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One of the most tedious aspects of an EHS manager’s job is to keep track of a host of records. Laws have been passed in every jurisdiction requiring facilities to produce and retain records of various kinds. Don’t get caught without the necessary records in the event of a surprise EPA or OSHA inspection! This special report shows EHS managers at a glance the records they must keep on hand and for how long.

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This special report contains a recordkeeping checklist to help you keep track of your records for major environmental laws and OSHA’s Hazard Communication Standard.

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May 07, 2013
Pebble Mine assessment highlights risks

In its second draft assessment of the impact of the proposed Pebble Mine on the ecology and economy of Bristol Bay, Alaska, the EPA paints a grim picture of potential stream and wetland losses, industry discharges that diminish water quality, and other adverse impacts resulting from road construction and possible dam failures. 

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The credibility of the assessment was attacked by The Pebble Partnership.  The Partnership is seeking federal permits to extract  as much as 11 billion tons of ore, containing mainly copper, which would make the Pebble Mine the largest mine of its type in North America.  The Partnership complains that the EPA has developed its own failure scenarios before the Partnership has even submitted a complete dredge and fill permit application to the Army Corps of Engineers; the EPA has authority under the Clean Water Act to veto permits the Corps grants. 

The EPA notes that the assessment is not a final Agency action; rather, it is intended to inform the consideration of options for future action by government bodies, including the Corps and the EPA. 

Largest sockeye salmon fishery

Bristol Bay encompasses an extraordinary salmon population, including the largest sockeye salmon fishery in the world.  EPA’s draft assessment emphasizes the economic importance of this resource.  According to the Agency, the ecological resources of the Bristol Bay watershed generated nearly $480 million in direct economic expenditures and sales in 2009 and provided employment for over 14,000 full- and part-time workers. The Bay’s commercial salmon fishery generates the largest component of economic activity with a value estimated at $300 million in 2009 (sales from fisherfolk to processors) and providing employment for over 11,000 full- and part-time workers at the season’s peak.

These estimates do not include retail expenditures from national and international sales.  The area’s sport-fishing industry supports approximately 29,000 sport-fishing trips, generates approximately $60 million per year, and directly employs over 800 full- and part-time workers (based on 2009 data).

Mining scenarios

EPA’s assessment considered three possible mines–Pebble 0.25 (approximately 0.25 billion tons of ore and a duration of 20 years); Pebble 2.0 (approximately 2.0 billion tons of ore and a duration of 25 years), and Pebble 6.5 (approximately 6.5 billion tons of ore and a duration of 78 years). 

Under Pebble 6.5, the assessment envisions that tailing storage facilities, waste rock piles, blockage, and dewatering will result in the loss of 90 miles of streams known to provide salmon spawning or rearing habitats.  Also, under the largest footprint scenario, wetland losses would approach 5,000 acres, reducing availability of and access to hydraulically and thermally diverse habitat that can provide enhanced foraging opportunities and important rearing habitat for juvenile salmon.  Indirect effects would include reduced food resources from the loss of organic material and alteration of the balance of surface water and groundwater input, potentially reducing winter fish habitat and making streams less suitable for spawning and rearing.

‘Flawed’ hypothesis

According to the Pebble Mine Partnership, EPA’s assessment is based on a “deeply flawed approach of creating and evaluating a completely hypothetical mine plan, instead of waiting until a real, detailed mine plan is submitted to regulators as part of a complete permit application.”  Concerns have been raised that the Agency’s assessment is an attempt by the EPA to veto the project before a formal proposal is even submitted. 

The EPA has indicated that the mine scenarios in the assessment are drawn from plans developed for Northern Dynasty Minerals, consultation with experts, and baseline data collected by The Pebble Partnership to characterize the likely mine site, mining activities, and surrounding environment.   Northern Dynasty Minerals is a major member of the Pebble  Partnership.  “Plans proposed by Northern Dynasty Minerals … are generally applicable to copper deposits in the Bristol Bay watershed,” says the Agency.

Click here for the assessment. 

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