2008 Annual Monitoring Report Summary

While underground mining reduces the impacts when compared to the previously proposed open pit, significant water quality and quantity issues remain.

In April 2009, the first annual meeting took place to review the Water Year 2008 monitoring reports. The purpose of the meeting was to provide input towards the discussion of the adequacy of the monitoring plans, to monitor the hydrologic aspects of the Buckhorn Mine and mitigation, and to suggest modifications that might be needed for adaptive management. The annual reporting requirements are extensive. 

After brief introductions including representatives from Washington State Department of Ecology, and Washington State Fish & Wildlife, the USDA Forest Service, Crown/Kinross, Golder Associates and OHA, OHA started the meeting off with an overview of our issues and concerns and a presentation by our consultant Ann Maest of Stratus Consulting.

OHA expressed grave concern over the failure of Crown/Kinross to submit reports required by the Hydrologic Monitoring Plan that are needed to understand the impacts of the mine. Crown/Kinross consultant, Golder submitted nine technical memos to the agencies that related to the Adaptive Management Plan. The memos were not integrated and were poorly organized. There was no table of contents or index and it was difficult to discern if requirements were met. We expressed our concern and frustration that there was not enough time to accomplish the objectives of the annual coordination meeting in the four hours allotted to it. Many of the agencies in attendance also expressed concern regarding the completeness and organization of the memos that were presented. Because of the incompleteness and poor organization of last year’s reporting and lack of time, we never actually got to the point during the annual meeting of discussing the adequacy of the plans or if modifications may be needed.

Since that time OHA has done an extensive review of the plans to develop a comprehensive matrix of annual reporting requirements and their degree of completion for 2008. After reviewing the memos and reports, in cooperation with Kinross, OHA finds the 2008 annual reporting incomplete and lacking basic foundational data needed to analyze the mine’s impacts or the accuracy of model predictions. OHA's analysis shows that the reporting does not meet the requirements of the plans.

Some Highlights from OHA’s Independent Review

Annual Reporting Requirements

Hydrologic Monitoring Plan (HMP)  - No annual reports received
Adaptive Management Plan (AMP) - Memos not integrated; hard to discern if requirements are met
                                                      - Memos are not reports
Ecological and Aquatic Resources Management Plan-Annual reporting incomplete.

Baseline: Conditions that existed before construction and mining

• Baseline water quality values are different for Kinross and Ecology
• Some baseline values are higher than current concentrations
• Baseline should be reevaluated so changes from baseline water quality conditions are apparent

Analytical Issues:

Detection limits
    - Some numeric values not in database
    - Some metals detection limits are too high compared to baseline/standard
    - Required detection limits are not noted in permit

Dissolved vs total measurements

Missing Analysis

• On site precipitation data
• Continuous flow inflow/effluent data
• Surface water monitoring points
• SW-15: flow and water quality
• According to HMP, flow should be measured, but no frequency was set. Data are available from Kinross but not in monthly monitoring database.
• Groundwater - Depth to water at Infiltration Gallery should be reported as depth below ground surface (permit condition) rather than below casing.

OHA presented a series of graphs and maps showing:
location of increasing levels from baseline of nitrate, sulfate, ammonia, and chloride

Mine Inflow Water Quality: Measured vs. Predicted
Southwest Zone: higher than predicted Sulfate, aluminum, arsenic, fluoride, lead, manganese, nitrate, and zinc; Makes treatment more difficult than expected

Flow Evaluations

Myers Creek augmentation study
Adaptive management
    - Measured vs. predicted flows
    - Locations recommended for additional flow

Myers Creek Augmentation Study

• The objective of the work was to see if augmentation of the stream with Lost Creek well water would increase flow at the international border (SW-15).
• Flow at SW-15 was not monitored during the test.
• The augmentation study occurred just after a major storm, making results difficult to interpret.
• Study should be repeated under better weather conditions, and flow should be measured at SW-15.

OHA’s Review Identifies Shortcomings

OHA’s analysis after almost one year of operations was hindered by incomplete annual monitoring and reporting of data. The monthly monitoring of surface and ground water around the mine shows that specific constituents continue to rise above baseline although they remain below standards. We consider the lack of annual monitoring reports specific to each requirement of the Hydrologic Monitoring Plan a potential permit violation. OHA acknowledges that some of the required information may be included in the Adaptive Management Plan memos but, we do not believe this meets the permit requirements. Kinross has expressed a commitment to get it right.

Possible Violations

• No on-site meteorological data as required
• No reporting of flow data for SW-15 (Myers Creek at international border)
• Outfall 002 is discharging from pipe to rubble, not to stormwater pond as required
• Inflow/effluent - continuous flow data required but not reported

Other Issues

• Failure to complete conservation easements for mitigation properties
• Failure to submit annual reports in a timely fashion
• Failure to make a good faith effort to administer monitoring plan

     - Many surface water points monitored only from June-Sept

     - Some required data in AMP reports; no HMP reports

• Water use data statistics and photos missing
• Stream flow data missing
• Evaluation of predictions in groundwater flow model not adequate
• Reporting of additional monitoring (NPDES S3.D)
• Water level or flow are required by the HMP and implementation of HMP is required as a conditions of the NPDES – then flow should be required as part of the NPDES permit

Measured vs. Predicted Flow Issues

• Measured low flows (fall/winter) are often substantially lower than modeled baseflows
• FEFLOW model does not adequately simulate pre-mining conditions
• Need precipitation data from the mine and historic stream flows as input to model

Recommendations

• Fix weather station at Buckhorn Mountain
• Re-evaluate modeled baseflow with data from Buckhorn Mountain weather station and historic data
• Monitor and report flow at SW-4, SW-12, SW-13, SW-15
• Re-do Myers Creek augmentation evaluation with monitoring point at SW-15
• Re-evaluate baseline water quality for surface water and groundwater
• Analytical issues
• Detection limits
• Dissolved and total metals for surface water
• Continue to improve treatment to better remove sulfate, nitrate/ammonia, chloride; consider using less explosive
• DMRs and composite database should include flow monitoring and OHA settlement monitoring
• “Frozen” monitoring points should be photo-documented
• Provide water use data
• Need integrated annual reporting
• Mine site (groundwater, surface water, influent/effluent, dewatering wells)
• “Mitigations” (compensation projects)
• The next annual meeting should be a full day long and reporting submitted when due.

Locations for Additional Flow – Adaptive Management

• Monitor and report flow at SW-4 (Lower Gold Creek), SW-12 (Lower North Bolster Creek), or SW-13 (Lower South Bolster Creek) – not currently required
• Flow monitoring is required at upstream locations on Gold Creek (SW-10), North Bolster Creek (SW-11), and South Bolster Creek (SW-14)
• Depletions are predicted for SW-4, SW-12, and SW-13
• Monitoring at downstream locations provides better picture of dewatering effects
• Monitor and report flow at SW-15 (Myers Cr at International Border)