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Department of Natural Resources Department of Natural Resources OFFICE OF PROJECT MANAGEMENT AND PERMITTING P.O. Box 111030 Juneau, AK 99811-1030 907-465-3177 May 29, 2020 Matthew Reece Minerals Program Manager Tongass National Forest 8510 Mendenhall Loop Road Juneau, AK 99801 Dear Mr. Reece, Please find attached the State of Alaska’s consolidated comments on the Preliminary Draft Supplemental Environmental Impact Statement for the Kensington Mine Plan of Operations Amendment 1. Thank you for the opportunity to provide comments at this juncture. Please let me know if you have any questions or need clarification on any of the comments. Sincerely, Sylvia A. Kreel Sylvia A. Kreel Large Project Coordinator Kensington POA1 PDEIS Consolidated Comments Table Department/Division/Section Section/Fig./Table Page # Comment/Issue Recommendation/Action Grammatical, spelling, punctuation, and reference errors found throughout Department of Fish & Game PD SEIS N/A Proofread and edit the PD SEIS for these errors prior to public notice. the document and most notably in Chapter 3. More recent ADF&G reports are available than cited throughout the Department of Fish & Game PD SEIS N/A Consider updating references where appropriate. document: Kane (2020); White (2020). Several acronyms presented in the document are omitted from this Acronyms and reference page including the following: APE (?), GMU (Game Management Department of Fish & Game xi ‐ xii Include all acronyms on this page for reference. Abbreviations Unit), RMA (Riparian Management Area), TCP (?), VCU (Visual Comparison Unit), and WAA (Wildlife Analysis Areas). Revise "Department of Transportation" as follows: "Department of Department of Fish & Game Section 1.1.1 1‐1 Error of omission in agency title. Transportation and Public Facilities". Rectify labeling and stream course of northeast tributaries: The most northern tributary is "Ivanhoe Creek"; the tributary to the east of Ivanhoe is "Ophir Creek". Per the 2004 FEIS (Figure 3‐2), Ophir Creek comprises two Northeast upper tributaries in the Sherman Creek drainage are inaccurately tributaries: "North Ophir Creek Tributary" and "South Ophir Creek Department of Fish & Game Figure 2.2‐22‐4 depicted. Tributary", consistent with our observationsa. South Ophir Creek Tributary has historically flowed along the toe of the Comet Waste Rock Stockpile; this drainage warrants further field investigation in order to accurately document stream course and fish presence. Revise "Ecological monitoring would include monitoring of aquatic life in the TTF, benthic invertebrate community composition, sediment quality and metal toxicity, and periphyton biomass and community composition." Department of Fish & Game Section 2.2.7.2 2‐13 Error of omission. as follows: "Ecological monitoring would include monitoring of aquatic life in the TTF, benthic invertebrate community composition, sediment quality and metal toxicity, and periphyton biomass and community composition within affected watersheds." (i.e., Slate, Johnson, and Sherman Creeks) Inaccurate description: Dolly Varden char will not be manually introduced Revise "The ultimate introduction of Dolly Varden trout (Salvelinus malma) into the TTF (Lower Slate Lake). Per Section 3.7.1 of POA 1 Reclamation would consist of fish from Upper Slate Lake and would be coordinated with and Closure Plan and Section 2.3.4 of the PD SEIS (p. 2‐37), "Upper Slate Department of Fish & Game Section 2.2.7.4 2‐15 the ADF&G and the Forest Service." to "Upper Slate Lake will provide Dolly Lake will provide Dolly Varden to Lower Slate Lake directly once flooding Varden char (Salvelinus malma) to Lower Slate Lake directly once flooding results in the joining of the two lake when the water level exceeds the 765 results in the joining of the two lakes". foot elevation". Revise "Survey Sherman, Johnson, and Slate Creeks under APDES permit AK005057‐1 including aquatic habitat and biological and fish resources." as Department of Fish & Game Section 2.2.9.5 2‐18 Error of omission. follows: "Survey Sherman, Johnson, and Slate Creeks per CAK's Plan of Operations and APDES permit AK005057‐1 including aquatic habitat and fish resources." Clarify the following statement: "The Upper Slate Lake Diversion Pipeline intake would act as a retention structure when runoff is high, allowing the Department of Fish & Game Section 2.3.1.1 2‐24 Lack of clarity. stored water to slowly drain down, instead of into, the TTF to reduce the water entering the TTF requiring treatment." Clarify the following statement: "Each WRS design includes a toe channel to direct stormwater to sediment ponds that would intercept and redirect runoff that has been in contact with waste rock. Stormwater would be Department of Fish & Game Section 2.3.2 2‐27 Lack of clarity. managed per the updated Storm Water Pollution Prevention Plan (Appendix C of POA 1)." Are these stormwater channels existing or to be implemented in the proposed action? ADF&G proposes that additional field investigation occur at the upper Upper Johnson Creek and its tributaries have not been thoroughly extent of Johnson Creek and that the DEIS be modified to incorporate the Department of Fish & Game Figure 2.3‐62‐30 surveyed by ADF&G and may be affected under the proposed action via additional information to accurately document stream course and fish the location of a WRS Expansion. presence. ADF&G may be able to assist with stream surveys. ADF&G proposes that additional field investigation occur at the South Ophir Creek Tributary (i.e., Growth Media Stockpile location) and that the Northeast upper tributaries in the Sherman Creek drainage are inaccurately Department of Fish & Game Figure 2.3‐72‐31 DEIS be modified to incorporate the additional information and accurately depicted. document stream course and fish presence. ADF&G may be able to assist with stream surveys. Department of Fish & Game Figure 2.3‐10 2‐35 South Creek is inaccurately depicted. Correct stream course as shown in Albrecht (2018). Lack of supporting information for the statement "Upper Slate Creek and Department of Fish & Game Section 2.5.1 2‐45 Remove or clarify this statement. Upper Johnson Creek support similar fish populations". Redundant statement: "It would likely need a liner, poses a risk of acid rock Department of Fish & Game Section 2.5.8 2‐49 drainage development, and would require an additional treatment system Remove duplicate statement. for contact water (rain and snow)." Revise "The Forest uses GIS software…" to "The Forest Service uses GIS Department of Fish & Game Section 3.1.1 3‐2 Error of omission in agency title. software…" in this instance and elsewhere in the document. Department of Fish & Game Section 3.2.3.4 3‐7 Reference error: Figure 3.2‐1 is not in the document. Remove the reference or include the figure. Per section 1.5.5.4 of APDES permit AK0050571, include the following Error of omission for ambient monitoring metrics required by APDES Department of Fish & Game Section 3.3.2.1 3‐9 requirement in the bulleted list of ambient monitoring requirements: permit AK0050571. "Periphyton biomass and community composition (annually in summer)." The Sherman Creek macroinvertebrate data presentation does not Include recent information: Kane (2020) summarizes Lower Sherman Creek mention potential influence from white material, which persisted macroinvertebrate data trends, generally finding more macroinvertebrates Department of Fish & Game Section 3.3.2.1 3‐9 downstream of Outfall 001 September 2014‐May 2017 and occasionally and greater EPT proportions at sample sites in 2019 than observed the thereafter.b previous several years. Outfall not specified in final paragraph discussing exceedances of effluent Specify Outfall within this paragraph, as in all other paragraphs within this Department of Fish & Game Section 3.3.2.1 3‐13 limitation for cadmium. section. Increasing the mill throughput may alter influent flow and quality into the Tailings Treatment Facility (TTF) and subsequently may affect the effluent quality into Lower East Fork Slate Creek at Outfall 002 of APDES Permit The text of DEIS in Section 1.2, page 1‐3, bullet says, "Increase(in) the mill AK0050571. Since the proposed change to the mill throughput potentially throughput from 2,000 to 3,000 tons per day." Chapter 3, page 3‐14 affects the mine's ability to achieve compliance with APDES Permit further notes that "Under all alternatives, future exceedances of effluent AK0050571, further evaluation may be necessary to determine the proper Department of Environmental limitations in the discharges at Outfall 001 and Outfall 002 could occur. Chapter 33‐14 permit conditions required as a result of the mill upgrade. Generally, Conservation Exceedances could occur immediately downstream of the discharge but changes to an APDES permitted facility that result in an increase of would be expected to be minor and temporary. The effects of exceedances pollutant into the receiving water are subject to a permit modification on designated stream uses, including uses for aquatic life, would not be process that may include a public opportunity to review and comment. expected in the receiving water body (i.e., Sherman Creek or Slate Creek) ." Please add a final sentence to the quoted paragraph on page 3‐14 that "The APDES permit evaluation of compliance and permit conditions will take place following the record of decision. " Reference error: Table 3.3‐1 is repeated and Table 3.3‐2 is inaccurately Rectify these references: remove one instance of Table 3.3‐1 and replace Department of Fish & Game Section 3.3.3.1 3‐14 referenced. the reference "Table 3.4‐2" with "Table 3.3‐2". Typographical error: "Treatment and discharge through an APDES Rectify statement: "Treatment and discharge through an APDES discharge Department of Fish & Game Section 3.3.3.4 3‐19 discharge permit would be required until the effluent does not meet permit would be required until the effluent meets Alaska water quality Alaska water quality standards." standards." Department of Fish & Game Section 3.3.3.4 3‐19 Typographical error: "Graphic Phyllite" Correct instances throughout document as follows: "graphitic phyllite".
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