Bonita Peak CAG 2/28/2019 Peter Butler, Ph.D. Draft IRAP Summary - PowerPoint PPT Presentation

Bonita Peak CAG 2/28/2019 Peter Butler, Ph.D.

Draft IRAP Summary   Addresses 26 Sites Out of 46 Sites and Two Study Areas.  Actions Are Interim; More May Be Done at these Sites.  Adaptive Management Approach.  Enables Early Actions at Multiple Sites to Speed Up Process.  Smaller Sites, Generally Privately Owned.  No BLM Owned Sites; One at least Partly Owned by Forest Service.

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Five Possible Alternatives   A. Move Mine Drainage Away from Mine Waste – 20 sites.  B. Divert Upland Flow around Mine Waste. – 11 sites.  C. Remove Sediment from Ponds Treating Drainage – 8 sites.  D. Remove In-Stream Mine Waste – 2 sites.  E. Cover Recreation Sites with Human Health Risk – 5 sites.

An Example of Costs   Alternative A – Diversion/Isolation Total Capital Cost: $1,082,000  Total Annual O&M Cost (15 years): $1,890,000  Total Periodic O&M Cost (15 years): $301,000   Total Alternative Cost (PV): $2,411,000  ---------------------------------------------------------  Total Capital Cost A+B+C+D= $3.8 million.  Total Present Value Cost A+B+C+D= $8.3 million.

Concerns in Comments   High Costs – Possible Double Counting .  A. Divert Drainage – Capital Cost: $55,000/site; Total PV: $120,000/site.  B. Divert Stormwater - Capital Cost: $91,000/site; Total PV: $173,000/site.  C. Excavate Sediment - Capital Cost: $175,000/site; Total PV: $425,000/site.  D. In-Stream Waste - Capital Cost: $170,000/site; Total PV: $312,000/site.

Lack of Estimated Benefits   Lots of Water Quality Data Showing Toxic Metal Concentrations.  No Estimates of Possible Metal Reductions at Sites.  No Estimates of How Sites Are Affecting Water Quality in Nearby Streams.  No Estimates of How Alternatives Will Improve Aquatic Life.

Lack of Prioritization   No Prioritization between Sites in IRAP .  Costs Should Be Allocated by Site Not Alternative.  Estimate Metal Reductions per Unit Cost (Biggest Bang for the Buck).  No Prioritization with Other Possible Projects .  Compare Cost/Benefit to Doing Additional Work at Some Sites vs. BMP’s at All Sites.  Compare Cost/Benefit to More Fully Using Treatment at Gladstone.

Adaptive Management   Theoretically, Could be Quite Useful.  Need to Estimate Costs and Benefits of Action, Implement Action, Compare Actual Costs and Benefits to Estimated.  So Far, No Estimates of Benefits and No Plan or Dollars Allocated for Analysis after Interim Action Implementation.  Potentially Responsible Parties (PRP’s) Don’t Like Uncertainty of Adaptive Management.

Questions? 