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.
[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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