Coeur Alaska

Letter from Gene Burden to Jon Kessler

STATE OF ALASKA
DEPT. OF ENVIRONMENTAL CONSERVATION TONY KNOWLES, GOVERNOR
OFFICE OF THE COMMISSIONER

410 Willoughby Ave., Suite 105 Telephone: 465-5066
Juneau, AK 99801-1795 Fax: 465-5070

August 15, 1995

Mr. Jon Kessler
Office of Policy Planning and Evaluation
USEPA
West Tower 1013
401 M Street SW
Mail Code 2111
Washington, D.C. 20460

Subject: Coeur Alaska Kensington Project XL

Dear Mr. Kessler:

The Alaska Department of Environmental Conservation (ADEC) has reviewed the Coeur Alaska Kensington Project XL Application and supports the selection of this project for EPA's XL program. We understand the XL program is in its early stages and believe the Coeur proposal offers a number of benefits to all parties (including EPA and ADEC) including the following:

1. Environmental performance that demonstrates investment in leading edge technology and innovation resulting in operations that meet and typically exceed applicable environmental regulations is welcome and good for current and future business. Parties such as Coeur, offer a low risk opportunity to apply modified regulatory oversight in response to such actions.

2. Governor Knowles launched the statewide Mining Task Force involving a wide range of stakeholders with an overall objective of promoting environmentally responsible mineral resource development in our state. Lessons learned from the Coeur XL project could prove invaluable in our efforts to attract such additional investments.

3. The process assures cooperation between all interested parties in reaching satisfactory resolution to design performance criteria as well as the standards which should allow regulatory flexibility.

4. We like the prospect of being able to reward, and thereby promote, sound environmental management in developing the state's key natural resources.

5. The project will enable ADEC to pilot assumption for primacy on the NPDES program permitting.

Mr. Jon Kessler
August 15, 1995
Office of Policy Planning and Evaluation
USEPA

The Coeur proposal involves application of best available treatment technology for the water treatment. They have demonstrated an innovative application in the design of a program that would separate the cyanide process wastestream, and treat the effluent to the highest level available while placing neutralized concentrate (solids) underground or in a segregated, lined area of the treatment facility.

In addition, Coeur proposed to eliminate the potentially contentious marine mixing zone in the area of the Lynn Canal commercial fishery by use of more advanced treatment than is required and discharging to a non-anadromous fishery stream. The capital investment will be accompanied by an advanced environmental monitoring program.

Coeur has also aggressively sought out the stakeholders for advice and input which will facilitate the regulatory and public input process as the NPDES permit is crafted.

In conclusion, the Kensington Project XL can serve as a model of our joint efforts to move to a more results oriented regulatory scheme. ADEC's assumption of a key responsibility in writing the NPDES permit would be a significant step in demonstrating our ability to assume primacy for the water discharge program in Alaska. We hope you will also support us in pursuing the opportunity to select Coeur for this important program.
Sincerely,

Gene Burden
Commissioner
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cc: Dennis Wheeler (Coeur Alaska)
B. Boyd (Coeur Alaska)
Len Vrrelli (ADEC)
Chuck Clarke (EPA Region 10)

Coeur Alaska

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