The following are comments prepared By Rick Clewett on behalf of the Cumberland Chapter regarding permit application (DSMRE 897-9007) by Enterprise Mining Company to build a slurry pond on Perry County, Kentucky. These comments were presented verbally at a hearing in London, KY, on March 27, 2008
Re: Pending DSMRE 897-9007 Permit Application, Enterprise Mining Company, Perry County, Kentucky
These comments are being submitted on behalf of the Kentucky chapter of Sierra Club, the Cumberland Chapter. With over 5,000 members statewide, we have been one of the main environmental organizations in Kentucky for the last half century. Two of the Cumberland Chapter’s long-term goals are to improve or maintain the state’s water quality and to make sure mining in the state is done in lawful and responsible ways that will pose minimum risk to people, habitat, and the environment.
It is inadvisable to build a slurry pound adjacent to and possibly on top of underground mines—whether active or abandoned. The Martin County disaster in 2000 makes this abundantly clear. The abandoned Hazard 5--a deep mine-- is in close proximity to the proposed construction site. Also, it is not clear that adequate core sampling has been done to determine the extent of underground mining below the proposed structures.
It is not prudent to build a 100 foot tall impoundment structure above infrastructure and residences that are thereby potentially placed in harm’s way
It is not prudent to build an in-stream slurry operation on a branch of the Kentucky River, since that body of water supplies drinking water to numerous cities down stream, including Lexington, Frankfort, Nicholasville, Richmond, Jackson and more.
While we do not think a sludge pond should be built at this location, if it is to be built, we suggest that it would be prudent for a slurry pond of this type and in this kind of location to have a hazardous waste liner in place. We are concerned about the likely degradation of water quality in wells down hill and down stream from the proposed structures.
The mitigation plan claims that streams will be restored with “equal or better habitat” than the pre-mining condition. What evidence is there that this can be done? The application claims that if this level of restoration is not achieved, corrective action will be taken. Who will determine this and who will oversee it?
While it may pose its own environmental problems, it would seem appropriate to require Enterprise Mining to do a study of the comparative feasibility of using the dry cake method of processing mining waste so as to avoid the need to build this potentially hazardous impoundment structure.
Respectfully submitted,
Rick Clewett, Cumberland Chapter Sierra Club Executive Committee
Co-Chair, Cumberland Chapter Sierra Club Political/Legislative Committee
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