Q&A: Mining & Green Energy
Professionals involved in the mining industry are constantly looking for ways to optimize operations and minimize the environmental impact by designing sustainable mine closures, using EV haul trucks, and remediating land/groundwater during and post operations. Permitting is one of the challenges our clients tackle daily, including specific reporting deadlines, actions required if a breach occurs, and requirements for facility inspection. Below, our experts provide a compliance crash course on mine permitting in Arizona.
In general, what role does mining play in advancing green energy?
The future of green energy relies on the mining of critical minerals because minerals such as copper, silver, cobalt, and nickel are needed for electric vehicles, wind turbines, solar panels, and other green technology. Mines provide the minerals to build transportation vehicles, infrastructure, and equipment to deliver water, natural gas, and electricity. Part of the continued demand for these critical minerals means more mining is necessary.
What is an aquifer protection permit (APP) and why would a mine need one?
An APP is required for any facility that discharges pollutant(s) to groundwater. It includes two key requirements: (1) to meet aquifer quality water standards at a point of compliance (POC), and (2) to demonstrate Best Available Demonstrated Control Technology to minimize the impact of discharges. The APP protects groundwater from any accidental or potential releases of pollutants and is in place for the entire life cycle of the mine until closure. APPs include a variety of requirements (both reporting and monitoring) and are often bound by Compliance Schedule Items (CSIs).
What is a CSI?
CSIs include engineering facility elements (such as retention ponds and tailing storage facilities), POC and groundwater monitoring, and financial closure/post-closure requirements. All the items on the CSI will have a trigger (start) date and due date. The CSI also indicates if the completion of a task will trigger an amendment. However, amendments can be requested and issued for items that do not pertain to the CSI, such as ownership transfer.
What are the types of amendments?
The three types of amendments associated with APPs are: significant, minor, and other. Below are some examples of items that require amendments:
- A “significant amendment” is needed when POC monitor wells need to be replaced (e.g., if a POC monitor well is damaged or is dry)
- A “minor amendment” is needed when alert levels (ALs) and aquifer quality limits (AQLs) are set for newly installed POC monitor wells. ALs and AQLs are determined after eight months of monthly sampling and determine boundaries for quarterly and semi-annual sampling of the POC monitor wells.
- An “other amendment” is needed when additional POC monitor wells are installed. This would be triggered if a monitor well is installed to remedy a data gap identified by groundwater modeling or when an AL or AQL needs to be changed; either removing or adding a new constituent or adjusting the actual limit of an AL or AQL based on water quality trends.
Interesting fact: Arizona is home to the largest copper mine in the United States and leads the country in copper production. We encourage you to research the mining history of your state to discover the types of minerals impacting the race for green energy!
Melisa Darrow is a hydrogeologist with 11 years of experience specializing in multidisciplinary engineering and environmental projects, including the management of $1M+ scale programs for her mining clients.
Brittany Meucci, GIT is a hydrogeologist with five years of consulting experience specializing in hydrology, mine compliance, and managing multi-sized field programs.