Ed Hathaway
Bill Lovely
US EPA, Region 1
Mail Code SEE
1 Congress Street, Suite 1100
Boston, MA 02114-2023


April 2002

Re: Elizabeth Mine, Strafford and Thetford, Vermont
Environmental Evaluation and Cost Analysis and Proposed Plan

Dear Ed and Bill:

Thank you for the opportunity to comment on the Environmental Evaluation and Cost Analysis and Proposed Plan.

We applaud you for all that you have done over the past two years to address the issues we have raised.

The ten groups represented on the Elizabeth Mine Community Advisory Group (EMCAG) all support the initial phases of EPA’s preferred alternative. Eight of the ten groups support the preferred alternative in its entirety.

We all share an interest in cost containment. We understand that it is likely that the cover over TP-1 will be necessary to prevent the continued contamination of the West Branch of the Ompompanoosuc River (WBOR)—especially the manganese and iron. However, we very much appreciate the flexibility you have built in to the preferred alternative, and understand that the final decision as to whether or not a cover system is necessary -- and the configuration of the cover system -- will not be made until comprehensive modeling and bench scale testing has been conducted.

Citizens for a Sensible Solution and the Strafford Planning Commission representatives support the removal and encapsulation of most of TP-3, surface water diversion, and erosion control. They expressed the hope that testing will demonstrate that the cover over TP-1 and the proposed water treatment systems will not be necessary. These two groups also believe that the cleanup goals are unrealistic, and that the state and EPA should develop a way to waive the Water Quality Standards and allow for a mixing zone in the WBOR.

While we understand that TP-3 contributes a large part of the contamination, we hope that creative preservation techniques for preserving a small part of this area in situ (including constructing a roof over a part of the heap leach piles) will be given careful consideration.

We also strongly support your proposal to look for onsite sources of common borrow, so that traffic impacts to the community are minimized.

We are attaching copies of recent comments from our technical consultants Richard Downer and Woody Reed.

Again, we thank you for your extraordinary commitment to hearing and addressing our community’s concerns. We look forward to continuing to work with you.

Sincerely,


Roderick Maclay, Chair
Elizabeth Mine Community Advisory Group

ELIZABETH MINE COMMUNITY ADVISORY GROUP
Tom Essex (802) 765 4118

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