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Expert Report on PolyMet SDEIS
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1
REVIEW OF THE WATER QUALITY MODELING
NorthMet Mine and Plant Site, Minnesota
March 2, 2014
Prepared for: Minnesota Center for Environmental Advocacy
Prepared by: Tom Myers, PhD, Hydrologic Consultant, Reno NV
Polymet presents an immense modeling project in support of their draft supplemental
environmental impact statement for their proposed Northmet Mining Project. This technical
memorandum reviews this modeling, including the conceptual model for flow and transport,
parameterization of the Goldsim simulation model, and the results.
Polymet presents its model in a report titled: Northmet Project, Water Modeling Data Package,
Volume 1 Mine Site. All references to Polymet or simply a page number in this memorandum
are to their model report. Also, a separate modeling report has been prepared to test the
assumptions presented by Polymet and is referenced in this review (Myers 2014).
Goldsim Modeling and Simulations
This section considers aspects of the Goldsim modeling the basic modeling of the conceptual
flow model including the geologic conceptualization and the hydrology. The next section
considers the conceptual flow and transport model. It is important to consider whether the
simplifications required in Goldsim are accurate and true to the hydrology of the site. Polymet
describes the objectives of the modeling and the selection of Goldsim in Section 3.
Polymet indicates that uncertainty in parameter values is due to both inherent variability and a
lack of complete knowledge, which they call aleatory and epistemic uncertainty, respectively.
They ignore the uncertainty that arises due to scale. For example, system parameters may be
known at a few points, but the basic value can be quite different is considered at scales larger
than a point (Schulz-Mackuch et al. 1999). Scale, for example, commonly causes parameters
such as conductivity (K) to increase as a larger volume is considered as more high permeability
zones are included. The modeling therefore uses K values that are too small.
The modeling uses Monte Carlo methods to randomly sample both input drivers and system
parameters to create multiple simulations with each representing equally-likely possible
performance of the system (p 11). If true, then the output is a probability distribution that
describes the likely performance of a given model result (Id.) meaning the output for any given
result, such as the concentration of antimony at a given monitoring point in the Partridge River.
2
This is true if the probability distribution does accurately and honestly capture the likelihood
of potential value and event (Id.) and also if the model equations and basic conceptual model
accurately describes flow and transport through the system. This review points out many
inaccuracies with the parameters, the assumptions, the conceptual model, and even the
equations used in the model to solve the transport. It indicates the overall results are
inaccurate and probably give a false sense of security.
There were four desired capabilities established for selecting the model platform (p 12). The
first is the model should be probabilistic, which if everything is parameterized correctly is an
excellent goal. The second is the ability to handle large quantities of data. It is possible that
the model structure could be too simplified just because of the desire to somehow
accommodate every potential input and generate immense loads of output. It may not be
necessary to simulate more than a dozen contaminant sources to a given facility if just a couple
of those sources provide overwhelmingly more load than others (Myers 2014). Similarly, the
third capability is the flexibility to simulate a variety of different purposes meaning the ability
to assign a probability distribution to every engineered source of contaminants, and the same
comment as to the second capability applies. The fourth capability is transparency, which
Goldsim does not seem to meet.
Polymet chose the Goldsim model as meeting the above capabilities. They apparently did not
consider the stochastic modeling capabilities of MODFLOW and MT3DMS, which could have
considered many of the parameters in a probabilistic manner without oversimplifying the
analysis (discussed more below). Modelers using MODFLOW/MT3DMS would have had
difficulty considering the randomness of the engineering inputs used in Goldsim, but for various
reasons that may not have been necessary or could have been accomplished in different ways.
For example, it would have been appropriate to run a model stochastically for each of several
sets of deterministic engineering inputs to show the effects of there being more seepage from a
given facility than as designed. This would have eliminated the problems caused by the
conceptual model used with Goldsim and discussed below.
Polymet also claims that Goldsim is widely used in the industry for conducting water and
chemical balances for mining applications (p 14). This reviewer has reviewed many
environmental documents for mining projects all over the country and somewhat globally and
has never seen the model used. To justify the claim of wide use, Polymet should provide an
extensive list of mines on which Goldsim has been used to simulate contaminant transport.
Goldsim uses stochastic modeling, implemented with Monte Carlo like random sampling of
input values and parameter, of deterministic equations to estimate the various outputs from
the model. The model is solved for each set of random selections to yield a probability
distribution for the output, rather than a single value, so that the user can assess risk.
3
The model output can be useful, a good representation of the potential outcomes of imposing a
development, here the proposed Northmet Mine, on a given natural system, if the natural and
proposed system is accurately conceptualized and if the equations used within Goldsim are
accurate for the conceptual model. Especially for water quality modeling, the flow and
transport equations must be appropriate to implement the conceptual model. The results are
useful only if the random selection of input and model parameters is from an accurate
probability distribution. Probability based modeling is a substitute for a good understanding of
the processes and the parameters that describe the process.
The model fails the transparency requirement because it is proprietary and it is not possible to
review or run the model without purchasing the model platform. Without this capability, it is
not possible for the public to independently test Polymets assumptions.
Conceptual Model
The conceptual model as implemented by Polymets modeling includes a standard definition of
a conceptual model as normally considered flows through the project domain as well as
how it is implemented into Goldsim; most of Polymets discussion does not distinguish among
the hydrology and its Goldsim implementation.
Hydrogeology
Polymet treats the bedrock as far more impermeable that it actually is, and that is based on
their pump test data. Polymet notes that K resulting from their pump tests ranges from 0.0024
to 1.0 feet/day, with a geometric mean of 0.17 feet/day (p 22). The statement is correct but
highly misleading. The original observations are shown in the following table, clipped from Barr
(2006b). Only three of the twelve observed Ks are less than the geometric mean, with one
being just 0.01 ft/d less than it. Well P-1 was essentially dry, but the data resulted in a 0.0024
ft/d value which controlled the geometric mean and essentially drives discussion of bedrock
being non-conductive. The Duluth complex is a large mafic intrusion and the Virginia
formation is a sedimentary unit (p 20), which according to Freeze and Cherry (1979) would have
K ranging from 10-8 to 10-3 and 10-10 to 10-5 m/s (0.00026 to 2.63 or 2.63x10-6 to 0.263 ft/d,
respectively). The pump test values are realistic and it would be better to consider that 70% of
the site had bedrock K greater than 0.1 ft/d. Scale issues matter more in bedrock because as
the rock volume being considered becomes larger, to a certain degree, the proportion of
fractures becomes larger as does the effective K. Polymet acknowledges that fractures in the
upper several hundred feet lead to a higher K (p 22).
4
Vertical Connection among Aquifers: There is a need for better information regarding vertical
gradients and the connection between the surficial and bedrock aquifers. The three nested
wells are nested only in the surficial aquifer and generally show a downward gradient, but they
are all located downhill from the pits. The vertical gradient may differ near the groundwater
divide. There is also no indication of gradient between the bedrock and surficial aquifer. The
discussion regarding bedrock groundwater levels (p 22) notes that the levels measured in five
bedrock observation wells were generally below the top of the bedrock contact. This would
indicate a lack of connection if the surficial aquifer were saturated but there is no information
at those points. There is simply not enough data to assess gradients among aquifers. There is
also only one pump test which suggests there is not connection. Because each significant
bedrock fracture may have a different hydraulic connection, this is insufficient information to
conclude there is no connection. This is perhaps the most important data that Polymet could
have because dewatering the bedrock will draw water from the surficial aquifer and could
dewater that aquifer if there is a connection.
Polymet reports a thirty-day pump test based on pumping at well P-2. As may be seen in the
table above, this well had the second lowest K. Its fractures may have poor connection with the
surface or pumping effects may take longer to propagate to the surface. This is far too little
data with which to assume little connection between the bedrock and surficial aquifers. For
modeling, Polymet has not justified their assumptions of no connection among aquifers.
5
Water Quality
The background water quality data is primarily important as the base on to which Polymets
mine discharges would add. They state that background SO4 is 18.3 and 9.1 mg/l in the
bedrock and surficial aquifer, respectively. Further, the modeling results for the Partridge River
are that the median SO4 concentration at SW004 is about 9.1 mg/l. This reflects the lack of
simulated transport through bedrock pathways. Considering copper, there is a significant
variety of values shown on Polymet Large Figure 17, but they do not exceed the drinking water
standard so Polymet is not concerned. Many of the observed groundwater values exceed the
simulated model results, which may reflect the simulation of sorption, which is discussed
below.
Additionally, the SO4 readings in the Partridge River have exceedences during the critical wild
rice period of April 1 through August 30 (p61, 62). They also note that all of the discharge that
enters from the Peter Mitchell Pit exceeds the standard. Importantly, this discharge is part of
the existing conditions, but not the natural background. Most of the modeling assumes this
discharge continues. Polymet should model a scenario w/o continued discharge from PMP
because it dilutes some constituents and causes some to have exceedences even without this
project.
Baseflow
Baseflow for the Partridge River may be incorrectly estimated. It is not uncommon to use the
annual 30-day low flow as a baseflow estimate, but there are various reasons why that may be
inaccurate here. Myers (2014, Part A) explains in detail the problems with this and presents an
independent estimate of baseflow for the area. This brief review mentions a few items from
Polymets modeling study.
1. Figure 4-8 demonstrates the immense variability in annual 30-day low flows. This reflects the
many factors which control flow, as outlined in Myers (2014), such frozen precipitation.
2. Dewatering discharge from the Peter Mitchell Pit cannot be simply subtracted from the flow
because the data presented in the modeling studies demonstrates that it is not simply an
additive process. In some months, there is more discharge than flow recorded on the river.
Water apparently gets stored along the river above the gage.
3. Mine dewatering may affect river flows in a way not considered drawdown from the
dewatering may draw water from the river into the aquifer. Polymet does not consider this
probably because they believe there is no connection. But there is no justification for not
considering it.
Polymet estimates river flow based on a distribution of monthly flows at SW006 as shown in
Table 5-13 (p 127). A problem with this scheme is that it is a random selection by month
6
without regard to the previous month. A dry month could follow a wet month, which is
unrealistic. The model then distributes the SW006 flow to other evaluation points according to
area draining to them and the year of mining.
Baseflow matters for several reasons. Baseflow is groundwater discharge and the groundwater
flow moves contaminants from the minesite to the river. For water quality modeling, it can
dilute the load discharging from the minesite but it also carries a part of the load. Dilution
would occur if most of the load is surface flow but if most is seepage, higher groundwater flow
may cause predictions to be higher.
Additionally, baseflow matters in the calculation of recharge, as discussed in the following
section.
Recharge
Recharge rates for the watershed have been underestimated. Recharge is the water that
enters the aquifers and controls the flux through an aquifer to a downgradient river. The
recharge estimate therefore drives modeling and controls the results. It is common to set
recharge equal to river baseflow so the error comes in how baseflow is estimated. Polymet
estimated an average recharge of 0.74 in/y for the drainage above Colby Lake (p 130), based on
a simulated groundwater inflow to the river of 5.3 cfs and 97 square miles. The watershed yield
(at gage 04015475 Partridge River above Colby Lake) is 0.84 cfs/mi2 (p 39) which is 11.4 in/y, a
value consistent with the precipitation and ET estimates. Recharge is the amount of 11.4 in/y
that is not storm runoff (assuming that none of the recharge reaches bedrock and flows from
the watershed). Based on comparisons with other methods, 0.74 in/y is an extremely low
(Myers 2014). It is critical to estimate the baseflow that groundwater contributed to correctly
set the recharge equal to it.
Polymet simply set baseflow equal to the lowest 30-day flow in this watershed. There are many
reasons that this is not correct or not representative in this basin (Myers 2014). Most 30-day
low flow observations occur during late winter or early spring. Much of the watershed and
most precipitation is frozen so there would be no recharge during that time. After a long frozen
period, the groundwater level in the water would have lowered substantially as the
groundwater supply is depleted. The gradient controlling discharge to the river is at its smallest
at this point. The baseflow at this time is groundwater but is very low compared to the flow
that occurred earlier in the winter when the water table, and gradient, was higher.
Additionally, some tributaries which carry groundwater to the river may freeze to the point that
discharge from parts of the watershed simply do not reach the river until the system thaws.
This is especially true if the tributary flows through wetlands or small ponds.
7
Evidence that the recharge rate is underestimated is the amount of dewatering that was
necessary from the Peter Mitchell Pit in the headwaters of the Partridge River. The average
dewatering rate for that pit was 11.8 cfs for about 11 years which was 13% of the discharge
recorded at the Partridge River gage near Colby Lake for that time period. Considering the
small area that would provide groundwater flow to the Peter Mitchell Pit, the dewatering rate
is very high. Because dewatering is water that had recharged within the capture zone of the
pit, it is apparent that the recharge rate within that capture zone is much higher than it is
within the watershed as a whole as estimated in the data report.
Myers (2014, Part 1) reestimated recharge for both Partridge and Embarrass River watershed
and found that Polymet underestimated it by three to five times. Myers (2014, Part 1) provides
substantial justification for using a higher recharge value, and is cited here for completeness.
The recharge rate matters because it controls the flux rate and mass loading along the model
pathways. It also controls the dewatering rate and how fast pits will refill. It will affect the
water balance in the pits and the amount of groundwater discharge into the streams. It will
also affect the amount of water that must be pumped, and discharged, to avoid having the
West Pit overflow. The higher rates will enter the shallow, surficial groundwater aquifer and
drive the flows and the mass loading to the river. Calibration with higher recharge would
require higher K in the bedrock and likely more bedrock flow to the river. It therefore appears
that the very driving force of the groundwater model, and the Goldsim contaminant transport
model, has been vastly underestimated.
The recharge rates should be reestimated considering the above and Myers (2014).
Everything in the model that depends on the recharge rate should be reestimated, including
the basic groundwater model used to estimate Goldsim parameters.
Flow Pathways
GoldSim uses 1-dimensional (1-d) flowpaths through the site to discharge points at the river.
The method is similar to the analytical element method sometimes used with MODFLOW in
which a section of a model domain is simulated with the analytic equation rather than with the
finite difference solution. Flow along the path would accumulate natural and minesite recharge
and interflow along the pathway. The modelers established eight flow paths based on
groundwater contours determined with MODFLOW modeling, including five surficial aquifer
flowpaths emanating from waste piles or pits and three bedrock flowpaths emanating from the
pits (Figures 1 and 2). They reach the river between SW003 and SW004. Only the flow paths
emanating from pit lakes have discharge entering at the upstream end during closure.
8
Figure 1: Snapshop of large figure 28, Polymet (2013c) showing surficial flowpaths.
Figure 2: Snapshot from Large Figure 29 showing bedrock pathways.
9
Polymet should address whether there should be pathways north to the river. None of the
model pathways discharge north even though there is a groundwater divide under the Cat 1
stockpile in pre-mining conditions. There is no pathway from the Cat 1 Stockpile to any
discharge point because Polymet assumes that any escaping seepage will discharge to the West
Pit (Figures 1 and 2 show the waste area in green and the liner around it). Pre-mine contours
suggest there was a groundwater divide through this area (and through the East Pit) such that
some seepage could discharge to the river on the north side.
Simulation of Flow and Transport along a Groundwater Pathway: The Goldsim model
estimates groundwater discharge to a given river reach at the downgradient end of the
flowpaths as equal to the recharge in the area draining to that reach. That includes flow into
the upstream end of the flowpath, facility seepage along the flowpath, and natural recharge
(with concentration set equal to the background concentration) (Equ 5-13). (Flow into the
upstream end is zero if the upstream end is a divide, no flow boundary, or anything other than
the pit lake.) Goldsim assumes a constant aquifer thickness (transmissivity) and a constant river
stage, so the downstream end of any gradient calculation is constant (p 104). The model does
apparently account for changes in the water level at the upstream end, which change the flow
rate or reverse its directions so that flow and contaminants could flow toward the pit rather
than toward the river discharge (p 105).
The flow calculations rely on an assumption that the surficial aquifer is 5-m thick rather than on
reality that the piezometric surface along an aquifer receiving recharge is parabolic in shape
(Id.). In other words, they have assumed constant thickness where in reality the thickness is
not constant. Polymet also ignores the actual variability in thickness caused by the actual depth
to bedrock ranging to almost 20 m, as seen in Large Figures 4 through 10. The actual
transmissivity varies spatially around the model domain and longitudinally along the modeled
flowpath. Polymet justifies using a singular thin aquifer by suggesting that a uniform aquifer
thickness results in a smaller aquifer area to accommodate flow and faster groundwater
velocities (Id.). Continuing, Polymet claims that [f]aster groundwater velocities result in less
dilution from recharge and higher concentrations observed at the evaluation points. This
justification is incorrect because the flow equations are steady state based on conservation of
mass the flow entering the cell during a time step equals the flow leaving. The concentration
of the flow leaving depends on the load that entered the cell being dispersed immediately
through the volume of the cell.
The GoldSim modeling also uses K values randomly chosen for each 1-d flow path; it is unclear
whether there is a separate value for each flowpath during each simulation. The
documentation does not discuss conditioning the value based on the chosen value for an
adjacent flowpath, which means accounting for correlation in the heterogeneity. In other
10
words, if it is strictly random then adjacent flowpaths could have widely different K which
would be inappropriate. On the other hand, if one K value is chosen for all the flowpaths within
the same aquifer type, the modeling would be ignoring spatial heterogeneity. It is impossible to
independently verify these values due to transparency issues discussed above.
The modeling uses bedrock K values that are much lower than their pump tests indicate and
lower than calibrated by Myers (2014). Attachment B, Table 1-15 shows that Polymet used
bedrock K ranging from 0.000047 to 0.00047 m/d with a mode of 0.00015 m/d. These values
are at least two to three orders of magnitude less than reported in the model report and
discussed above herein. It is another example of how Polymet has downplayed the potential
for bedrock to pass any flow to the rivers. Transport through the bedrock would be faster
because of the preferential flow but Polymets assumptions prevent such transport. The same
table shows reasonable ranges for surficial aquifer pathways that are basically confirmed by
Myers (2014, Part 2). However, Polymet used a thickness of only 5 m for the surficial aquifer,
which may be too thin and result in too low a transmissivity in places. It is unclear how this
would affect transport because it is unclear, due to the lack of transparency in the model
documentation, where velocity would be based on all of the simulated flow occurring through
the 5-m aquifer or whether it would be based on gradient. In other words, it is unclear whether
it is based on conservation of mass or Darcys law. The former would cause higher velocities
and faster transport and the latter would cause slower velocities and transport because the
gradient is established separately.
GoldSim constructs flowpaths using adjacent cells and models the water balance
simultaneously among each cell. It apparently utilizes one K for the entire flowpath. This
assumption violates any realistic conceptual model of flow in the aquifers by ignoring
heterogeneities. The K could vary along the flow path but the modeling as proposed here fails
to account for that. If possible, the GoldSim modeling should use different K estimates for each
cell but they should be selected with spatial correlation considered.
Polymet treats the surface and bedrock pathways separately. The bottom of the surficial
aquifer is treated as an impermeable boundary, effectively separating the surficial aquifer flow
paths from the bedrock flow paths in the model (p 105). This is based on Polymets
underestimate of bedrock conductivity. Polymet claims that by preventing mass from entering
bedrock flow paths causes the mass to reach the evaluation points more quickly because
allowing mass to enter the bedrock would slow the transport. This is most likely incorrect
because the porosity in the bedrock is lower and the actual groundwater particle velocity is
likely higher. If the model accurately accounted for the preferential flowpaths in the bedrock
(Siegel and Ericson 1981), modeling flow through the bedrock would cause it to reach
evaluation points more quickly.
11
Contaminants move along the flow paths by advection and dispersion. Dispersion is based on
cell length. Goldsim models dispersion numerically, with flow containing a constituent load
instantaneously dispersing through the entire cell. This means the load would be dispersed
evenly through the volume of a downstream cell. The Goldsim manual, cited in Polymet,
specifies that it is common to set the dispersion length equal to one-half of the cell length. This
led to Polymet using 42 cells approximately 23.6 m in length (p 114). The time step for the
mine site was one month (Polymet 2013c, p 15) which bears no relation to the length of model
cells and dispersion. The process of dispersion in the Goldsim model, by instantaneously
spreading contaminant through a cell, differs from actual dispersion by which contaminants
disperse continuously through the entire domain. If the time step used in Goldsim is
significantly shorter than the time normally required for contaminant to disperse over that
distance, it may be moving contaminant too quickly which would dilute the contaminant.
Alternatively, if the time step is longer than the actual dispersion time, it might slow transport.
While this simplification within Goldsim is an inaccuracy, whether it biases the results toward
faster or slower transport or higher or lower concentrations depends on how the cell length
and time step compares to actual dispersion time as described above. As described, with 42
cells it will require 42 time steps for breakthrough of contaminants from the upstream end of
the pathway to reach the discharge point at the river, although the breakthrough concentration
may be extremely low.
The concentration at the downstream end depends on the routing of contaminants through 42
sets of steady state flow and balance equations (one set for each cell). Dividing the flow paths
in the Polymet model (Figures 1 and 2) into 42 cells makes apparent that the width is much
larger than the length. The load entering the cell disperses uniformly through the cell,
therefore the lateral dispersion in each cell is much greater than longitudinal dispersion. This is
not in keeping with reality because the lateral and vertical dispersion is usually 0.2 and 0.1
times the longitudinal dispersion. This excessive horizontal dispersion dilutes the contaminant
along its pathway more than would be estimated with standard transport equations (Fetter
1999). This would inappropriately dilute the estimated concentration for contaminants arriving
at the monitoring points or the river.
Goldsim Simulation of Mine Facilities
The efficacy of the proposed mine depends on the engineered solutions working as designed
and on the assumptions used in the Goldsim modeling manifesting as assumed. The
engineering designs are discussed elsewhere. The following section discusses aspects of the
Goldsim modeling and Polymets application of it. Following that are two sections concerning
specifics of modeling sulfate and copper transport through the mine site. A necessary
conclusion is that the assumptions about the engineering, geochemistry, the hydrology, and the
12
geological conceptualization combine to provide predictions suggesting that the project will not
degrade waters.
Seepage through a waste stockpile is a function of the stockpiles water balance, which is
considered steady state by time step. Seepage is the difference between meteoric water at the
top of the pile, evaporation, runoff and infiltration. The water balance of waste rock stockpiles
(p 81) does not include storage. Rather the model assumes that all water entering the stockpile
during a year also exits it. Monthly climate and soil properties are chosen randomly. By not
considering storage, the model does not allow water to accumulate so that large amounts could
seep all at once. By ignoring the autocorrelation of climate among months and antecedent
conditions, the model also ignores the potential additional seepage that would occur during
subsequent wet months. Both assumptions decrease the amount of water available to seep
through the waste stockpiles. The assumption could limit the effect of high precipitation
years, when leftover storage from the preceding year combines with infiltration during the
current year to cause a larger of water reaching the liner or containment system.
The method for modeling evapotranspiration (ET) from bare and reclaimed stockpiles does not
appear to be correct). The document says they need to represent the mean fractional
evapotranspiration for the stockpiles throughout time and across the entire stockpile footprint
(p 81), therefore they need a distribution for the uncertainty in the mean of the entire
population (as opposed to the uncertainty in the range of possible observed values) (p 82).
They select a single fractional value of ET as a proportion of annual precipitation for use
through the entire simulation, whether wet or dry year. There is no consideration to ET being a
higher proportion of precipitation during dry years and also may evaporate more water during
wet years. This could limit the amount of infiltration by losing more precipitation to ET during
wet years. The data used to analyze the variability shows that the amount of precipitation that
becomes ET varied substantially from year to year (Table 5-4), with the highest precipitation
year (1982) not having the lowest proportion lost to ET. This means that ET is not simply a
function of water availability and assuming that a set fraction of annual precipitation becomes
ET introduces an error into the simulation. The better way to model this would be to select an
ET proportion from the observations using the sample rather than population standard
deviation.
Flow to/from Pits
Polymets model accounts for mine dewatering as part of the water balance for the two pits.
Their MODFLOW modeling was used to determine groundwater inflow to the pits. Figure 6-12
below is an example of the water balance simulated in the West Pit during year 14. The
13
groundwater inflow, 55 gpm, is a small fraction of the overall amount of water removed from
the plant (313 gpm). Table I-22 lists the groundwater inflows, which do not exceed 100 gpm at
any time. Figure 5-10 shows the log-normal distribution that Polymet applies to the estimate of
pit flow, during year 14 the range would be from about 75% to 200% of 55 gpm. Myers (2014)
estimates are substantially higher because of the higher K in the bedrock.
14
During reclamation, the groundwater inflows to the West Pit are similar. The largest natural
source is pit wall runoff, with rates of about 270 gpm for about 15 years. The largest inflow
simulated by Polymet was pumping into the pit from either the WWTF or untreated from the
Plant Site at rates up to 900 gpm. Myers (2014) found this pumping may increase loads in the
groundwater, but Polymets method of modeling flowpaths precludes including this if the
modeler does not specifically include it. Polymet (2013) assumes that discharge into
groundwater begins when the water level rises above the bedrock into the surficial aquifer.
The discharge into the surficial aquifer ranges from 3.1 to 6.4 gpm (Polymet 2013, p 160). Into
bedrock, Polymet considers two flow paths and the total range is from .03 to .08 gpm. This low
flow rate into bedrock reflects Polymets extremely low conductivity estimate, but it is also
incorrect as reviewed above and simulated by Myers (2014).
This flow is the discharge into the upper end of the flowpaths and therefore controls the load.
It demonstrates one way that Polymets modeling limits the load reaching the groundwater
flow paths. If the discharge into the aquifers is significantly wrong, the load is wrong and the
transport calculations yield a value that is too small. Simulating a probability distribution for the
discharge is not a substitute for calculating the load. Polymet should complete a more realistic
analysis of flow from the West Pit into the groundwater.
15
Inflow to and from the pits should be determined as a function of depth using MODFLOW and
then adjusted for uncertainty based on a probability distribution. The basis for this distribution
should be described. If it is to be legitimate, it should be determined using a stochastic
simulation within MODFLOW.
Results for Sulfate
Polymets simulations estimate that sulfate concentrations entering the river are mostly
constant through the entire simulation, as shown on their figure K-03-24.2 and K-04-24.2 for
the no action and the project alternatives for stations SW004 and SW004a. The primary change
in concentration at points downstream from SW004a is due to the discharge from the WWTF
which has a specified concentration. At SW004a (Figure K-04-24.2) for example, the
concentration with the project at P90 is slightly less than the no action alternative presumably
due to the dilution by the discharge from the WWTF. A similar effect occurs at all of the
stations from SW004a to Colby Lake.
16
Figure M-03-24 for SW004 shows that natural groundwater flow, runoff, and dewatering
discharge from Peter Mitchell is 99% of the total SO4 load, between 50 and 55 tonnes/yr for the
entire 200-yr simulation period. Further downstream, the WWTF contributes a small but
consistent load of less than 10 tonnes/yr. The total load increases as background RO and
groundwater increases. In other words, most of the load simulated by Polymet to be in the
lower river is already there, with the WWTF load representing only a few percent of the total
load at SW006. The load simulated as contributed by the mine is on the order of tonnes per
year or only a few percent of the natural load. River concentrations are very near the
background groundwater concentrations which are shown below. Again this reflects the fact
that natural conditions control the simulated concentrations in Polymets modeling.
17
The lack of mine-induced SO4 in the river occurs even though the mine adds very significant
SO4 loads to the system. Considering the East Pit only, over 30,000 tones are added during
year 11 from backfilling category 4 waste rock. By year 22, over 50,000 tones have been added
18
just to the East Pit from various sources as shown in Figure 1-01-24.1. This load obviously does
not reach the river, so the question is where does it go?
Polymets Figure 6-41 shows the median East Pit SO4 concentration reaches 2600 mg/l for a
couple years after the Cat 4 waste rock loading but falls afterward even with the continued
loading. This upper limit is due to the concentration caps that Polymet assumes it can attain by
controlling the pH to between 6.0 and 7.5 (Polymet 2013). They would do this by adjusting the
pH of the WWTF effluent, lime/limestone addition or other adaptive water quality management
strategies (p 185). Their modeling assumes the caps will work perfectly, but it is important to
question what must be done to make the assumption realistic. The addition of lime/limestone
and proper mixing would have to occur during the initial backfill. Inadequate mixing could
result in volumes of waste with much higher SO4 concentrations. Theoretically, lime could be
injected through injection wells after backfilling, but this has not been proposed nor shown to
be possible. The same applies to the adding of WWTF effluent to keep the waste saturated it
would have to be mixed thoroughly into the waste which would require multiple injection wells
into the backfilled waste rock to thoroughly mix the amending water. The modeling assumes
they would get perfect mixing of both WWTF effluent or lime/limestone, but in practice this is
much more difficult than assumed in Polymets simplified modeling.
19
Polymets reliance on optimistic engineering and modeling assumptions continues during the
reclamation period. Concentrations of many constituents in the East Pit porewater change
significantly due to the extraction and treatment of the porewater in the WWTF (p 187).
They consider the reclamation period as beginning when the East Pit wetland is completely
flooded and [ending] when the sulfate concentration in the backfill porewater is brought to 250
mg/l (Id.). This is expected to occur between years 25 and 60 with an average of year 36. It is
not totally clear, but it appears that Polymet will pump water from the pit, treat it, and
discharge it elsewhere. The SO4 load to the WWTF during this period as shown in Figure H-15-
24.2 reflects this probable source. Their estimated SO4 loading to the East Pit beyond year 20
does not include any WWTF return flow or a load from the backfilled waste rock (Figure I-
01.24.2 below). This means they are accounting for no load from any water added to the pit to
keep it saturated but they are assuming the pit remains saturated so there is no continued
oxidation. It appears therefore that Polymet is missing two large components of load to the
East Pit.
20
The plan appears to be to pump water from the pit to treat it but to keep the backfill in the pit
saturated at the same time, presumably by pumping water back into the pit. The Adaptive
Water Management Plan (Table 2-1) calls for pumping c1750 gpm from the East Pit to the
WWTF during reclamation for treatment. This pumping rate is approximately four times the
21
pumping rate used to dewater the pit, therefore the pumping alone would obviously dry the pit
and desaturate the backfill. However, they assume that the submerged waste rock backfill
contributes no additional load to the porewater during [years 22 through the end of East Pit
reclamation] because it is completely subaqueous (p 187) and its load is being removed via
pumping for treatment in the WWTF (Id.). The Adaptive Water Management Plan claims that
during reclamation WWTF effluent will be pumped to the East Pit to maintain water levels (p
16). Essentially, they assume and model that the combination of pumping from the WWTF and
the percolation of meteoric water would counter the pumping of 1750 gpm and allow the
backfill to remain saturated. Polymet presents no plan as to how this would work in practice
even though it underpins their modeling.
It may not be possible to pump at this rate from the backfilled waste because of its conductivity
and because relatively impermeable bedrock surrounds the pit. This has to be considered
seriously along with all of the other things Polymet promises to capture and treat. While
theoretically possible to simultaneously remove and return 1750 gpm to the pit for many years,
there is no guarantee that the backfill would remain saturated. Flow through it would choose
preferential flow paths and some areas may actually be unsaturated. Once the removed water
reaches its treatment goal and all pumping ceases, groundwater flow through the pit may flush
oxidation products from areas that had not accessed by the pumping. Additionally, because
these potential loads to the East Pit are not considered in the modeling, Polymets predictions
of time for the porewater to be treated to a given level could be gross underestimates. Myers
(2014) simulated a pump and treat scenario for the East Pit and found that concentrations at
various points in the backfill would be highly variable and in some areas would exceed the
target even 100 years after the end of mining.
Polymet appears to rely on the pit being a sink that prevents constituents from flowing into
surrounding groundwater. Because they are keeping the pit full of water even while pumping
from it, there may be gradients allowing flow from the pit to the surrounding groundwater.
Polymet should describe at some place in the SDEIS how this would work in practice and
consider what could happen if it does not work. Myers (2014) modeling does consider flow
through the pit and shows that loads begin to reach the river after 50 to 80 years. A similar
condition occurs during operations from year 11 to year 22, although water escaping from the
East Pit may reach the West Pit due to continued dewatering there. Concentration graphs of
simulated monitoring wells in the Central Pit and Cat 4 stockpile (after year 11) in Myers (2014)
confirms this movement. There are no similar graphs in Polymets work, so it is difficult to
know where the massive SO4 load actually goes.
22
Results for Copper
The background groundwater concentrations for copper range to about 10 ug/l, as discussed
above and shown on Polymets Large Figure 17. Figure K-04-13.2 shows that modeled Cu
concentrations rarely exceed 3 ug/l, which is significantly less than the standard. The slight
increase occurring at year 40 for the Project is probably due to WWTF discharge to the river.
The river concentration is less than observed in the groundwater but about what is observed at
SW004, with substantial variability.
The copper load to the East and West Pits, shown in Figure I-01-13.1 and I-02.13.1, are two
examples of substantial loads added to the system that do not apparently make it to the river at
all. Cu is pumped from the East Pit, as described above for SO4.
23
24
Polymet may assume that Cu is pumped from the East Pit during reclamation, but the pumping
into the West Pit to fill it causes a gradient away from the pit and drives a load from the pit into
the surrounding groundwater. Sorption as modeled by Polymet is the primary factor
preventing Cu from reaching the river (Myers 2014).
Polymets model treats Cu sorption as deterministic, meaning they do not examine any scenario
except for full sorption. They do not model any of the factors which could affect sorption, such
as pH, contact time, or the relative particle surface areas. As found by Myers (2014), if
sorption does not occur or occurs in a much smaller amount, Cu will reach the river at rates
which could violate the standard.
In addition to the engineering features, Polymets assumed sorption essentially prevents any
Cu from the mine from reaching the river. They have not justified that this will occur nor test
what could occur if their assumptions are wrong.
Summary
Polymets modeling is the basis for the water quality predictions made in the SDEIS. The
modeling is simplified to a one-dimensional system, either along flowpaths or along the river
channel. Uncertainty is considered by treating all non-deterministic inputs or parameters as a
probability distribution. The model, completed using the Goldsim platform, has many
conceptualization issues that indicate that its simulations may oversimplify the system. Several
assumptions implemented in the Polymet model, both about the modeling and the engineering
25
of the site, combine to yield predictions that there will be effectively no water quality impact
caused by this proposed mine. Predicted concentrations at the various surface water locations
show that the project does not increase concentrations much compared with the no action
alternative. The load at these locations tend to be from natural runoff, natural groundwater,
and from dewatering discharge at the Peter Mitchell Pit much more than from the proposed
Northmet. The following are specific comments on the modeling or the results of the
modeling:
1. The model assumes that all waste rock covers, liners, and containment systems will work
perfectly. The probability distributions do not account for substantial failures. If the seepage
through one or more stockpiles is double that planned, there would be substantially higher load
reaching the rivers.
2. The model assumes sorption for four contaminants, including copper, which causes the model
to predict that effectively none of the contaminant reaches the river. This sorption occurs even
though the high background load continues to flow to and discharge into the river.
3. The model assumes that plans to keep backfilled waste in the East Pit saturated during
operations and to pump and treat it during reclamation will prevent all contaminants from
escaping the pit and reaching the river. This is a very optimistic. Polymet should analyze a
scenario which does not rely on this assumption.
4. The modeling does not consider two loads to the East Pit the load from pumping water from
the WWTF to the pit to keep it saturated during reclamation and the load caused by oxidation of
backfill if perfectly saturated conditions are not maintained.
5. Pumping the West Pit full of water causes a mound which allows water and contaminant load to
escape and flow from the pit to downgradient groundwater.
Myers (2014) presented an alternative model that was more physically realistic than Polymets.
The agencies should consider how the realistic modeling completed by Myers (2014) differed
from Polymets and give particular consideration as to whether Polymets modeling was
physically realistic. The agencies should further consider that Polymets modeling includes
assumptions that prevent much of the transport that may actually occur. The agencies should
ultimately reject the results of Polymets modeling and require them to complete more
physically and conceptually realistic models
References
Anderson MP, Woessner WW (1992) Applied Groundwater Modeling: Simulation of Flow and
Advective Transport. Academic Press
Barr Engineering (Barr) (2006a) RS 02 Hydrogeological Drill Hole Monitoring and Data
Collection Phase 1, Hydrogeologic Investigation Phase I, PolyMet NorthMet Mine Site, RS -
02. November 16, 2006
26
Barr Engineering (Barr) (2006b) RS 10 Hydrogeological Drill Hole Monitoring nd Data
Collection Phase 2, Hydrogeologic Investigation Phase II, PolyMet NorthMet Mine Site, RS -
10. November 16, 2006
Fetter CW (1999) Contaminant Hydrogeology, 2nd Edition. Prentice-Hall.
Freeze RA, Cherry JA (1979) Groundwater. Prentice Hall, Englewood Cliffs, NF.
Myers T (2014) Groundwater Flow and Transport Modeling, NorthMet Mine and Plant Site.
Prepared for the Minnesota Center for Environmental Advocacy.
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Site, Version 11. March 8, 2013.
Schulze-Makuch, D., D.A. Carlson, D.S. Cherkauer, and P. Malik. 1999. Scale dependence of
hydraulic conductivity in heterogeneous media. Ground Water 37, no. 6: 904-919.
Siegel DI, DW Ericson (1981) Hydrology and Water Quality of the Copper-Nickel Study Region,
Northeastern Minnesota. US Geological Survey Water-Resources Investigations 80-739 Open
File Report. St Paul MN