Letter from Murray Walsh to William Boyd
August 1, 1995
File No. M-06-90
155 SOUTH SEWARD STREET
JUNEAU, ALASKA 99801
William F. Boyd
Coeur d'Alene Mines Corporation
P. O. Box I
Coeur d'Alene, Idaho 83816
Dear Mr. Boyd:
The City and Borough Of Juneau (CBJ) supports Coeur
Alaska's application to be accepted as a participant for EPA's Project
XL. During a recent discussion of the proposal with Rick Richins,
we learned that the pilot project has evolved even since it was submitted
to EPA on July 14th. We understand that the proposal now includes
three primary components: (1) modifications of the Kensington
Gold Project involving discharge into Sherman Creek and meeting permit
limits through flow augmentation and additional treatment; (2) a pilot
project which, if successful, could enable the State of Alaska to assume
responsibility for administering the NPDES program in Alaska; and (3)
a related study element which addresses the analytical limitations of
reliably measuring low concentrations of various regulated substances.
We would like to offer the following comments on the primary aspects of the proposal. First, the project modifications being proposed through the XL program appear to have considerable potential for "better environmental results." The proposal should be analyzed and, if found to produce those better results, be considered for implementation.
Second, we are very pleased to learn of Coeur's proposal to assist the State of Alaska, through the XL Program, in evaluating the assumption of NPDES permitting authority. We believe that the "trial run" Coeur has proposed is very likely to show that the process can have a smoother flow with the State in this permitting role, and that there are many benefits to be realized through more project specific and site specific permitting.
Finally, Coeur Alaska's proposal to use Practical Quantitation Levels (PQL) as NPDES permit limits appears to hold many practical advantages for monitoring permit compliance. As we understand it, PQL represents the concentration at which 75% of EPA and state laboratories are able to quantify a compound within specified limits. A PQL based permit limit would seem to yield more reliable and consistent data.
August 1, 1995
Thank you for the opportunity to review Coeur's pilot project proposal for an XL project. Please feel free to share this letter with the EPA.
Murray Walsh, Director
cc: CBJ Planning Commission
Rick Richins, Coeur Alaska