The public comment period for the Greens Creek Mine tailings expansion is open and has been extended to May 23, making now the perfect time to get your comment in!
We at SEACC have put together this easy tool to help you draft your comment on the Draft Supplemental Environmental Impact Statement for their proposed tailings expansion process.
The Forest Service is considering four alternatives during this NEPA (National Environmental Policy Act) comment period.
Alternative A is the “No-Action” alternative and would not allow Greens Creek to expand the tailings facility beyond the currently permitted capacity.
Alternative B is the smallest expansion and is the USFS’s proposed alternative. It would provide 12-18 years of additional tailings storage.
Alternatives C and D are larger expansions and would move the B-Road to the west side of the tailings facility, which is downwind during typical fugitive dust generating conditions. Both of these options would substantially raise the height of the tailings. SEACC outright opposes both Alternative C and D.
Here are the top three issues we want to draw your attention to as you prepare your comment:
- Fugitive Dust: For over 30 years, lead and other metals-contaminated mine tailings have been blowing off the Greens Creek Mine tailings pile and onto the Admiralty Island National Monument, the Tongass National Forest, and the marine waters of Hawk Inlet. Tailings are the finely ground waste that remains after the valuable ore is milled and processed. At Greens Creek Mine, the tailings contain lead, zinc, cadmium, and other metals. The fugitive dust problem needs to end, and the Forest Service agrees — they have included a near-zero fugitive dust detection requirement before any further expansion is allowed. The public should strongly support this requirement. In addition, the Forest Service should mandate a fugitive dust ecological risk assessment to ensure we understand the impacts the tailings dust is having on the environment and should require a comprehensive fugitive dust mitigation and monitoring plan prior to any tailings storage expansion. Please consider asking them to do so in your comments!
- Repeat the Baseline Studies: The Alaska National Interest Lands Conservation Act (ANILCA) allows Greens Creek to mine in the Monument as long as it does not cause “irreparable harm” to fish, fish habitat, and the ecological resources of the Monument. But the baseline environmental studies from 1981 have never been repeated to determine whether harm is happening, making the question of “irreparable” harm difficult to evaluate. It is inappropriate for the USFS to approve an expansion at the mine until the baseline studies have been replicated. Moreover, there are several recommendations in the most recent Greens Creek Mine audit document regarding the need for baseline data for elements such as geochemical data about tailings and additional parameters in the Fresh Water Monitoring Program (Greens Creek Mine Audit, 2018, pages 8 & 13).
- End the Mixing Zone: A mixing zone is an area where industrial effluent is allowed to be discharged that does not meet Alaska water quality standards, creating zones of acute and chronic toxicity — poisoning the water in that specific zone. Greens Creek mine waste is currently being discharged in a mixing zone inside Hawk Inlet, an important subsistence wildlife area. The Environmental Protection Agency allows in-pipe mixing as a supplement to ensure adequate water treatment. Augmenting the flow with seawater would result in the effluent meeting water quality standards in the pipe, and allow for elimination of the mixing zone in open water.
SEACC’s position is that Alternative B is the most appropriate expansion alternative, but only if these three key concerns are addressed.
Check out this link to access our easy comment tool to draft your own comment on this draft environmental impact statement — the comment tool makes it easy to submit your letter and to customize it to add your own voice!
What should you add to personalize your comment? Consider sharing about how you access Hawk Inlet and/or Admiralty Island National Monument, and how you think the above concerns might impact you, or our community.
Want more information? Reach out! You can reach us at info@seacc.org with questions.
