bull trout.