Center for Biological Diversity • Information Network for Responsible Mining Sheep Mountain Alliance • Uranium Watch
Dec. 17, 2012 Mr. Rob Ernst Uncompahgre Field Office 2465 South Townsend Avenue Montrose, CO 81403 Via email to: email@example.com Re: Prince Albert Mine EA Scoping Comments
Dear Mr. Ernst, Thank you for the opportunity to provide comments on the Prince Albert Mine Environmental Analysis during the public scoping period. Our organizations share a concern for the environment of the region and the regulation of uranium mines, including the Prince Albert and mines throughout the Uravan Mineral District. The Information Network for Responsible Mining is a Colorado-based citizens organization that advocates for the protection of communities and the environment and actively participates in mining reviews. Uranium Watch is a not-for-profit organization that works to educate and advocate for protection of public health and the environment from past, current and future impacts of uranium mining and milling in the Four Corners area. Sheep Mountain Alliance is a grassroots-based citizens organization dedicated to the preservation of the natural environment in the Telluride Region and Southwestern Colorado. The Center for Biological Diversity is a national, nonprofit conservation organization with more than 450,000 members and online activists dedicated to the protection of endangered species and wild places. Our organizations appreciate your consideration of the following comments and concerns related to the proposed action and Environmental Analysis. The Prince Albert Mine is of special interest and concern because of its location high on Club Mesa above the confluence of the San Miguel and Dolores rivers. This region is important to recreational users and conservationists and provides habitat for wildlife and aquatic species in the rivers, two vital and interdependent waterways that sustain the ecological and economic health of the surrounding communities. Any proposed actions at the Prince Albert Mine should be considered and understood for their connections to other proposed actions in the region, adjacent and nearby uranium mining activities, and the overall conservation- and recreationbased values of the area. All potential impacts from the mine’s expansion and operations should be analyzed, including:
Waste Rock Disposal: The proposed action includes expanding the existing waste rock pile and building an additional, secondary waste rock pile to accommodate future excavations as the mine develops. The Bureau of Land Management should develop an alternative in the Environmental Analysis that eliminates the expansion of the existing waste pile, eliminates the secondary waste pile and eliminates the permanent, above-ground disposal of waste rock. This alternative should consider how the progressive gobbing of waste rock back into the underground workings of the mine could occur and reduce the longterm surface impacts at the site. The potential for disposing of all or a significant portion of the waste rock underground should be throughly analyzed. Because the Prince Albert Mine is located in an attractive and interesting part of Club Mesa and is accessible by a fairly short side road off the main route, the general vicinity of the mine already attracts visitors and holds potential for recreational use in the future once the mine is fully reclaimed. Reduction of the final size of the permanent waste piles on site could help protect these features and reduce visual impacts. In addition, because the Prince Albert is considered a dry mine, BLM should analyze whether the gobbing of waste rock in the workings will provide additional protections for water quality and the site itself. Ore Storage: According to the results of chemical analysis submitted to the Colorado Division of Reclamation, Mining and Safety, the ore at Prince Albert has relatively high potential to produce toxic or acid forming leachate from the ore pile. The primary constituents of concern are antimony, arsenic, mercury, selenium and uranium, all of which could pose water quality concerns for any drainage from the site into the San Miguel River, should the proper functioning or maintenance of permanent stormwater management features decline over time, as is frequently the case with uranium mines that place operations on standby for lengthy periods or following final closure and release. The Plan of Operations quite optimistically states that the stormwater management features at the site are designed to be “zero discharge.” Considering that selenium, in particular, poses serious risk to aquatic life, BLM should analyze whether the environmental impacts of any stormwater discharges into the river could be reduced by using synthetic liners in the main sediment basin for the ore pile as well as the three secondary catch basins. The rivers below these basins provide important habitat and restoration potential for the sensitive fish species of bluehead sucker, flannelmouth sucker and roundtail chub. The ore pad itself relies on a natural geologic barrier to contain any migration of radionuclide or toxic materials, however, BLM should analyze whether the possibility of such contamination could be reduced by using a synthetic liner in the ore pad during mine operations. The Plan of Operations also does not address the length of time that ore may be stored at the site. Because the Plan does not include an interim management plan for any period of extended shutdown, it is likely that ore will be produced at the Prince Albert and remain on site for lengthy periods because years of idleness and brief production runs, if any, are the normal course of operations for the region’s uranium mines. Although the Plan does say that all hazardous materials will be removed from the mine site during extended periods of downtime, it doesn’t limit the length of those periods nor does it identify ore as one of these hazardous substances. BLM should consider placing operational limits on the amount of time that ore can be stored openly at the Prince
Albert, limiting that period to 30 days before ore must be removed and transported offsite for processing. Wildlife: In addition to the fish species of concern in the San Miguel and Dolores rivers, the Prince Albert Mine provides both winter range and severe winter range for mule deer and elk. In the area, nesting raptors are present, along with river otter, desert bighorn, and a dozen species of bats, including the Thompson Big Eared Bat, a BLM sensitive species that often roosts or hibernates in abandoned mine tunnels. The mine is next to the upper rim of the San MiguelDolores canyon, and that poses an additional need for analysis because of the nearby presence of roosting peregrine falcons and other raptor species that nest on the cliff walls and are negatively impacted by human and industrial activities in close proximity. BLM should consider an alternative in the EA that considers restricting operating hours in order to mitigate impacts to sensitive species such as peregrine falcon. BLM should also develop an alternative that prohibits operations during the winter months and limits the hours when hauling can occur. Cultural Resources: BLM should analyze carefully the potential impacts to cultural and paleontological resources at the site. There are numerous historic and cultural resources present on other parts of Club Mesa, which makes their presence at the Prince Albert more likely as well. Although the survey already conducted did not identify specific cultural or historic resources in the permitted area, it is possible that mining activities could produce contact with artifacts or sites. In addition, the geology of the Prince Albert site makes the discovery of dinosaur or other vertebrate fossils another likely occurrence with increased mining and exploration activities. Mitigation plans and protocol for how cultural, archeological or paleontological resources will be handled if located during mining should be incorporated into the Plan of Operations. Transportation: The Plan of Operations anticipates that ore produced at the Prince Albert will be hauled to the mill near Blanding, Utah, or potentially, to the Piñon Ridge Mill in Paradox Valley if it is ever to be constructed. The EA should include an analysis of the transportation impacts of hauling from the Prince Albert as all the roads on Club Mesa are in substandard condition and make for dangerous driving in winter conditions, and multiple routes are possible. Energy Fuels Resources, which owns the mill in Blanding, has recently announced that it is limiting uranium processing at the mill because of a downturn in economic conditions and is not taking additional orders. BLM should analyze and consider where, in fact, the Prince Albert ore may be destined, considering the lack of opportunity to process it regionally. Roads: The proposed action would authorize the construction of another mile of roads in the Prince Albert permitted area in order to develop new ventholes for the mine and to conduct development drilling for mine expansion. This is a significant amount of new road construction. BLM should develop an alternative in the proposal that eliminates the need for additional road development or dramatically limits it. Additional roads on Club Mesa will only exacerbate the habitat fragmentation that is already apparent in the area.
Radon Emissions: The Prince Albert is currently exempt from the Subpart B NESHAPS permitting requirements. However, this exempt status is likely to change as the federal regulation is outdated and must be updated through a federal rulemaking process. Because there is currently no Subpart B permit for the Prince Albert, it will be allowed to produce uncontrolled radon emissions during mine operations as well as during periods of idleness. BLM should carefully consider in the analysis what impacts uncontrolled radon emissions from the Prince Albert will have in the region and when taken into consideration with the emissions of other uranium mines and milling facilities. The Prince Albert’s location near the top of Club Mesa makes it especially crucial to understand the impacts of radon releases because of the complex meteorological conditions caused by its relatively high elevation and adjacent deep canyon formations. Cumulative Impacts: BLM must carefully consider the cumulative and interdependent nature of mining and milling operations in the region and how expanded mining operations at the Prince Albert effects the state of the environment and cumulative impacts. Impacts to our regional air quality, rivers and streams, soil and watershed health, wildlife, human communities and the human environment, transportation networks, agriculture, natural and cultural resources, recreation, and wildlife must all be throughly understood in context of the regional uraniumrelated activities that are occurring. The analysis should consider the threshold of activity and how specific projects change and impact that threshold. The region’s carrying capacity for uranium development, for example, the amount of radium-related contamination that water supplies can adequately bear, should be carefully considered. Connected Actions: The Prince Albert Mine is located adjacent to two Department of Energy uranium leasing tracts on Club Mesa that are subject to future exploration and mining development. These lease tract areas are analyzed in a forthcoming Programmatic Environmental Impact Statement to which BLM is a cooperating agency. The PEIS is expected to include a detailed analysis of the cumulative impacts of uranium mining and milling throughout the Uravan Mineral District in order to provide a better regional understanding and will provide sitespecific information about the tracts that neighbor the Prince Albert. The BLM should consider the information available in the forthcoming DOE PEIS and how it relates to the Prince Albert Environmental Analysis study and alternatives. Timeliness, Purpose and Need: The expansion of the Prince Albert appears to be somewhat of a Potemkin Village proposal, where the required NEPA analysis and approval documents will be secured far in advance of any actual mining. Although the mine is ready to be developed, there is no viable market for its ore and a mill to receive it does not appear to be guaranteed in the present or over time. Without processing, and without a market to support processing, then any permit granted as a result of this Environmental Analysis will literally sit on a shelf for an undetermined amount of time into the future and will rapidly become outdated. BLM should seriously consider the unlikelihood of mining activities resuming and expanding at the Prince Albert and the overall purpose and need for an expansion that will exist primarily on paper, for speculative economic purposes. If and when the viability of the uranium market
returns to the region, then the impacts and operations of the Prince Albert should be analyzed at that time and under contemporary mining regulations. This is especially important in an industry that will see significant regulatory changes and developments at the federal level in the next several years. The lack of current activity at the Prince Albert should form the contextual bedrock of a no-action alternative in the EA and it should be carefully considered in the review. Thank you again for your consideration of these comments. Sincerely,
Jennifer Thurston Executive Director Information Network for Responsible Mining P.O. Box 746 Telluride, CO, 81435 (212) 473-7717 firstname.lastname@example.org Sarah M. Fields Program Director Uranium Watch P.O. Box 344 Moab, UT 84532 (435) 259-9450 email@example.com Hilary White Executive Director Sheep Mountain Alliance P.O. Box 389 Telluride, CO 81435 (970) 728-3729 firstname.lastname@example.org Taylor McKinnon Public Lands Campaigns Director Center for Biological Diversity P.O. Box 1178 Flagstaff, AZ 86002 (928) 310-6713 email@example.com