Resource Development Council

RDC Comment Letter:
Pogo Mine NPDES Permit

November 26, 2010

Cindi Godsey, Environmental Protection Agency
Tim Pilon, Alaska Department of Environmental Conservation

Re: Reissuance of EPA NPDES permit and certification by State of Alaska for the Pogo Mine

Dear Ms. Godsey and Mr. Pilon:

The Resource Development Council for Alaska, Inc. (RDC) writes to express support for the reissuance of a National Pollutant Discharge Elimination System (NPDES) permit to the Pogo Gold Mine, as well as the certification of the permit by the State of Alaska under the Alaska Pollutant Discharge Elimination System (APDES).

RDC is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

The Pogo Gold Mine began operating in 2006 and has a projected 10-year mine life. Ore is processed onsite, with a budgeted 920,000 tons to be processed in 2010. Gold is acquired through a gravity recovery and flotation concentrate process in which all mill process water is recycled. A portion of the tailings are added to cement to form a paste and placed underground as backfill, and any remaining tailings are dewatered and placed in a drystack.

Water discharged at Pogo includes only mine drainage from the underground mine workings and surface runoff. The water first goes through a water treatment plant at the mill site, then is piped to a newly-installed, specialized treatment plant before it flows into the Goodpaster river. Consistent, thorough monitoring of the discharged water at several locations in the area has shown it to be within the limits set forth in the originally issued NPDES permit.

The Pogo Mine employs over 300 workers and provides for another 100 contractor jobs. They have made large advances towards increasing worker safety, with a 50% reduction in reportable incidents in 2009. Moreover, employee retention has greatly improved, with turnover having been reduced by 50%, providing for more experienced, knowledgeable staff. Also of great importance are the efforts made to reduce reportable spills at the mine site, resulting in a 55% reduction in the past year. Therefore, RDC wholeheartedly supports the reissuance of the Pogo Mine NPDES permit and the State of Alaska certification.

Thank you for the opportunity to comment on this important issue.

Resource Development Council for Alaska, Inc.