2006 study of Water Quality at modern hardrock mines
The IMM project application clearly states that the mine will comply with all regulations pertinent to water discharge into Wolf Creek from dewatering and that the mine will store any tailings on site in such a way as to prevent any leaching from the tailings into the creek. All mines within the US are required to certify that they comply with the Clean Water Act and all other applicable local and state environmental requirements.
However, in actual fact, based on a 2006 study conducted by Ann Maest, PhD and Jim Kuipers, PE, an overwhelming majority of mines fail to comply. The studies are entitled: “Comparison of Predicted and Actual Water Quality at Hardrock Mines: The reliability of predictions in Environmental Impact Statements” and “Predicting Water Quality at Hardrock Mines: Methods and Models, Uncertainties, and State-of-the-Art.”
Below we present the highlights from these disturbing but extremely important and scientific studies. A white paper, entitled “Predicting Water Quality Problems at Hardrock Mines, A Failure of Science, Oversight, and Good Practice” by Alan Septoff, Dec. 2006 which can be found in its entirety here is the basis for the information presented below.
A failure of science, oversight and good practice
This paper is a summary, written for the layperson, of the findings of a two-year research study on the accuracy of water quality predictions at hardrock mines. The study, conducted by Jim Kuipers and Ann Maest , brings to light a decades-long failure by government regulators, industry, and consultants to recognize and correct deficient procedures and methods for predicting contamination of water at hardrock mines. Kuipers and Maest have discovered that, in practice, there is a failure to compare predictions made before the mines are permitted with the actual results. The predictive modeling results are not adjusted to account for real-life failures - this, despite the fact that at the vast majority of mines, problems were worse than predicted. Establishment of credibility in modeling requires that the predictions be tested, and then the models adjusted based on the results. This process appears broken when it comes to predicting the impact of mines on water quality for mine permits.
Do predicted water quality impacts match reality?
The answer, in short, is no. The Comparison Report reveals:
Potential & Predicted Water Quality
The authors discovered a two-tiered system for water quality predictions, one-tier of which was based not on sound science, but on unsupported “good faith” projections.
The two tiers of “predictions” made about water quality in environmental assessments are referred to by the authors as “potential” and “predicted” water quality:
All the environmental reviews analyzed in the Comparison Report predict acceptable water quality after mitigation at mines where water quality standards were met before mining began. If this prediction were not made, the regulatory agency would not be able to approve the mine.
However, inadequate information was provided to demonstrate how the mitigation measures would actually prevent water quality impacts. Therefore, regulators were generally accepting the final water quality predictions on “faith.”
Prediction vs. Reality: Overall Water Quality Impacts to Ground and Surface Water
Of the 25 mines sampled:
Predictions vs. Reality: the Failure of Mitigation
In the cases where water quality standards were exceeded, in some cases the mine proponent anticipated the potential for pollution and prepared mitigation strategies (e.g. a mine waste dump lined with plastic to prevent acid drainage leaching into groundwater). Predictions of the efficacy of mitigation were no more reliable than overall predictions of water quality:
Predictions vs. Reality: Mines near Water with Elevated Acid Drainage or Contaminant Leaching Potential are High Risk
Some mine projects are so high risk that water quality exceedances are a near certainty: those mines that are both near groundwater or surface water resources, and possess an elevated potential for acid drainage or contaminant leaching.
Water Quality Pollutants
Of the 76% of mines that exceeded water quality standards, the pollutants that exceeded standards were as follows