Comment to the MPCA on NorthMet Water Quality Permit -comments due March 16, 2018

PolyMet draft water quality permit comment
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155

This permit proposes to monitor discharges in the Laurentian area from this project’s copper-sulfide mining of low grade ore in an extremely water-dependent area of the world at the headwaters of the Great Lakes and the St Lawrence Seaway.
Infrastructure including rails and roads will be required. Among the facilities referenced in this draft, the following:

  • A beneficiation plant
  • A hydrometallurgical plant
  • A flotation tailings basin (FTB) including Seepage Capture Systems
  • A hydrometallurgical residue facility (HRF)
  • A waste water treatment system (WWTS) – discharge of which will be routed through pipes to maintain flows in Trimble Creek, Second Creek, and Unnamed Creek, with some being recycled directly to FTB pond.
  • Other ancillary facilities (eg Colby Lake water pipeline) including:
    • Mine water filtration train
    • Tailings basin seepage treatment train
    • Wastewater treatment of solids/byproducts: from the tailings basin seepage treatment train including waste from filters and membrane cleaning and concentrate, which will be routed to FTB pond and mine water chemical precipitation treatment train.


Can we rely on a for-profit corporation to monitor itself? The permittee, Polymet, is expected to report all data from the required monitoring stations, whether favorable or not. If reported accurately and standards are not met, then Polymet will be required to monitor again until standards are met. What worthy and worthwhile actions will be taken at the “end of the day?”

If the unfathomable number of reports (essentially required just to monitor the discharge from this mining operation) are maintained accurately with regularity, consistency and competency, what truly effective actions can be taken when standards are exceeded? What of the monitoring stations that have no set standards as guidelines? What of those that are not enforceable? What actions are possible that will return the water to its base levels when the degradation becomes apparent to us all? What amount of money in the form of fees or financial guarantees can reclaim what is lost?

In addition, there is little that anyone can do to prevent natural processes and disasters from occurring, or human error whether knowingly or not; and so, by any standard, this mine will degrade our water resources in Minnesota and beyond. Can any permit for such a mine adequately address these issues?

Once copper mining has run its course in the Arrowhead by setting precedent with Polymet, the first of many to come, what will remain and what can truly be reclaimed? “Downstream,” the St Louis River estuary and Lake Superior, the largest body of fresh water in the world? “Downstream,” the BWCA, and the Rainy River Watershed, the Superior National Forest and Voyageurs, the most pristine wilderness areas on the planet? Can we afford this mine?

There are hundreds of pages listed (in this water permit draft and other permits) of essential equipment and gauges required just to monitor pollution from the proposed NorthMet Project (copper mine) on a continuing basis daily, monthly and/or annually through the life of this mine and beyond. This alone speaks for itself and cannot be reconciled with the safety of our greatest natural resource.

I respectfully request that MPCA deny this permit to pollute our waters.