Saturday, August 25, 2012

Letter to Paul Baker, Division of Oil, Gas and Mining


August 22, 2012

Paul Baker
Minerals Program Manager
Utah Division of Oil, Gas and Mining
P.O. Box 145801
Salt Lake City, Utah  84114-5801

Dear Mr. Baker:

As per our phone conversation on August 17, 2012, I am writing you to request a hearing with you and the Associate Director, Dana Dean, to discuss our concerns about the exploratory permit granted to Agrium Phosphate Company.  It is my understanding that Agrium/Utah Phosphate Company has sent a bond in the amount of $147,377.50 for mitigation.

The Uintah Water Source Protection Coalition does not in any way support the possibility of phosphate mining on SITLA land near Ashley Springs.  We are appealing the exploration permit being granted to the Utah Phosphate Company.


“Ashley Springs, a natural flowing stream, is the primary source of water for the Ashley Valley Water Treatment Plant.  When flows decrease, water from Red Fleet Reservoir is pumped to the plant.  Approximately 80 percent of the water comes from Ashley Springs and 20 percent from Red Fleet.  The plant supplies water to over 9,000 people, primarily in Vernal City.”

(http://www.cuwcd.com/drinkingwater/ashley.htm and discussion with treatment plant manager, Brad Grammer, March 30, 2012)


Ashley Springs is the only source of water for the Ashley Valley Water and Sewer Improvement District Water Treatment plant.  Over 8,000 people, primarily outside Vernal City, are supplied water from this plant.  (Discussion with Dave Hatch of the improvement district, March 30, 2012)


Utah Phosphate Company owns three mining leases from SITLA. 


East Side
Recharge for the east side of Ashley Springs is from surface water flows originating east and north of the discharge point.  The Park City phosphate formation is on the surface while the Weber Sandstone formation lies beneath it.[i]  Both formations slope south at from 10 to 20 degrees below the horizontal.[ii]  These slopes indicate the recharge areas described above.  This is exactly the area 68 percent of the mine will excavate.

            West Side
Colored dye tests done in 1971 determined, “The main Dry Fork Sinks are the major source of the flow of Ashley Springs.  The tests gave no evidence that the water entering the Dry Fork Sinks has any other place of discharge…”[iii]  It took only three days for the dye to appear.[iv]  In addition, fine-grained sediments are known to flow out of the spring during high water flows in the spring of the year.

The exact path the water takes from Dry Fork Sinks to Ashley Springs is unknown.  Some have suggested there are solution cavities dissolved by the water.  Whatever formation or formations the water travels through, it’s clear the velocity of flow is sufficient to keep sediment suspended during the approximately 10.5 mile trip.  It’s clear from the red arrowed line on the attached map that the underground flows pass


[i] Geology of the Uinta River-Brush Creek Area Duchesne and Uintah Counties, Utah, Geological Survey Bulletin 1007, 1955, pages 45 to 55.  Also, Correlation Chart of Detailed Stratigraphic Sections, From Whiterocks River to Green River, Uintah County, Utah.
[ii] Ibid. Geologic Map and Structure Sections of the Uinta River-Brush Creek Area, Duchesne and Uintah Counties, Utah.  See Section 12 near the label, “Ashley Creek Anticlinal Nose.”
[iii] Hydrogeology of the Eastern Portion of the South Slopes of the Uinta Mountains, Utah, Utah Department of Natural Resources, 1971, page 46.
[iv] Ibid. Figure 12, Dye Concentrations versus Time – Dry Fork Sinks Test.

Mining and mineral processing facilities generate more toxic and hazardous waste than any other industrial sector.  The waste can impact surrounding communities and pose a serious risk to public health and the environment. To reduce these risks, EPA is working to ensure the mining and mineral processing industry are in compliance with environmental laws.

Environmental Protection Agency
Drinking Water Contaminated at Phosphate Mine[iv]

Type of Impact/Media Affected: The metals detected in the ground water corresponded to those elements (arsenic, cadmium, and zinc) detected at high concentrations in the unlined waste ponds. Contaminants had been detected in a nearby spring, used for drinking water at a local cafe, which was consequently condemned, and the river, which is used for recreation and irrigation.

HUMAN HEALTH AND ENVIRONMENTAL DAMAGES FROM MINING AND MINERAL PROCESSING WASTES, Office of Solid Waste, U.S. Environmental Protection Agency, December 1995, page 84.

Mine Operations Make Ground Water Contamination Likely

As discussed above, blasting will fracture and break up the rock directly beneath the ore which is removed.  Instead of being solid, the rock will be broken into tiny pieces.  This will increase the surface area of the rock by millions of times.  This greatly facilitates the water percolating through the mass and dissolving minerals.  As discussed previously, many existing pathways to the springs will be disrupted; however some water will still reach the spring. Phosphate rock contains arsenic, selenium, radioactive minerals and other harmful materials.  This situation makes it very likely these contaminants will show up in Ashley Springs and perhaps other wells in Dry Fork Canyon which may be hydrologically connected to the formations beneath the mine.

Utah Phosphate Company may sincerely believe and vigorously indicate they will provide the necessary mitigation to prevent occurrences such as those described above.  However, it’s clear from the long history of phosphate mining that the large size of the mines, coupled with the nature of the mining and ore processing, simply makes that impossible.

The effects of exploratory activities, including seismic testing, are unknown.  Solid rock transmits blast energy very well and could affect the flow path providing most of the water to Ashley Springs.  There is substantial risk that blasting energy traveling downward will break up and dislodge rocks above and within the underground flow path.  This will likely compact and obstruct the path resulting in reduced water flows discharging from Ashley Springs. 

No amount of bond money can repair damage to the system.  These impacts would be permanent. 

Ultimately phosphate mining in this area is risky and could permanently reduce the amount of water supplied to Ashley Springs, contaminate the water with toxic metals and radioactive materials and endanger the water supply of over 17,000 people living in Vernal City and Uintah County.

We, the undersigned, request the Division of Oil, Gas and Mining to reconsider the advisability of mining in this area.  We oppose exploratory drilling.  If an exploratory permit is issued, then the Uintah County Water Source Protection Coalition will continue to oppose phosphate mining on the SITLA land surrounding Ashley Springs. 

Again, we request a hearing with Dana Dean and you to discuss the ongoing mining issues surrounding Ashley Springs and its watersheds.

Thank you for your consideration in this matter.

Sincerely,



Loran Hills
Member, Uintah County Water Source Protection Coalition





                                   






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