Aerial View of Robinson Mine, Winter 2009

Photograph Attribution: Uncle Kick-Kick - Robinson Mine (in the winter). Uploaded by PDTillman, CC BY-SA 2.0, https://commons.wikimedia.org/w/index.php?curid=19196949

Introduction

The Robinson Mine is an open-pit copper mine in White Pine County, Nevada near the city of Ely. Mining in the area began in the 1860s and has changed hands several times since 1985. The mine is currently operated by KGHM Polska Miedź S.A. (KGHM Robinson) under its subsidiary, the Robinson Nevada Mining Company. While the majority of mining operations occur on lands owned by KGHM Robinson, some occur on or adjacent to land managed by the Bureau of Land Management (BLM). In accordance with the KGHM Robinson Mine Plan of Operations for the Robinson Mine (Mine Plan), originally approved in 1994, Robinson Mine operations are set to end in 2024. KGHM Robinson seeks to amend the Mine Plan to allow operations to continue until 2028 and to expand to other areas of land managed by the BLM. The BLM determined that the proposal requires an environmental impact statement (EIS) analysis under the National Environmental Policy Act (NEPA) before making a decision. The draft EIS examined here discusses KGHM Robinson's proposed action and alternatives, as well as potential environmental, recreational, and socioeconomic impacts that could result from the project.

United States Department of the Interior

Bureau of Land Management

Ely District Office

702 North Industrial Way

Ely, Nevada 89301

Re: Robinson Mine Plan of Operations Amendment Draft Environmental Impact Statement, Public Comments Due 1-21-21

To Whom It May Concern:

Environmental Review, Inc. has reviewed the draft Environmental Impact Statement for the Robinson Mine project and has the following comments:

Comments

1. In Environmental Summary subsection “Geochemistry and Groundwater Quality” (pg. ES-3), it is said that “[p]it lakes would form over a period of time, with resulting irretrievable impacts on water quality. These irretrievable impacts would be long term but would not be irreversible.” The use of the term “irretrievable” implies that the impacts of pit lakes on water quality cannot be undone. However, these same impacts are then said to be “long term” but “not be irreversible,” which implies that they could be undone after some time. Is it correct to say that the impacts of pit lakes on water quality would be permanent for the duration of the project and could only be reversed after mining operations end? Could this be reworded for clarity?

2. Section 2.2.4 (pg. 2-3) describes the plan under Alternative D to dispose of potentially acid-generating (PAG) waste rock in the proposed King Waste Rock Dump. It mentions that “[a]t least a 50-foot-thick layer of additional NPAG [non-potentially acid-generating] waste rock would then be placed atop the PAG to act as a cover or cap, thus reducing the potential for precipitation to infiltrate the PAG material.” What information is available to support the claim that adding a 50 foot layer of NPAG material to the top of the PAG would significantly reduce infiltration, and thereby reduce potential acid rock drainage? What is the estimated risk of acid rock drainage with and without the NPAG cover, and how drastically would this change if the thickness of the NPAG cover was increased?

3. Section 3.4.2.2 (pg. 3-23) states that “the selected seismic event (200-year return period) used for the stability analysis [of the King Waste Rock Dump] does not meet current industry practice, which recommends design to an earthquake with return period of 475 years.” What were the reasons for using a seismic event with a shorter return period than the industry standard for this stability analysis?

4. The layout of Table 3.8-1 (pg. 3-47) is a little confusing. It appears that acreage and percentage of analysis area are provided for soils based on two different characteristics: K factor and wind erodibility index. However, there is not a clear separation between these two groups of data, so it could be misinterpreted to mean that each row describes one kind of soil when they actually describe two. We would recommend either splitting the table into two or adding a vertical line between the first “Percentage of Analysis Area” column and the “Wind Erodibility Index” column.

5. The introduction of section 3.9 titled Vegetation (pg. 3-50) mentions that natural resources outside the project area may be impacted due to construction, operation, and decommissioning activities. Consequently, NEPA necessitates what is referred to as “an evaluation of resources within the geographic area where the project impacts are anticipated to accrue and within the time frame in which the effects of the proposed project would occur.” This wording does not directly speak to the question of if and how these potential impacts will be addressed. What level of responsibility will be taken for impacts occurring outside of the project area?

6. Section 3.9.2.4 (pg. 3-54) explains the vegetation-related effects of constructing the King Waste Rock Dump, also known as the preferred alternative. It is noted that “small populations of weedy annual species (e.g., halogeton, cheatgrass, Russian thistle) may become established in localized disturbance areas for short periods of time” (pg. 3-54).  Disturbance creates opportunities for invasive vegetation to become established. A Colorado State University Extension fact sheet titled “Cheatgrass and Wildfire” explains that cheatgrass can produce more than 10,000 plants per square yard and is highly flammable. A University of Nevada, Reno publication called “Taking Aim at Wildfires in Nevada” states that increased invasive plant species are a driver of wildfires in Nevada (Wolterbeek, 2020). Although the EIS includes a noxious weed management plan, what can be done to reduce the possibility of catastrophic wildfires in this area given the high likelihood of invasive species being present in the short term?

7. Section 3.11.2.3 of the EIS (pg. 3-77) pertains to irreversible water resource impacts of the project. It is mentioned that if cumulative depletions of aquifers associated with the project area are ongoing, long-term aquifer recharge could be affected depending on the storage volume of the aquifer. This language is ambiguous regarding potential impacts.  What should be done or calculated prior to starting this project in order to gain a better understanding of potential impacts of long-term aquifer recharge?

8. Section 3.12.1.1 (pg. 3-77) pertains to potential wildlife impacts within the scope of the project. There is a continuous usage of the words “may occur” regarding the various species that might live in the project area. When was the last time that a comprehensive species survey was conducted within the project area? Has a species survey been conducted in areas outside of the project area that may potentially be impacted by the project?

9. Section 3.12.1.4 covers Special-Status Wildlife Species. It is stated that no ESA-listed species are likely to occur within the project area (pg. 3-80). The information following this statement only refers to aquatic Special-Status species; terrestrial species are not mentioned. The paragraph preceding this information mentions that the analysis area may be suitable for up to 119 Special-Status species, 32 of which have the potential to occur or have been observed in prior biological species surveys. That being said, based on what information can the BLM claim that no ESA-listed species are likely to occur within the project area? 

   Please direct all responses to these comments to the following email addresses: This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it. 

Sincerely,

Veronica Guerra (Associate in California)

Environmental Reviewer

Environmental Review, Inc. 

1792 Rogers Avenue

San Jose, California 95112

Matthew Coughlin (Associate in Maryland)

Environmental Reviewer

Environmental Review, Inc. 

1792 Rogers Avenue

San Jose, California 95112

References

Colorado State University Extension. (2020). Cheatgrass and Wildfire [Fact Sheet].  

https://extension.colostate.edu/topic-areas/natural-resources/cheatgrass-and-wildfire-6-310/

Wolterbeek, M. (2020, May 12). Taking aim at wildfires in Nevada. Retrieved January 16, 

2021, from https://www.unr.edu/nevada-today/stories/fire-science