SYNOPSIS

OF U.S. EPA COMMENTS ON POLYMET FINAL EIS

MINING TRUTH

Northward flow of polluted water into the Rainy River watershed
The EPA confirms northward flow of polluted water into the BWCA and
Voyageurs National Park watershed is a possibility and that further impact
assessment is needed Specifically, limited site-specific data is currently available
to assess the potential for a northward flow path, and to design effective
contingency mitigation measures should northward flow occur. The EPA
recommends this data be gathered and studied as the project design is being
further developed. Northward flow would also transfer water out of the Great
Lakes watershed and be subject to approval under the [Great Lakes Compact.]
Lack of baseline data after ten years of study
PolyMet relies heavily on adaptive management that would employ contingency
mitigation measures to mitigate unexpected pollution. This requires accurate
baseline data to understand what the current conditions are. Despite ten years of
study, the EPA notes that baseline data is insufficient, and should be collected and
analyzed before any major grading or excavation of soils or conveyance or pumping
of water is carried out at the site
Need for comprehensive and accurate water modeling
The EPA recommends agencies involve a specialized expert to inform the
permitting agencies review of a comprehensive monitoring and modeling program
at the Mine Site. They also state [a]ny such review should consider the influence of
other nearby mining operations (such as NorthShores [Peter Mitchell Pit]). The
northward flow issue arose late in the process due to failure to include the impact of
nearby mining operations in the water models used in the PolyMet EIS.
Wetland impacts
Uncertainty about the scale and scope of indirect wetlands impacts through changes
in water levels led EPA to comment that monitoring and mitigation should be
further developed during the permitting process... The EPA recommends that
PolyMet establish additional monitoring and plan for additional indirect wetland
loss. The EIS identifies thousands of acres of wetlands that could be lost.
Mineral fibers
The EPA notes that a study currently undergoing peer review examining the cancer
potency of mineral fibers should be incorporated into analysis of the health risks
from PolyMet in order to minimize worker and public health risks related to
mineral fibers.
Continued EPA involvement in review of the proposal
The EPA would like to continue to engage in a close dialogue with the permitting
agencies about the details of modeling, monitoring, and project design (including
contingency mitigation measures), as relevant to project construction and
permitting decisions. In addition, the EPA requests the opportunity to review the
[Army] Corps final permit evaluation and draft [Clean Water Act] Section 404
permit...