Tailings Disposal Facility Expansion

Final Environmental Impact Statement

and

Record of Decision

Volume I

Tongass National Forest

Admiralty Island National Monument, Juneau, Alaska

 

United States Department of Agriculture

Forest Service 

R10-MB-744c September 2013

Greens Creek Mine
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Greens Creek Mine

Tailings Disposal Facility Expansion

Record of Decision

United States Department of Agriculture, Forest Service Alaska Region

Lead Agency: USDA Forest Service

Tongass National Forest

Responsible Official: Forrest Cole, Forest Supervisor 

Tongass National Forest 

Federal Building 

Ketchikan, Alaska 99901 

For Information Contact: Chad VanOrmer

Monument Ranger

Admiralty Island National Monument 

8510 Mendenhall Loop Road

Juneau, AK 99801 

Abstract

The Responsible Official, Forrest Cole, the Forest Supervisor of the Tongass National Forest, has 

made a decision regarding the proposed Greens Creek Mine Tailings Disposal Facility Expansion. 

His decision is based on the project's Final Environmental Impact Statement. The Forest 

Supervisor has selected Alternative D, with modifications as described in this Decision. The 

primary modification is to delete construction of a second tailings facility in the Fowler Creek 

watershed. Alternative D Modified, also referenced as the Selected Alternative, authorizes Greens 

Creek Mine to expand the existing tailings disposal facility further south into Admiralty Island 

Monument by about 18 acres, which adds approximately 2.1 million cubic yards of storage 

capacity to the facility. An additional 8 acres is authorized to be developed outside of the 

Monument for rock quarry and reclamation material storage sites and expanding an existing water 

management pond. At the expected rate of tailings disposal, the expansion extends the time at 

which the facility will reach its capacity by approximately 10 years. The Selected Alternative 

does not authorize the Hecla Greens Creek Mining Company to dispose of tailings in any part of 

Tributary Creek classified as Class I or Class II fish habitat, and it does not authorize construction

of a second tailings disposal facility. Selecting a modification of Alternative D does not preclude 

the future consideration or selection of any of the action alternatives considered in this 

environmental impact statement in the event of future National Environmental Policy Act 

decisions.
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Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪1

Record of 

Decision 

Greens Creek Mine 

Tailings Disposal Facility Expansion 

USDA Forest Service 

Admiralty Island National Monument 

Tongass National Forest Alaska 

SUMMARY 

The Forest Service prepared the Greens Creek Mine Tailings Disposal Facility Expansion 

Final Environmental Impact Statement (EIS) to analyze the potential impacts of increasing 

the capacity of the Greens Creek Mine to dispose of additional tailings and waste rock. 

The EIS complies with the National Environmental Policy Act (42 United States Code 

[U.S.C.] 4321 et seq.) (NEPA), the Alaska National Interest Lands Conservation Act (16 

U.S.C. 431 note), the National Forest Management Act of 1976, and all other applicable 

Federal and State laws and regulations. This Record of Decision (ROD) describes the 

Forest Supervisor’s decision to approve an expansion of the existing Greens Creek mine 

tailings disposal facility. The decision is based on the EIS and the entire project record. 

The Forest Supervisor has selected Alternative D, with modifications described in this 

Decision. The primary modification is to delete construction of a second tailings facility 

in the Fowler Creek watershed. Alternative D Modified, also referenced in this Decision 

as the Selected Alternative, authorizes the Greens Creek Mine to expand the existing 

tailings disposal facility by about 18 acres, further south into the Admiralty Island 

National Monument. An additional 8 acres is authorized to be developed outside of the 

Monument for rock quarry and reclamation material storage sites and expanding an 

existing water management pond. The capacity of the facility will be expanded by about 

2.1 million cubic yards. At the expected rate of fill, the ability of the facility to accept 

additional tailings will be extended by approximately 10 years, from 2019 to 2029. No 

tailings will be deposited in the sections of Tributary Creek that are classified as Class I or 

Class II fish habitat. The Selected Alternative does not authorize construction of a second 

tailings disposal facility in the Fowler Creek watershed as described in Alternatives C and 

D of the Final EIS. Adopting a modification of Alternative D as the Selected Alternative 

does not preclude the future consideration or selection of any of the action alternatives 

considered in this EIS, or other new feasible alternatives that may arise, through future 

NEPA processes. 
2 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

PROJECT AREA 

Figure 1 shows the project area and vicinity. 

Figure 1. Project Area and Vicinity Map 

 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪3

DECISION 

This ROD documents my decision to implement Alternative D from the Greens Creek 

Mine Tailings Disposal Facility Expansion Final EIS, with four modifications: 

 Delete construction of a second tailings disposal facility in the Fowler Creek 

watershed. The second facility was not included in Alternatives B and B 

Modified, so this change is within the range of alternatives analyzed in the Final 

EIS. 

 Delete the expansion of the existing tailings disposal facility by 7.2 acres to the 

northeast, into the Cannery Creek watershed. This expansion was not included in 

Alternative B, so this change is within the range of alternatives analyzed in the 

Final EIS. 

 Avoid expanding the existing reclamation material storage site within Admiralty 

Island National Monument and add a 4.8-acre reclamation storage site near the 

junction of the A Road and the B Road, as displayed in Alternative B Mitigated. 

This change is within the range of alternatives analyzed in the Final EIS. 

 Delete the West Road from the camp site to the new rock quarry within the 

perimeter of the existing tailings disposal facility, and adding a much shorter (160 

- foot) road within the perimeter to provide access to the rock quarry. Because the 

new road is not within an inventoried roadless area, and the net effect of this 

change is to reduce the amount of new road construction, the effects are within the 

range of those disclosed in the Final EIS. 

With these four changes, Alternative D Modified is referenced throughout this document 

as the Selected Alternative. 

The Selected Alternative is nearly equal to Alternative D figures shown in Appendix E of 

the FEIS, showing years 1-10 of Alternative D, allowing the Hecla Greens Creek Mining 

Company to expand the existing tailings disposal facility further south into Admiralty 

Island National Monument by about 18 acres (ROD, Figure 2). An additional 8 acres is 

authorized to be developed outside of the Monument for rock quarry and reclamation 

material storage sites and expanding an existing water management pond. The Selected 

Alternative expands the facility’s capacity by about 2.1 million cubic yards, which will 

delay the time at which the capacity is reached by approximately 10 years, from 2019 to 

2029 at the expected rate of fill. No tailings will be deposited in those sections of 

Tributary Creek that are classified as Class I or Class II fish habitat, and a second tailings 

facility will not be constructed. 

The total effects of the Selected Alternative are far less than those associated with any of 

the action alternatives analyzed in the Final EIS, because the Selected Alternative would 

disturb only one-fifth to one-third of the total acreage affected by any of the action 

alternatives. The effects to the Monument will be nearly identical to those described in 

Alternative D, and the total impacts to wetlands, wildlife, aquatics, and other resources are 

less than for any of the action alternatives. 

 
4 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

Figure 2. Selected Alternative 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪5

Components of the Selected Alternative include: 

 Expansion of the existing tailings disposal facility (TDF) southward into the 

Monument; 

 Development of a reclamation material storage area near the junction of the A and 

B roads, outside of the Monument; 

 Development of a rock quarry north of the existing TDF, and access from within 

the existing facility, outside of the Monument; 

 Development of a new water management pond south of the existing TDF and 

expansion of existing water management ponds; and 

 Relocation of the B road and truck wheel wash facility to accommodate the TDF 

expansion. 

ALTERNATIVES CONSIDERED 

The development of alternatives is described in Section 2.2 of the Final EIS. Alternatives 

were developed to respond to the four significant issues identified by the public during the 

NEPA scoping process, including water quality, wetlands, fish habitat, and protection of 

Admiralty Island National Monument. 

Alternatives Considered in Detail, Including the NoAction Alternative 

Four alternatives were analyzed in detail in the Draft EIS, as well as several possible 

mitigation measures that could be applied to the Proposed Action, Alternative B. To 

provide additional clarity regarding the choices to be made, the Final EIS includes a fifth 

alternative, Alternative B Mitigated, which includes the mitigation measures described in 

the Draft EIS. All alternatives except Alternative A (the No-Action Alternative) respond 

to the purpose and need for the project. The five alternatives analyzed in detail are 

described below: 

Alternative A, the No-Action Alternative. This alternative is the existing condition. 

Alternative A would not allow any expansion of capacity to store tailings at Greens Creek 

Mine. Based on revised information provided by Hecla Greens Creek Mine during 

preparation of the Final EIS, the existing tailings disposal facility would reach its capacity 

in 2019, at which time the Greens Creek Mine would have to cease operations. Under this 

alternative, when the mine is closed, Greens Creek Mine will cover the tailings facility 

with an engineered cover designed to support local vegetation and to limit the ingress of 

water and oxygen into the tailings below. The cover will substantially limit the 

development of acid rock drainage from the tailings. Greens Creek will be responsible for 

collection and treatment of water from the tailings disposal facility for at least a hundred 

years, perhaps in perpetuity. 

Alternative B, the Proposed Action. This alternative was developed by Greens Creek 

Mine to facilitate long-term planning and avoid piecemeal permitting. Alternative B 

would expand the actual footprint of the currently authorized tailings pile by 54 acres, all 
6 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

of which would be within Admiralty Island National Monument. Total new disturbance, 

including the tailings and ancillary facilities such as reclamation materials storage, 

quarries, water storage ponds, and other facilities, would be 116 acres, 100 acres of which 

would be within the Monument. When added to the 65-acre currently authorized facility, 

the tailings disposal facility would occupy 181 acres at full capacity under Alternative B. 

Alternative B would raise existing capacity by 14.2 million cubic yards, the equivalent of 

30-50 years of additional operations at current production rates. This alternative would 

maximize efficiency by incorporating the tailings infrastructure in one location. 

Moreover, for any given capacity, a single tailings pile also has the smallest overall 

footprint due to basic geometry; because the sides of the pile are limited to a given slope 

angle to maintain stability; the larger the base of the pile, the higher it can be built. On the 

other hand, this alternative would expand the tailings disposal facility further into the 

Monument. In addition, at full capacity the facility described under Alternative B would 

cover approximately 4,000 feet of fish habitat in Tributary Creek, including 1,646 feet of 

habitat for anadromous fish such as salmon (referred to as Class I habitat), and 2,400 feet 

of habitat for non-migratory resident fish (referred to as Class II habitat). The closure 

scenario of the Alternative B is the same as for Alternative A: Greens Creek will construct 

an engineered cover as well as collect and treat water from the facility for at least 100 

years after closure, perhaps in perpetuity. 

Alternative B Mitigated. This alternative was developed by the Forest Service to display 

how impacts to Admiralty Island National Monument could be reduced. Alternative B 

Mitigated includes several features that were described in the Draft EIS as mitigation 

measures that could be applied to the Proposed Action. Alternative B Mitigated would 

expand the existing tailings disposal facility to provide 14.2 million cubic yards of 

additional tailings disposal capacity, equivalent to 30-50 years of additional operations, 

the same level of expansion as under Alternative B. Under Alternative B Mitigated, 

however, some of the expansion would be to the northeast into the Cannery Creek 

watershed outside the Monument, so that an equal increase in capacity could be achieved 

while reducing the expansion into the Monument by 31 acres as compared to Alternative 

B. The effects on Class I fish habitat in Tributary Creek would be the same under 

Alternative B Mitigated as under Alternative B; 1,646 feet of such habitat would be 

covered with tailings. The effects on Class II habitat would be about half under 

Alternative B Mitigated than under Alternative B: 1,169 feet of such habitat would be lost 

due to tailings placement. The size of the lease boundary for the full build-out 

encompasses 167 acres. Under this alternative, ancillary facilities such as reclamation 

material stockpiles and rock quarries and borrow sources are located north of the existing 

facility, out of the Monument. This alternative would disturb fewer acres of the 

Monument, but still contain all tailings and related infrastructure in a single facility. The 

closure and post-closure requirements of this alternative are the same as those of 

Alternatives A and B. 

Alternative C. The Forest Service developed this alternative to display the effects of 

minimizing further development in the Monument beyond what is already authorized. 

Alternative C would require construction of a second tailings disposal facility located at 

2.6 Mile on the “A” Road, which is outside the Monument and about 3 miles north of the 

current facility. Under this alternative, Greens Creek Mine would have approximately 5 

years of additional capacity at the current facility, allowing the company time to complete 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪7

engineering and permitting work, then build the new facility and widen the “A” Road to 

accommodate heavy haul traffic. Alternative C would meet the purpose and need of 

granting the equivalent of 30-50 years of additional tailings disposal capacity, but about 

25-45 years of that capacity, or 13.2 million cubic yards of tailings, would be located at 

the second facility. An additional 2.3 acres of Monument land would be disturbed, and 

the total area occupied by both facilities would be 224 acres. At closure, each tailings 

disposal facility would be capped using the same engineered cover design as described 

above under Alternatives A, B, and B Mitigated. Greens Creek Mine would also be 

required to collect and treat water from the tailings facilities for at least a hundred years 

after closure, perhaps in perpetuity. Under Alternative C, untreated contact water from 

the second location would be pumped back to the existing water treatment plant – a 

distance of about 3 miles -- and discharged through the currently permitted marine outfall. 

Alternative D. The Forest Service developed Alternative D to consider ways to avoid 

filling any part of Tributary Creek with tailings. Like the other action alternatives, this 

alternative would provide about 30-50 years of additional tailings disposal capacity. 

Alternative D was designed to incorporate the efficiency of a single facility as much as 

possible by expanding the existing facility to the south, further into the Monument, by 

about 23 acres. Alternative D would also expand the existing facility to the northeast, into 

the Cannery Creek watershed, by 7.2 acres. Alternative D would expand the capacity of 

the existing facility by about 3 million cubic yards, the equivalent of 10-15 years of 

tailings disposal. Greens Creek Mine would construct a second facility, located at 2.6 

Mile on the “A” Road, rather than fill any portion of Tributary Creek with tailings. The 

total area occupied by both facilities would be 245 acres. Greens Creek Mine would also 

be required to collect and treat water from the tailings facilities for at least a hundred years 

after closure, perhaps in perpetuity. Under Alternative D, untreated contact water from 

the second location would be pumped back to the existing water treatment plant – a 

distance of about 3 miles -- and discharged through the currently permitted marine outfall. 

The closure and post-closure requirements of this alternative are the same as identified for 

alternatives above. 

Alternatives Considered but not Analyzed in Detail 

Several additional alternatives were proposed internally or by the public during scoping 

and review of the Greens Creek Mine Tailings Disposal Facility Expansion Draft EIS. 

More discussion of these alternatives is located in Chapter 2 of the Final EIS, Alternatives 

Considered but Eliminated from Detailed Study, and in Appendix D of the Final EIS. 

In looking at on-island locations, the 1983 EIS that analyzed development and 

construction of the Greens Creek Mine considered as many as 13 locations for a tailings 

impoundment. The 1983 analysis established criteria for locations including impacts to 

National Monument lands, reduction of fish habitat, deterioration of water quality, effects 

upon the marine environment, reduction of wildlife habitat, effects upon recreation, 

economic feasibility, and technical feasibility. Seven sites met the technical feasibility 

benchmark, including a site equivalent to the site being considered in Alternatives C and 

D in this analysis. After further consideration, the 1983 EIS analyzed three locations for a 

tailings impoundment: North Hawk Inlet (the current location of the second pile in 

Alternatives C and D of this analysis); the “Football Field” closer to the portal between 
8 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

1,000-1,500 feet in elevation, within the Monument; and the “Cannery Creek” location 

which was ultimately selected. The 2003 EIS analysis did not look at alternative locations 

in detail, citing substantial increases in impacts to wetlands, wildlife, and the potential for 

impacts to water quality. 

In this analysis, the Forest Service considered several alternative locations or 

configurations for tailings placement, including off-island and on-island sites. Off-island 

disposal would require the shipping of tailings by barge, which proved to be costprohibitive. Moreover, a new facility would create similar or a new set of effects in 

another setting. Screening criteria for alternative locations on the island included 

geotechnical stability, impacts to wetlands, impacts to fish bearing streams, and 

accessibility. No geotechnically stable location was identified that could avoid impacts to 

wetlands and fish-bearing streams. Alternative facility designs such as altering the shape 

of the pile in an attempt to avoid or minimize impacts to Tributary Creek were considered 

but ultimately not carried forward due to construction costs and engineering difficulties. 

It is the presence of pyrite in the tailings that creates the potential for acid rock drainage, 

and therefore the greatest need to treat all water that has come into contact with the 

tailings to meet Alaska Water Quality Standards before such contact water is discharged 

to the environment. The 2003 EIS considered the removal of pyrite from the tailings but 

eliminated it from further study. Based upon the interest of the Cooperating Agencies and 

the interdisciplinary planning team, this possibility was looked at again for this analysis 

based on two criteria: technical and logistical feasibility, and predicted long-term water 

quality. This alternative was eliminated from further consideration due to the complexity 

of logistics and operational constraints of placing the required facilities at the current mill 

site, and a greater risk of significant adverse effects. The removal of pyrite from the 

tailings would require the use of sulfuric acid in the pyrite circuit. Thus, Greens Creek 

would need to store large amounts of sulfuric acid on site for pyrite removal, which would 

add to the inventory of hazardous materials at the mine and increase the risks of hazardous 

material spills during shipping, which could harm water quality, aquatic life, and the 

Monument. The pyrite concentrate itself would be highly reactive and create a potential 

for spontaneous combustion. An additional processing circuit to remove pyrite would 

need to be constructed adjacent to the existing mill. A pyrite concentration storage facility 

would also be required. The 2003 EIS estimated that up to 2.5 acres of land would be 

required to accommodate a pyrite facility and the associated storage facilities for 

concentrate and chemicals. The mill is located in a topographically steep and congested 

area, and it would be very difficult if not impossible to locate an additional facility of that 

size in this area. In summary, the additional risks associated with removing pyrite from 

the tailings, and the impracticality of this alternative, warranted excluding it from detailed 

analysis in the EIS. 

Environmentally Preferable Alternative 

Alternative A, the no-action alternative, is the environmentally preferable alternative 

because it would not expand the tailings facility, so it would avoid any additional adverse 

environmental impact from such an expansion. 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪9

RATIONALE FOR THE DECISION 

Summary 

This decision was an unusually difficult one for me to make. In 2003, I made a similar 

decision to expand the tailings disposal facility, a decision expected to last far longer than 

10 years. Thus, the intent of this analysis was to provide a longer-term solution to provide 

greater certainty to all parties about the future of Greens Creek Mine and of the protection 

of Admiralty Island National Monument. 

In arriving at this decision, I studied the entire project record, going all the way back to 

the 1983 EIS for initial approval of the mine, and every subsequent NEPA analysis since 

then. I also carefully examined the complex web of applicable legal requirements, many 

of which are specific to mining activities in the two national monuments on the Tongass, 

and revised information from Hecla Greens Creek Mine as to when the existing tailings 

disposal facility will reach capacity. Knowing how strongly people feel about the issues 

raised by this project, I concluded there will be time to gather and analyze additional 

information before authorizing further impacts on the Tributary Creek watershed or a 

second tailings disposal facility and the associated effects such a facility would have. 

Thus, while I was hoping to avoid another relatively short-term decision, I have 

determined that it is the wiser course of action. It allows time to gather and analyze 

additional information, to thoroughly consider all feasible ways to provide additional 

tailings disposal capacity, and to clearly and convincingly document such consideration 

through future NEPA processes. My reasons for not choosing the other alternatives 

described in the Final EIS are discussed in greater detail below. 

Alternatives B and B Mitigated 

These alternatives are very similar, in that they both expand the existing tailings disposal 

facility and do not include construction of a second facility in the Fowler Creek 

watershed. The only substantial difference between the two alternatives is that Alternative 

B confines the expansion to the Tributary Creek watershed; consequently, the entire 

expansion would be located in Admiralty Island National Monument. To reduce the 

portion of the expansion located in the Monument, Alternative B Mitigated would expand 

the existing tailings disposal facility to the northeast into the Cannery Creek watershed, 

and not as far south into the Tributary Creek watershed. 

As described in the Final EIS, these alternatives have several advantages. For any given 

capacity, one larger facility inherently occupies a smaller area of land than do two smaller 

facilities. Consequently, fewer acres of wetlands are adversely affected under these 

alternatives than under Alternatives C and D. Confining tailings disposal to the fewest 

number of watersheds also reduces overall effects, such as the addition of fugitive dust to 

the Fowler Creek drainage and the increased release of greenhouse gases due to an 

increased haul distance to the second facility. Moreover, since water that has come into 

contact with tailings may require treatment in perpetuity, the alternatives with one tailings 

facility rather than two avoid the need to pump untreated contact water from the Fowler 

Creek location about 3 miles to the existing water treatment plant; the only pumping 

required by a single facility after mine closure is while personnel are on site periodically 
10 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

to treat water stored adjacent to the treatment plant. Thus, a single facility as included in 

Alternatives B and B Mitigated avoids long-term risks of environmental harm from 

uncontrolled spills of untreated contact water should unattended pumps, generators, or 

pipes out of sight of the treatment plant fail sometime in the future. While failures are 

possible under a single facility as well, those risks are much smaller because far fewer 

pipes, generators, and pumps are involved and personnel are more likely to detect any 

failure before a substantial spill occurred. 

On the other hand, these alternatives affect the Monument more than Alternatives C and D 

do. Section 503(f)(2)(A) of the Alaska National Interest Lands Conservation Act 

(ANILCA), requires the Secretary of Agriculture to promulgate reasonable regulations to 

assure that all mining operations related to what is now Greens Creek Mine, including (but 

not limited to) operations within the Monument, are compatible, to the maximum extent 

feasible, with the purposes for which the Monument was established. The regulations 

promulgated pursuant to this Section (36 Code of Federal Regulations [CFR] 228.80) 

further provide that operations meet the statutory requirement if they include all feasible 

measures which are necessary to prevent or minimize potential adverse impacts on the 

resources the Monument was established to protect. Moreover, 36 CFR 228.8(e) requires 

mine operators to take all practicable measures to maintain and protect fisheries habitat. 

Some reviewers of the Draft EIS commented that these requirements prohibit adoption of 

any alternative that allows tailings to be disposed of in the portions of Tributary Creek 

classified as Class I or Class II fish habitat unless the Forest Service could demonstrate 

that Alternatives C and D, which do not affect the fish-bearing portions of Tributary 

Creek, are not feasible. Other reviewers asserted that the effects of Alternatives B or B 

Mitigated on the fish-bearing portions of Tributary Creek would violate Section 

503(i)(1)(B) of ANILCA, which entitles Greens Creek Mine to a lease for mining and 

milling purposes only if it would not cause irreparable harm to the Monument. 

During the preparation of the Final EIS, Hecla Greens Creek Mining Company provided 

information that the Company believes demonstrates that Alternatives C and D are not 

economically feasible. Although the information demonstrates that it would be far more 

expensive to build a second tailings disposal facility as described in Alternatives C and D, 

I am not confident that these alternatives are infeasible. The assertions that Alternatives B 

and B Mitigated would result in irreparable harm to the Monument because of their 

impacts on the fish-bearing portions of Tributary Creek are also important and challenging 

issues. For these reasons, after reviewing the project record, I believe additional 

information needs to be collected regarding feasibility of alternative sites before 

authorizing activities that would affect the fish-bearing portions of Tributary Creek. 

Alternatives C and D (without modifications) 

These alternatives are similar, in that they both would require construction of a second 

tailings disposal facility in the Fowler Creek watershed. Consequently, both alternatives 

would require untreated contact water to be pumped back to the existing water treatment 

plant, perhaps in perpetuity, and discharged via the existing marine outfall in Hawk Inlet. 

Both alternatives would require Greens Creek Mine to widen and upgrade 3 miles of the 

existing "A Road" to accommodate the additional traffic of heavy trucks that haul tailings, 

and to bury the pipes needed to transport contact water to prevent it from freezing. The 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪11

only substantial difference between the two alternatives is that Alternative C expands the 

existing tailings disposal facility much less than does Alternative D, providing less time 

before construction of the second facility in Fowler Creek would have to be completed. 

As described in the Final EIS, these alternatives would substantially reduce the footprint 

of the combined tailings disposal facilities that would be located within the Monument, 

compared to Alternatives B and B Mitigated. Specifically, they avoid disposing of 

tailings in the fish-bearing portions of Tributary Creek. In this way, the issues related to 

whether the disposal of tailings causes irreparable harm to the Monument would be easier 

to resolve under Alternatives C and D than under Alternatives B and B Mitigated. 

On the other hand, these two alternatives would introduce new impacts to the Fowler 

Creek watershed, which is not currently affected by tailings disposal. These alternatives 

would result in filling substantially more wetlands (128 acres for Alternative C, 138 acres 

for Alternative D) than would Alternative B (89 acres) or Alternative B Mitigated (70 

acres). They also would affect an existing goshawk nest, unlike Alternatives B and B 

Mitigated, and result in greater greenhouse gas emissions due to the longer haul distance 

between the mill and the Fowler Creek tailings disposal site. I must also consider the 

long-term risks associated with the need under these two alternatives to pump untreated 

contact water a distance of about 3 miles for at least 100 years after closure, and perhaps 

in perpetuity. Based on my review of the record, I believe that long-term reliance under 

Alternatives C and D on a greater number of generators, pipes, and pumps, most of which 

would be out of sight of the treatment plant, poses a higher risk of substantial spills of 

untreated contact water than the simpler pumping system required under Alternatives B 

and B Mitigated. 

For all these reasons, even though Alternatives C and D would cause less harm to the 

Monument, current information suggests that Alternatives C and D may have more total 

adverse environmental effects than would Alternatives B and B Modified. 

As previously discussed, Section 503(i)(1) of ANILCA provides that Greens Creek Mine 

is entitled to a lease only if certain conditions are met. Section 503(i)(1) reads as follows: 

(i)(1) With respect to the mineral deposits at Quartz Hill and Greens Creek in the 

Tongass National Forest, the holders of valid mining claims under subsection 

(f)(2)(B) shall be entitled to a lease (and necessary associated permits) on lands 

under the Secretary’s jurisdiction (including lands within any conservation system 

unit) at fair market value for use for mining or milling purposes in connection with 

the milling of minerals from such claims situated within the Monuments only if 

the Secretary determines— 

(A) that milling activities necessary to develop such claims cannot be feasibly 

carried out on such claims or on other land owned by such holder; 

(B) that the use of the site to be leased will not cause irreparable harm to the 

Misty Fjords or the Admiralty Island National Monument; and 

(C) that the use of such leased area for such purposes will cause less 

environmental harm than the use of any other reasonably available location. 
12 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

With respect to any lease issued under this subsection, the Secretary shall limit the 

size of the area covered by such lease to an area he determines to be adequate to 

carry out the milling process for the mineral bearing material on such claims. 

Based on my review of the project record, including previous NEPA documents, it 

appears that the primary focus of the public since enactment of ANILCA in 1980 has been 

on the language in clause (B) about avoiding irreparable harm to the Monument. It also 

appears that many people have assumed that Section 503(i)(1) applies only to activities 

within the Monument. After studying the language carefully, I have reached a different 

conclusion: that the provisions apply on any National Forest System land, including land 

within the Monument and land outside its boundary. 

The information currently available does not suggest that either Alternative C or 

Alternative D (without the modifications described in the Selected Alternative) "will 

cause less environmental harm than the use of any other reasonably available location." 

However, since the Draft EIS was published, questions have arisen whether ways might 

exist to reduce the environmental effects of Alternatives C and D, such as developing a 

second water treatment plant and marine outfall in the northern part of Hawk Inlet or 

perhaps Young Bay; or routing untreated contact water to the beach on Hawk Inlet, 

treating it there, and then routing it to the existing marine outfall. I believe additional 

information is needed to ascertain whether any of these measures would reduce the 

environmental effects of Alternatives C and D before authorizing construction of a second 

tailings facility. 

That brings me to the issue of the feasibility of Alternatives C and D. As previously 

mentioned, USDA promulgated regulations to implement Section 503(f)(2)(A) of 

ANILCA. Those regulations (36 CFR 228.80) read as follows: 

Operations within Misty Fjords and Admiralty Island National Monuments, 

Alaska 

(a) Mineral activities on valid mining claims in the Misty Fjords and Admiralty 

Island National Monuments must be conducted in accordance with regulations in 

subpart A of this part and with the provisions of this section. 

(b) Prior to approving a plan of operations, the authorized officer must consider: 

(1) The resources of ecological, cultural, geological, historical, prehistorical, 

and scientific interest likely to be affected by the proposed operations, 

including access; and 

(2) The potential adverse impacts on the identified resource values resulting 

from the proposed operations. 

(c) A plan of operations will be approved if, in the judgment of the authorized 

officer, proposed operations are compatible, to the maximum extent feasible, with 

the protection of the resource values identified pursuant to paragraph (b)(1) of this 

section. 

(1) The authorized officer will deem operations to be compatible if the plan of 

operations includes all feasible measures which are necessary to prevent or 

minimize potential adverse impacts on the resource values identified pursuant 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪13

to paragraph (b)(1) of this section and if the operations are conducted in 

accordance with the plan. 

(2) In evaluating the feasibility of mitigating measures, the authorized officer 

shall, at a minimum, consider the following: 

(i) The effectiveness and practicality of measures utilizing the best 

available technology for preventing or minimizing adverse impacts on the 

resource values identified pursuant to paragraph (b)(1) of this section; and 

(ii) The long- and short-term costs to the operator of utilizing such 

measures and the effect of these costs on the long- and short-term 

economic viability of the operations. 

(3) The authorized officer shall not require implementation of mitigating 

measures which would prevent the evaluation or development of any valid 

claim for which operations are proposed. 

(d) In accordance with the procedures described in subpart A and paragraphs (c)(1) 

through (c)(3) of this section, the authorized officer may approve modifications of 

an existing plan of operations: 

(1) If, in the judgment of the authorized officer, environmental impacts 

unforeseen at the time of approval of the existing plan may result in the 

incompatibility of the operations with the protection of the resource values 

identified pursuant to paragraph (b)(1) of this section; or 

(2) Upon request by the operator to use alternative technology and equipment 

capable of achieving a level of environmental protection equivalent to that to 

be achieved under the existing plan of operations. 

The language in paragraph (c)(2) of these regulations applies most directly to determining 

the feasibility of measures to prevent or minimize potential adverse impacts on resources 

the Monument was established to protect. Consistent with this language, the Tongass 

Forest Plan defines “feasible” to mean: 

Capable of being accomplished in a successful manner within a reasonable period 

of time, taking into account economic, environmental, technical, and safety 

factors. In evaluating feasibility, the following are considerations: 1) the 

effectiveness and practicality of the measures being considered; and 2) the longand short-term costs of the measures and the effect of those costs on long- and 

short-term economic viability of projects or programs. 

As mentioned in the discussion of Alternatives B and B Mitigated above, during 

preparation of the Final EIS, Greens Creek Mine provided information that the company 

believes demonstrates that Alternatives C and D are not feasible. I am not confident that 

these alternatives are not feasible. However, because of the uncertainties regarding the 

feasibility of Alternatives C and D (without modifications described in the Selected 

Alternative), I believe additional information needs to be collected regarding feasibility of 

Alternatives C and D before authorizing construction of a second tailings facility. 
14 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

Alternative A, the No-Action Alternative 

The question arises whether the No-Action Alternative, Alternative A, is the best course 

of action until the additional information described above is gathered, reviewed, made 

available to the public, and incorporated in subsequent NEPA analysis. After all, the 

latest information from Greens Creek Mine suggests that capacity of the existing tailings 

disposal facility will not be reached until 2019, considerably later than previously 

estimated. I considered that approach, and rejected it for several reasons. First, while 6 

years may seem like plenty of time to address the concerns outlined above, it will 

probably take at least 2 or 3 years of field work to gather the required information; about 3 

years to prepare another EIS; and it could take at least 2 years to build whatever facility 

might be approved—more if that is an additional facility. It may well take at least 6 years 

before another decision can be made, even without a legal challenge that could extend that 

timeframe. In addition, there is a substantial amount of waste rock that will be stored in 

the tailings disposal facility prior to closure. The estimate that tailings storage capacity 

will be reached in 2019 did not take into account the need to store waste rock as well. 

Adjusting for that requirement substantially shortens the time period before additional 

tailings cannot be stored in the existing facility. Finally, paragraph (c)(3) of the 

regulations cited above clearly prohibit me from requiring “implementation of mitigating 

measures which would prevent the evaluation or development of any valid claim for 

which operations are proposed.” I believe this language requires me to take action needed 

to ensure that Greens Creek Mine can continue operations, subject to the other 

requirements discussed previously. 

Conclusion 

For the reasons discussed above, some decision must be made to ensure that operations 

can continue until the necessary additional information can be gathered, analyzed, and 

reviewed by all stakeholders through the NEPA process. The Selected Alternative is the 

best way I know of to achieve that result, and as described above, it has far less 

environmental effects than the other alternatives considered in the Final EIS. That is why 

I am adopting it in this Decision. 

Although the Selected Alternative is a modification of Alternative D, adopting it does not 

preclude consideration or selection in the future of any of the action alternatives 

considered in this EIS, or other new feasible alternatives that may arise, once the 

additional information described in this Decision is gathered, analyzed, and reviewed 

through future NEPA processes. 

Because I am adopting an alternative that provides only a relatively short-term solution to 

the issues related to tailings disposal and protection of Admiralty Island National 

Monument, it is important to consider how best to prepare for the next decision that is 

likely to be needed several years from now. At that point, a short-term solution that 

avoids affecting the fish-bearing sections of Tributary Creek and also avoids a second 

tailings facility is unlikely to be available. Therefore, it is essential that the Responsible 

Official for the next decision not be in the position I am in today. To avoid that dilemma, 

the Tongass National Forest will work with other appropriate parties on two items. The 

first is to develop a supplement to the Forest Service Directives to clarify how to apply the 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪15

complex set of legal requirements that are specific to Admiralty Island National 

Monument and Misty Fiords National Monument. The second step is for Hecla to provide 

feasibility analyses regarding the construction and use of alternative tailings disposal 

facilities. The Tongass National Forest will work with other stakeholders to identify the 

information that must be incorporated into the feasibility analyses, using the definition of 

feasibility as stated above. As these analyses will be used to support any additional 

expansion of the Greens Creek Mine tailings disposal facility, they must be completed in a 

timeframe that enables the information to be included in any subsequent NEPA analysis. 

EFFECTS OF THE SELECTED ALTERNATIVE ON 

SIGNIFICANT ISSUES 

Issue 1 – Water Quality 

Water quality and treatment is the same among all alternatives. Modeling, based upon 

water quality data collected from the tailings disposal facility during the last 20 years of 

operations, predicts that contact water will not meet water quality standards after closure, 

and that the water will require treatment in post-closure for hundreds of years, perhaps 

into perpetuity. The modeling does not show any differences in water quality among the 

alternatives. Thus, all of the alternatives will require collection and treatment of water for 

100 years, perhaps into perpetuity. The Selected Alternative will require the mine to 

collect and treat water from the tailings disposal facility until the water can meet Alaska 

Water Quality Standards, likely in perpetuity, as with the other alternatives. Greens Creek 

Mine will be responsible for providing financial assurance to ensure that long-term water 

treatment will occur. The treated water will continue to discharge into Hawk Inlet, and is 

required to comply with the Clean Water Act under the Alaska Pollution Discharge 

Elimination System. 

At closure, an engineered cover will be constructed on the pile to limit the ingress of water 

and oxygen into the tailings. This will minimize the development of acid rock drainage. 

Water will be collected as it drains from within or underneath the pile. The cover will be 

built to drain water falling onto the pile to natural watersheds and promote the return of 

natural forest vegetation, including Sitka spruce and western hemlock. 

Issue 2 – Wetlands 

The Selected Alternative will affect about 14 acres of wetlands. Approximately 8 acres of 

these wetlands will be covered with the tailings disposal facility and the area cannot be 

reclaimed as wetlands at closure of the mine. Water management pond development will 

fill about 2 acres of wetlands. These acres are considered a permanent loss of wetlands 

and mitigation will occur under the Clean Water Act according to a Corps of Engineers 

permit. These affected wetlands are near the headwaters of the Tributary Creek channel. 

Tributary Creek may experience changes to the hydrologic system, as diverting noncontact runoff could increase peak flow velocities in the natural stream channel during 

large storm events, potentially causing erosion of channel substrates and impact channel 

geomorphology. Mitigation will be put in place to minimize these effects as much as 
16 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

practicable. The remaining 4 acres of wetlands lost will occur near the junction of the A 

and B Roads where reclamation material will be stored. 

Issue 3 – Fish Habitat 

The Selected Alternative does not allow Greens Creek Mine to fill or otherwise directly 

affect any Class I or Class II stream. The Selected Alternative does not require the 

widening or upgrading of the existing road. Only one new 160- foot road will be 

constructed as a result of this decision; no stream crossings will be required. Additionally, 

Greens Creek Mine is required to repair the existing fish passage facility on Greens Creek 

and provided for continued monitoring and maintenance of the facility. 

Issue 4 – Admiralty Island National Monument 

The Selected Alternative will cause an additional 18 acres of disturbance within 

Admiralty Island National Monument. No tailings will be disposed of in any fish-bearing 

portion of Tributary Creek. The area of impact from the decision represents less than 

1/100th of a percent of the Monument, and is contained within a single watershed. 

Impacts to ecological resources are primarily concentrated to wetlands in the headwaters 

of Tributary Creek. Additionally, the Selected Alternative was chosen to comply with 

applicable legal requirements specific to managing the mine within Admiralty Island 

National Monument as described in the Rationale for Decision. 

COMPARISON OF ALTERNATIVES 

This section compares outputs and environmental effects of the alternatives for the 

significant issues and resources analyzed. The effects are summarized from Chapter 3 of 

the Final EIS, which should be consulted for a full understanding of these and other 

environmental consequences. For each resource, the environmental effects of the Selected 

Alternative are within the range of (or less than) the Alternative effects analyzed in the 

Draft EIS. The major difference among alternatives is the location and configuration of 

the TDF. The method of construction, disposal, water management and treatment, and 

reclamation and closure plans are the same for each of the alternatives. Alternatives C 

and D would require pumping of the effluent from additional collection points to a water 

treatment plant approximately 3 miles away, that would be required as long as active 

treatment is required, perhaps in perpetuity. This will entail the use of generators and 

pump stations along the route between the second facility and the existing facility, as well 

as 3 miles of pipeline carrying untreated water from the second tailings facility, and 

represents an increased risk of an uncontrolled discharge should pumps, pipes, or 

generators fail along the pipeline. 

Alternatives B Mitigated and D (unmodified) expand the current facility to the northeast, 

in the Cannery Creek watershed, to minimize impacts to the Monument. The construction 

of the northeast corner will require a high volume of clean fill, imported from off-island 

sources because no geochemically stable rock source has yet been found near the mine. In 

addition, water collected from this portion of the facility would not be able to freely drain 

to the collection ponds and water treatment plant after closure of the mine. Water 

collected from this portion of the facility would require constant pumping to a collection 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪17

pond and water treatment plant on the other side of the facility. This represents a much 

smaller distance of pumping and associated infrastructure such as generators than would 

be required for a second tailings disposal facility, but still represents the increased risk of 

an uncontrolled discharge should pumps or generators fail. 

Climate change has also been a consideration, including the effects of climate change on 

the project, the effects of the project on climate change, and how either type of effect 

varies by alternative. As described in Chapter 3 of the Final EIS and the table below, 

Alternatives C and D (unmodified) would increase the amount of greenhouse gas (carbon 

dioxide) emissions by 33 and 29 percent, respectively, compared to the other action 

alternatives. There would be no discernible differences among the alternatives in how 

climate change would affect the project. 

Table 1 provides a comparison of alternatives relative to the issues and resources 

analyzed.
Record of Decision

18 ▪ Record of Decision Greens Creek Mine Tailings DTable 1. Summary of Potential Impacts of Each Alternative by Resource

Resource 

Impact Alternative A Alternative B Alternative B Mitigated Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Air Quality Uncontrolled: PM10-2.5

tons per year (tpy) 

142 171 164 233 

 PM2.5 tpy 17 22 21 30  Controlled: PM10-2.5

tpy 

77 90 87 123 

 PM2.5 tpy 9 12 11 16  Greenhouse gas 

emissions (tons CO2 

emissions per year) 

707 707 707 946 

Water Resources–Surface Water 

Percent of watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 20 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 11 

Tributary Creek: 15 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 3 South Hawk Inlet: 11 

Tributary Creek: 3 Cannery Creek: 2 Fowler Creek: 2 North Hawk Inlet: 11 Middle Hawk Inlet: 1 South Hawk Inlet: 2 

TributCanneFowleNorth MiddlSouth 

 Total acres of 

watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 81 Cannery Creek: 19 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 28 

Tributary Creek: 62 Cannery Creek: 23 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 12 South Hawk Inlet: 29 

Tributary Creek: 12 Cannery Creek: 15 Fowler Creek: 107 North Hawk Inlet 28 Middle Hawk Inlet: 6 South Hawk Inlet: 6 

TributCanneFowleNorth MiddlSouth 

 Reduction in stream 

flow 

Minor reduction of flow in two creeks (Tributary and Cannery) 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A. Impacts to Tributary Creek slightly less than Alternative B. 

Minor reduction in flow in three creeks (Tributary, Cannery, and Fowler) 

SimilaAlternalthouFowlebe delapproxyears 
Reco

Greens Creek Mine Tailings Disposal Facility Expansion 

Table 1. Summary of Potential Impacts of Each Alternative by Resource (continued) 

Resource 

Impact Alternative A Alternative B Mitigated Alternative B Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Water Resources–Surface Water (continued) 

Additional water management infrastructure such as diversions, groundwater slurry walls, and water management ponds 

Yes as TDF expands to currently approved size 

Yes; more water management infrastructure required than Alternative A 

Yes; more water management infrastructure required than Alternative B; additional water management infrastructure required, including construction and maintenance of pipeline and pump stations. 

Yes; more total infrastructure required than Alternative B and Alternative Mitigated B; additional water management infrastructure required for new TDF, including construction and maintenance of pipeline and pump stations 

SimilaAlternalthouwater for new not be until cbegan approxyears 

 Need for long-term 

water treatment 

Yes Yes Yes Yes Yes 

Water Resources–Groundwater 

Change in flow or quality 

Minimal effect on local hydrogeology; no impacts to groundwater quality 

Similar to Alternative A Similar to Alternative 

A 

Similar to Alternative A but new TDF located in additional groundwater area 

SimilaAltern

Aquatic Resources 

Habitat permanently lost (feet) 

Class I Tributary: 0 

Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 0 Fowler: 0 

TributFowle

Class II Tributary: 0 

Fowler: 0 

Tributary: 2,400 Fowler: 0 

Tributary: 1,169 Fowler: 0 

Tributary: 0 Fowler: 1,044 

TributFowle

Risk of chemical or mining product spill 

Low, due to BMPs and Spill Prevention, Control, and Countermeasure Plan requirements 

Similar to Alternative A, although risk would continue over 30 to 50 years due to extended operations 

Similar to Alternative B 

Similar to Alternative B except the area of potential spills would expand to include Fowler Creek drainage 

SimilaAltern

Geochemistry Likelihood of TDF 

ARD developing (uncontrolled) 

Low due to very low permeability, low availability of oxygen and closure and reclamation of TDF 

Similar to Alternative A Similar to Alternative 

A 

Similar to Alternative A 

SimilaAltern

Geotechnical Stability 

Likelihood of TDF failure 

Very low probability of TDF failure due to design measures 

Similar to Alternative A Similar to Alternative 

A 

Similar to Alternative A 

SimilaAltern

Soils New loss in soil 

productivity (measured in acres disturbed) 

0 1281/ 1261/ 1741/ 1851/ 
Record of Decision

20 ▪ Record of Decision Greens Creek Mine Tailings D

Table 1. Summary of Potential Impacts of Each Alternative by Resource (continued) 

Resource 

Impact Alternative A Alternative B Mitigated Alternative B Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Vegetation Acres of new 

disturbance 

0 POG: 73 acres 

Unproductive forest: 55 acres 

POG: 64 acres Unproductive forest:: 62 acres 

POG: 114 acres Unproductive forest: 60 acres 

POG: Unpro70 acr

Off-site effects Elevated metals levels in 

lichens may continue through life of operations; duration of effects would depend on the effectiveness of control measures 

Similar to Alternative A; however, off-site effects may continue longer due to longer mine life 

Similar to Alternative B 

Similar to Alternative B 

SimilaAltern

Wetlands Acres and types of 

new disturbance 

0 Bog/Bog Woodland: 20 

Forested: 36 Sedge Fen/Fen: 28 Marsh: 1 Total: 85 

Bog/Bog Woodland: 12 Forested: 35 Sedge Fen/Fen: 27 Marsh: 3 Total: 77 

Bog/Bog Woodland: 8Forested: 78 Sedge Fen/Fen: 25 Marsh: 1 Total: 112 

Bog/B9 ForestSedge MarshTotal: 

Wildlife New decrease in 

brown bear buffers (acres) 

None 30 29 6 14 

New removal of POG habitat (acres) within brown bear buffers 

None 35 27 5 11 

Duration of activities that could disturb wildlife and marine mammals 

Through 2019 Additional 30–50 years Additional 30–50 

years 

Additional 30–50 years 

Additiyears 

New temporary reduction in deer winter range habitat (acres) 

None 128 125 174 184 

Result in “take” of Endangered Species Act (ESA)-listed species2/

No No No No No 

Number of goshawk nests potentially affected 

0 0 0 1 1 
Reco

Greens Creek Mine Tailings Disposal Facility Expansion 

Table 1. Summary of Potential Impacts of Each Alternative by Resource (continued) 

Resource 

Impact Alternative A Alternative B Mitigated Alternative B Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Threatened (FT) and endangered (FE) species / Forest Service Sensitive Species (FSS)/Forest Service Rare (FSR) 

Humpback whale (FE)2/

Not likely to adversely effect 

Steller sea lions (FE)2/ Not likely to adversely effect Yellow-billed loon (candidate and FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Arealisting

Chinook salmon; coho salmon; sockeye salmon; steelhead (FT or FE, depending on the run) 

No effect 

Green Sturgeon (FT) No effect Pacific Herring (candidate and FSS 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

Queen Charlotte goshawk (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

Black oystercatcher (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

 Mountain lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

 Large yellow lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

 Alaska rein orchid 

(FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

 Bog adder's-mouth 

orchid (FSR) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area

listing

Land Use Meet management 

prescriptions 

Yes Yes Yes Yes Yes 

Recreation Duration of operations 

(when public may be excluded from areas) 

Through 2019 plus reclamation period 

Additional 30–50 years plus reclamation period 

Additional 30–50 years plus reclamation period 

Same duration as Alternative B; disturbance at new TDF initiated in approximately 3–5 years 

DisturTDF nuntil ayear 1
Record of Decision

22 ▪ Record of Decision Greens Creek Mine Tailings D

Table 1. Summary of Potential Impacts of Each Alternative by Resource (continued) 

Resource 

Impact Alternative A Alternative B Mitigated Alternative B Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Scenic Resources 

Compliance with applicable scenic integrity objective (SIO) 

Yes Yes Yes Yes Yes 

 Duration of visual 

effects 

Around 2019 plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Reclamation at existing TDF to begin in approximately 3–5 years; reclamation of new TDF at end of mining activity (30–50 years); reclamation establishment period applies to both facilities 

Reclamexistinbegin approxyears; 50 yeaactivitreclamestabliappliefaciliti

 Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion at current location and new site to the north 

Moderat currand nenorth 

Subsistence Duration of mine life Through 2019 30–50 more years 30–50 more years 30–50 more years 30–50  New temporary 

reduction in deer winter range habitat (acres) during operations and until forested canopy develops post reclamation 

None 128 125 174 184 

 Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion at current location and new site to the north 

Moderat currand nenorth 

Cultural Resources 

Effects on historic properties 

Historic properties not adversely affected; Hawk Inlet identified as a sacred place by Angoon affected over the long term 

Same as Alternative A Same as Alternative A Same as Alternative A Same 

A 
Reco

Greens Creek Mine Tailings Disposal Facility Expansion 

Table 1. Summary of Potential Impacts of Each Alternative by Resource (continued) 

Resource 

Impact Alternative A Alternative B Mitigated Alternative B Alternative C Alt

Duration of Mine 

Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 30

Socioeconomics Duration of annual economic and 

employment benefit from operations 

Through 2019 30–50 more years 30–50 more years 30–50 more years 30–50 

Monument Resources 

New disturbance within Monument (acres) 

0 104 83 18 31 

 Post-mining condition Near-natural condition 

following reclamation 

Similar to Alternative A Similar to Alternative 

A 

Similar to Alternative A 

SimilaAltern

Environmental Justice 

Disproportionately affect minority or low income populations 

No No No No No 

1/ Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis processes become 2/ A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on April 19, 20
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪24

PUBLIC INVOLVEMENT 

The Notice of Intent (NOI) to prepare the EIS for the Greens Creek Mine Tailings 

Disposal Facility Expansion was published in the Federal Register on October 5, 2010. 

The publication of the NOI initiated the scoping process and a public review and comment 

period required under NEPA at 40 CFR Part 1501.7. In addition to the NOI, the Forest 

Service placed a public notice in the Ketchikan Daily News and the Juneau Empire on 

October 8, 2010, which ran for 4 days, and also used email to advertise public meetings. 

A scoping document that provided a brief background on the Greens Creek Mine; a 

description of the proposed action, agency involvement, permits and authorizations, and 

the scoping process; an EIS preparation schedule; and information sources was distributed 

to a mailing list generated from previously completed similar projects and with input from 

the cooperating agencies. After a 15-day extension, the formal scoping period ended on 

November 19, 2010. 

Public scoping meetings were held in Juneau on October 14, 2010, and in Angoon on 

October 15, 2010. Fifteen people signed the attendance sheets at the public meeting in 

Juneau, and 20 signed in at the Angoon meeting. The scoping process produced 16 

individual comment submittals, which were individually reviewed by the interdisciplinary 

team identifying over 150 comments. A Scoping Summary Document is available in the 

project record. 

The Forest Service published a Notice of Availability of the Draft EIS in the Federal 

Register (77 FR 23713 [2021-04-20]), which coincided with distribution of paper and 

electronic copies to the public. The document was posted concurrently on the Tongass 

National Forest website. The Notice of Availability was published in the Juneau Empire

and Ketchikan Daily News on April 20, 2012. The Forest Service and the Unites States 

Army Corps of Engineers (USACE) held open house public meetings in Juneau (May 15, 

2012) and Angoon (May 16, 2012) to solicit comment on the Draft EIS and the USACE 

Public Notice of Permit Application, which was included as Appendix A to the Draft EIS. 

Meeting announcements were posted in the Ketchikan Daily News on May 11, 2012. 

Nineteen people signed in for the public meeting in Juneau, and 10 people signed in for 

the meetings in Angoon. 

The Forest Service received over 700 comments contained within over 100 comment 

“letters,” which were submitted in the form of letters, emails, and hand-written comments. 

In addition, 10 comment letters were addressed to the USACE. Two comment documents 

were addressed to both agencies. All comments have been read and considered in this 

analysis. Where appropriate, the Final EIS has been revised to address comments 

received during the comment period. Copies of comment letters and responses to each of 

the comments are presented in Appendix A of the Final EIS. 

PROJECT RECORD 

The project record for this project includes the Draft EIS and Final EIS, the 2008 Forest 

Plan, all material incorporated by reference and other critical materials produced during 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪25

the environmental analysis of this project. The project record is available for review at the 

Admiralty Island National Monument in Juneau. 

MITIGATION 

Table 2.6-1 in the Final EIS summarizes the mitigation measures identified for each 

resource area and includes the agency or entity responsible for oversight of the mitigation 

completion. Other measures may be beyond regulatory authority but could be put in place 

by the Greens Creek Mine. Table 2.6-1 is included here as Table 2 of this Decision; for a 

more thorough discussion of mitigation measures, please see the corresponding section in 

the Final EIS. 

Table 2. Required Mitigation Measures by Resource 

Resource Measure 

Section in 

the EIS Site Responsibility 

Air Ongoing dust abatement and monitoring. 

Conduct operations in such a manner as to 

avoid or minimize the production and 

transport of fugitive dust from the site 

(MIN-3, Forest Service 2012). 

3.2 TDF HGCMC 

 *Investigate the source(s) and extent of 

fugitive dust-related metals contaminants 

observed in the Forest Service’s lichen 

monitoring program. As necessary, 

develop mitigation measures to reduce 

fugitive dust emissions. 

3.2 TDF / 

Mill Site / 

Roads 

HGCMC 

Air and Water 

Quality 

Inspect trailers hauling tailings/ waste 

rock; ensure covers are in place and 

secure and tailgate latched and secured 

against spillage. 

3.2, 3.5 TDF, mill 

area, and 

roads 

HGCMC 

 Spray roads with water if notable dust 

observed. 

3.2 Roads HGCMC 

 Vehicles must have the wheels cleaned 

prior to leaving the TDF using clean 

water from existing permitted water 

source. 

3.5 TDF HGCMC 

 Implement additional fugitive dust control 

measures. 

3.2.3 TDF HGCMC 

Geotechnical 

Stability 

Tailings pile must be constructed with 

compacted outside side slopes that are no 

steeper than 3H:1V; slopes during 

operation may be steeper than 3:1 if 

future operation or slope work is planned 

or approval is obtained. 

3.3, 3.5 TDF HGCMC per 

ADEC Waste 

Management 

Permit 

 Locate ore stockpiles and waste facilities 

on stable, level sites (Min-6, Forest 

Service 2012). 

3.3 Site-wide HGCMC 

Geochemistry Implement standard operating procedures 

to evaluate risk of acid rock drainage 

(ARD) and other geochemical concerns 

prior to developing quarries. 

N/A Quarries HGCMC 

 
Record of Decision 

26 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

Table 2. Required Mitigation Measures by Resource (continued) 

Resource Measure 

Section in 

the EIS Site Responsibility 

Geochemistry 

(continued) 

Continue characterization of waste rock 

and tailings using accepted protocols to 

identify materials that have the potential 

to release acidity or other contaminants 

when exposed during mining (Min-6, 

Forest Service 2012). 

3.3, 3.5 TDF HGCMC 

Water Resources 

/ Water Quality 

Maintain culverts and ditches; inspect 

facilities twice each year to maintain 

functionality. Clean culverts when more 

than 4” of sediment accumulates (6” in 

ditches). 

3.5 Roads HGCMC 

 Install storm water detention structures, 

detention ponds or other structures at the 

confluence of surface water runoff 

diversions and natural channels in a 

manner that will maintain 

geomorphologic integrity of the natural 

channel. 

3.5 TDF HGCMC 

 Water management detention basins and 

ponds would continue to be operated with 

low storage volumes to maintain adequate 

contact water capacity in the pond 

systems; the maintenance of adequate 

contact water capacity is required by 

ADEC. 

3.5 TDF HGCMC 

 Collect and route direct runoff from 

tailings facility. 

3.5 TDF HGCMC 

 Collect and route direct runoff from mill 

area tailings and storage and transfer 

facilities. 

3.5 Mill area HGCMC 

 Prevent contact water runoff into surface 

water bodies. 

3.5 TDF HGCMC 

Vehicles exiting the TDF(s) must have 

the wheels cleaned. 

3.5 TDF HGCMC 

 Vehicles exiting the mill building 

concentrate room must have the wheels 

cleaned; runoff water from the truck wash 

collects in the sump and is pumped to the 

bulk thickener; no runoff water from the 

concentrate loading area leaves the 

building. 

3.5 Mill area HGCMC 

 Spill response and reporting procedure. 

Detailed Contingency Plan outlines spill 

response and reporting procedures in the 

event of a spill of a hazardous substance. 

3.5 Site-wide HGCMC 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪27

Table 2. Required Mitigation Measures by Resource (continued) 

Resource Measure 

Section in 

the EIS Site Responsibility 

Water Resources 

/ Water Quality 

(continued) 

Establish vegetative cover and moderate 

slopes to manage surface water flows. 

Most slopes will be constructed with a 

3H:1V slope; use erosion control 

measures (e.g., silt fences, swales, and 

weed-free jute matting) to slow the water 

and reduce erosion while vegetation 

becomes established. 

3.5 TDF HGCMC 

 Stabilize channels and channel banks. 

Hydroseeding used on channel banks to 

aid in stabilization; channels may be 

stabilized with degradable fiber mat to 

establish vegetation; riprap used to 

stabilize the constructed channels in areas 

that are subject to highly erosive stream 

flows. 

3.5 Site-wide HGCMC 

 Hydroseede slopes for stability. Monitor 

road cuts for exposed soils and use 

hydroseeding as appropriate. 

3.5 TDF HGCMC 

 During operations, drainage channels 

designed to handle flows from a 24 

hour/25-year storm event. Applies to all 

drainage channels and diversion 

structures during reclamation. 

3.5 Site-wide HGCMC 

 Ensure that clean water remains clean. 

Surface runoff is intercepted and diverted 

around the mill area. 

3.5 Mill area HGCMC 

 Minimize tailings contact with 

groundwater by installing liners and under 

drains beneath the tailings; install slurry 

walls surrounding the facility (Min-6, 

Forest Service 2012). 

3.6 TDF HGCMC 

 Maintain or increase water management 

infrastructure to contain and treat tailings 

contact water and manage industrial storm 

water. 

3.5 Site-wide HGCMC per the 

current APDES 

Permit 

 Provide for water treatment in perpetuity 

to avoid or minimize the development and 

release of acidic or other contaminants 

(Min-6, Forest Service 2012). 

3.5 TDF HGCMC 

 Install impermeable caps, liners, and 

surface water diversions (Min-6, Forest 

Service 2012). 

3.5 TDF HGCMC 

Aquatic 

Resources 

Repair and maintain, in perpetuity, the 

existing fish passage facility on Greens 

Creek. 

3.7 TDF HGCMC per 

previous NEPA 

documents and 

ADF&G 

mitigation 

requirements 

 Observe timing windows for instream 

activities as stipulated by ADF&G for the 

protection of fish species. 

3.7 Roads, 

fish 

passage 

HGCMC 
Record of Decision 

28 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

Table 2. Required Mitigation Measures by Resource (continued) 

Resource Measure 

Section in 

the EIS Site Responsibility 

Soils Salvage topsoil in stockpile (Min-8, 

Forest Service 2012). 

3.9.4 TDF HGCMC per GPO

Establish test plots to study the optimum 

depth of the plant growth layer. 

3.9.4 Site 23 

Test 

Cover 

HGCMC 

Vegetation Establish test plots to verify that 

vegetative roots would not extend into the 

barrier layer, and develop an appropriate 

seed or planting mix. 

3.10.3.1 Site 23 

Test 

Cover 

HGCMC 

 Survey of HGCMC mine activity areas 

and roads for weeds to determine existing 

condition. 

3.10.3.1 TDF Forest Service 

 Assure that all vehicles and heavy 

equipment transported to the project area 

are free of invasive plant propagules and 

contaminated soil. 

3.10.3.1 Site-wide HGCMC 

 Use of erosion control materials that are 

weed seed free. Avoid use of hay or straw 

bales. 

3.10.3.1 Site-wide HGCMC 

 Avoid or remove existing invasive plant 

populations in order to reduce the risk of 

spread. 

3.10.3.1 Site-wide HGCMC 

 Eradicate or control any newly introduced 

high priority invasive plant populations in 

the project area for the life of the project. 

3.10.3.1 Site-wide HGCMC 

 Perform triennial monitoring surveys of 

mine activity areas and roads for high 

priority invasive plant introductions for 

the life of the project, and for at least 

3 years following mine site closures. 

3.10.3.1 Site-wide HGCMC 

 Annually monitor high priority invasive 

plant treatment sites. 

3.10.3.1 Site-wide HGCMC 

Wetlands Mitigation for wetlands will be 

determined by the Section 404 permit. 

3.8.4 TDF HGCMC; USACE

Cultural 

Resources 

Implement Cultural Resources 

Management Procedure for ongoing 

operations around known sites and for 

managing previously unidentified 

resources. Survey all areas in advance of 

ground disturbing activity. 

3.17 Site-wide HGCMC 

 Document history of customary, 

traditional, and contemporary uses of the 

Cannery and adjacent areas of Hawk 

Inlet. The first step in the process will be 

for Greens Creek Mine to submit a study 

plan to the Forest Service for approval. 

3.17 TDF HGCMC 

Wildlife and 

Subsistence 

HGCMC employees prohibited from 

hunting. 

3.11, 3.16 Site-wide HGCMC 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪29

Table 2. Required Mitigation Measures by Resource (continued) 

Resource Measure 

Section in 

the EIS Site Responsibility 

Wildlife and 

Subsistence 

(continued) 

To reduce the potential for impacts to 

nesting migratory birds, ground 

disturbing activities and tree clearing 

should be conducted outside the nesting 

season in the region (late May through 

early July). 

3.11.4 TDF HGCMC 

Air, Water, Soil 

and Aquatics 

Review current practices and update as 

necessary to be consistent with Forest 

Service National Core BMPs (Forest 

Service 2012) to avoid, minimize, or 

mitigate adverse effects to soil, water 

quality and riparian resources that may 

result from mining and milling activities. 

Update GPO accordingly. 

3.2, 3.3, 3.4, 

3.5, 3.6, 3.7, 

3.8, 3.9 

Site-wide HGCMC 

*New requirement. Requirements not marked by asterisks are required by previous decisions or existing 

permits or plans and made part of this decision. 

In addition to the requirements listed in Table 2 (Table 2.6-1 of the Final EIS), my 

decision also includes the following requirements: 

 Greens Creek Mine will maintain its post-closure water quality model and update 

the model with observed water quality and hydrologic data. Results of the model, 

predications of post-closure water quality, and interpretation of the model results 

will be provided in a report to the Forest Service prior to the five-year 

environmental audit required by the ADEC Waste Management Permit such that 

the results can be incorporated into the audit. 

With the implementation of these measures, I conclude that all practicable means to avoid 

or minimize environmental harm from the Selected Alternative have been adopted. 

MONITORING 

Monitoring is a tool which involves gathering data and information and observing the 

results of management activities as a basis for evaluation. Monitoring activities can be 

divided into project-specific monitoring and Forest Plan monitoring. The NFMA requires 

national forests to monitor and evaluate their Forest Plans (36 CFR 219.110). Chapter 6 

of the Forest Plan includes the monitoring activities to be conducted as part of the Forest 

Plan implementation. Monitoring of the Selected Alternative will be done during 

implementation and also as part of the Forest Plan monitoring program. Specific 

monitoring items are outlined in Chapter 2 of the Final EIS. These monitoring items are 

part of this decision and will be implemented. 
Record of Decision 

30 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

FINDINGS REQUIRED BY LAW 

Alaska National Interest Lands Conservation Act 

Subsistence Evaluation and Findings (Section 810) 

A subsistence evaluation was conducted for the five EIS alternatives, in accordance with 

ANILCA Section 810. ANILCA 810 subsistence hearings were conducted in the 

communities of Hoonah and Angoon, Alaska, with open public phone lines as advertised 

in the Juneau Empire and the community of Tenakee Springs, in September and 

November of 2012, respectively, and are discussed in detail in Appendix G. The hearings 

and subsequent evaluation conclude that none of the action alternatives, including the 

Selected Alternative, will result in a significant possibility of a significant restriction on 

access to, or use of, any subsistence resources. 

Protection of Admiralty Island National Monument (Section 503(i)(1)) 

Based on my review of the entire project record, and for the reasons described in the 

Rationale for the Decision section of this ROD, I have determined: 

 that the additional disposal of tailings authorized under the Selected Alternative 

cannot be feasibly carried out on the valid mining claims within Admiralty Island 

National Monument or other land owned by Hecla Greeks Creek Mine; 

 that the use of the site to be leased under the Selected Alternative for additional 

storage of tailings from Greens Creek Mine will not cause irreparable harm to the 

Admiralty Island National Monument; and 

 that the use of such leased area for such purposes will cause less environmental 

harm than the use of any other reasonably available location. 

Bald and Golden Eagle Protection Act 

The Selected Alternative was designed to be in compliance with the National Bald Eagle 

Management Guidelines published by the U.S. Fish and Wildlife Service to maintain 

habitat to support long-term nesting, perching and winter roosting habitat for bald eagles. 

The Guidelines recommend activities inconsistent with bald eagle use follow timing, 

distance, or landscape buffer restraints which vary with the type of activity and the 

landscape characteristics. During implementation, the Forest Service will consult with 

USFWS to ensure project activities meet the Guidelines. 

There are three bald eagle nest sites within one-half mile of the existing TDF, all of which 

were inactive in 2011. If nests in this area are found to be active prior to construction, 

including new nests established after 2011, the project would adhere to National Bald 

Eagle Management Guidelines. 

Clean Air Act 

Emissions from the implementation of the Selected Alternative are not expected to exceed 

State of Alaska ambient air quality standards (18 AAC 50). The Alaska Department of 

Environmental Conservation (ADEC) has issued air permits that serve as a framework for 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪31

the operation of the mine site. Permits are in place to regulate air emissions at the mine 

site. Operational guidelines and restrictions are identified in the permits to ensure air 

quality standards are maintained at the Greens Creek Mine property boundary during 

ongoing mining activities. 

Clean Water Act 

Project activities meet all applicable State of Alaska Water Quality Standards (WQS). 

Congress intended the Clean Water Act of 1972 (Public Law 92-500) as amended in 1977 

(Public Law 95-217) and 1987 (Public Law 100-4) to protect and improve the quality of 

water resources and maintain their beneficial uses. Section 313 of the Clean Water Act 

(CWA) and Executive Order 12088 of January 23, 1987 address Federal agency 

compliance and consistency with water pollution control mandates. Agencies must be 

consistent with requirements that apply to “any governmental entity” or private person. 

Compliance is to be in line with “all Federal, State, interstate, and local requirements, 

administrative authority, and process and sanctions respecting the control and abatement 

of water pollution.” The Forest Service strategy for control of nonpoint source pollution is 

to apply appropriate BMPs, evaluate BMP performance, and initiate corrective actions 

where objectives are not met. The Forest Service recently issued national core BMPs 

(Forest Service 2012) which have been incorporated into the mitigation measures for this 

project. 

On October 31, 2008, ADEC assumed initial authority over permitting, compliance, and 

enforcement of the Alaska Pollutant Discharge Elimination System (APDES) program, 

regulating point source discharges and stormwater runoff under Section 402 of the CWA. 

ADEC’s authority over mining APDES permits began on October 31, 2010. APDES 

permit limits and other requirements are established to ensure compliance with State WQS 

for both marine water and freshwater. The Greens Creek Mine’s National Pollutant 

Discharge Elimination System (NPDES) permit was assigned the designation of APDES 

when it transferred from the U.S. Environmental Protection Agency to ADEC under Phase 

III of the NPDES transfer of authority program. Until ADEC reissues the APDES, the 

conditions and limitations of the 2005 permit remain in effect. The permit establishes 

water quality-based effluent limits and monitoring requirements for treated process water 

being discharged to Hawk Inlet. It also establishes stormwater monitoring requirements at 

10 locations throughout the Greens Creek Mine area. 

Regulations in 36 CFR 228.8(h) state that “certification or other approval issued by state 

agencies or other federal agencies of compliance with laws and regulations relating to 

mining operations will be accepted as compliance... with these regulations.” The Forest 

Service therefore accepts the APDES permit as compliance with CWA requirements. 

Endangered Species Act 

There are no federally listed species managed by the USFWS within the project area. A 

biological assessment was prepared and sent to the National Marine Fisheries Service 

(NMFS) on March 22, 2013 as part of the Section 7 consultation under the Endangered 

Species Act. In a letter dated April 19, 2013 NMFS concurred with the findings of “Not 

likely to adversely affect” the federally listed humpback whales and stellar sea lions and 
Record of Decision 

32 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

“No effect” on federally listed Green Sturgeon, chinook salmon, sockeye salmon, coho 

salmon, and steelhead. The biological assessment is included in the project record. 

Magnuson-Stevens Fishery Conservation and 

Management Act 

The potential effects of the project on Essential Fish Habitat (EFH) were included in 

Chapter 3 of the Draft EIS. This discussion includes reference to the Magnuson-Stevens 

Fisheries Conservation Act that requires the Forest Service to consult with the National 

Marine Fisheries Service on projects that may affect EFH. It also includes a description 

of the EFH in the project area, a description of the proposed activities, and a description of 

the measures that will protect these essential habitats. 

The Draft EIS was provided to the National Marine Fisheries Service to initiate the 

consultation process according to the agreement dated June 26, 2007 between the Forest 

Service and the National Marine Fisheries Service. NMFS concluded that impacts to EFH 

under Alternative B would be “substantial and permanent,” noting direct effects to 

Tributary Creek and downstream resources. NMFS provided conservation 

recommendations in a letter dated July 19, 2012. I addressed each of their conservation 

recommendations in a response letter and will continue to consult with NMFS. The 

Selected Alternative will have less effect on EFH because it does not include the filling of 

anadromous or resident fish habitat of Tributary Creek. Information on the mitigation 

measures and applicable Standards and Guidelines to minimize effects to EFH are 

discussed in Chapter 3 of the Final EIS. A copy of the Final EIS and ROD will be sent to 

NMFS. This satisfies the EFH consultation requirement based on the 2007 agreement 

with NMFS. 

Marine Mammal Protection Act 

By extending the mine life, exposure of marine mammals in Hawk Inlet and Young Bay 

to disturbance and noise associated with the marine terminal, barge and crew shuttle 

traffic, and the potential for fuel or oil spills would be unchanged from current operations 

for an additional 10 years. Marine mammal viewing guidelines administered by NMFS 

and enforced by the Coast Guard are sufficient for their protection. Contractors, 

purchasers and employees will be required to follow provisions on Marine Wildlife 

Guidelines, including special prohibitions on approaching humpback whales in Alaska as 

defined in 50 CFR 224.103. NMFS administers the Marine Mammal Protection Act 

(MMPA), which prohibits the “take” of all marine mammal species in U.S. waters. 

“Take” is defined as “to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, 

or kill any marine mammal.” Harassment is defined in the MMPA as “any act of pursuit, 

torment, or annoyance which has the potential to injure a marine mammal or marine 

mammal stock in the wild; or has the potential to disturb a marine mammal stock in the 

wild by causing disruption of behavior patterns, including, but not limited to, migration, 

breathing, nursing, breeding, feeding, or sheltering.” 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪33

2008 Forest Plan 

I have determined that this decision and the Greens Creek Mine Tailings Disposal Facility 

Expansion Final EIS are consistent with the 2008 Forest Plan. 

National Historic Preservation Act 

Archaeological resource surveys of various intensities have been conducted in the analysis 

area in accordance with the Regional Inventory Strategy. A finding of “no adverse effect” 

was recommended for all alternatives for the EIS. The Alaska State Historic Preservation 

Officer was given the opportunity to comment on the Determination of Effect and has 

concurred with the Agency’s Determination. 

Executive Orders 

Executive Order 11988 (Floodplains) 

Executive Order 11988 directs federal agencies to take action to avoid, to the extent 

possible, the long- and short-term adverse effects associated with the occupancy and 

modification of floodplains. The Selected Alternative does not affect floodplains as 

defined by Executive Order 11988. 

Executive Order 11990 (Wetlands) 

Executive Order 11990 requires federal agencies to avoid, to the extent possible, the long 

and short-term adverse effects associated with the destruction or modification of wetlands. 

It is not feasible to avoid all wetland areas due to the extent of wetlands in the project area 

and the technical constraints of constructing a geotechnically stable facility. I have 

determined that the Selected Alternative includes all reasonable measures to minimize 

harm to wetlands, which may result for such use. A separate permit, issued by the 

USACE, is required for all wetland fill. 

The Selected Alternative will affect about 14 acres of wetlands. Approximately 8 acres of 

these wetlands will be covered with the tailings disposal facility and the area cannot be 

reclaimed as wetlands at closure of the mine. Water management pond development will 

fill about 2 acres of wetlands. These acres are considered a permanent loss of wetlands 

and mitigation will occur under the CWA according to a USACE permit. These affected 

wetlands are the headwaters of the Tributary Creek channel. The remaining 4 acres of 

wetlands lost will occur near the junction of the A and B Roads where reclamation 

material will be stored. 

Executive Order 12898 (Environmental Justice) 

Executive Order 12898 directs federal agencies to address whether a disproportionately 

high and adverse human health or environmental impact on minority populations, lowincome populations, or Indian tribes is likely to result from the proposed action and any 

alternatives. 

Minority communities in the vicinity of the project area include the communities of 

Angoon and Hoonah, each home to a federally recognized tribe. There are no 

communities within the project area. The Selected Alternative is not expected to have a 
Record of Decision 

34 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

disproportionately high and adverse effect on the health or well-being of the minority or 

low-income populations that may use the project area. 

The Executive Order directs agencies to consider patterns of subsistence hunting and 

fishing when an agency action may affect fish or wildlife. Although low-income and 

minority people are not the sole users of these resources in Alaska, the effects on these 

resources are addressed in Chapter 3 of the Final EIS. Any changes in consumption 

patterns and wild food resources, as well as other project effects, would be equally 

applicable to the general population. 

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) 

Executive Order 12962 requires federal agencies to evaluate the effects of proposed 

activities on aquatic systems and recreational fisheries. The Selected Alternative 

minimizes the effects on aquatic systems through project design, application of standards 

and guidelines, BMPs, and site-specific mitigation measures. The Selected Alternative 

does not allow Greens Creek Mine to fill any Class I or Class II stream and eliminates the 

proposed western perimeter road, which would have crossed an anadromous stream. The 

Selected Alternative does not require the widening or upgrading of the existing road. 

Only one new 160 - foot road will be constructed as a result of this decision; no stream 

crossings will be required. Greens Creek Mine is required to repair a damaged fish 

passage facility in Greens Creek and maintain the structure in perpetuity. As a result, 

recreational fishing opportunities will remain essentially the same as the current condition 

because aquatic habitats are protected through implementation of BMPs and riparian 

buffers. 

Executive Order 13007 (Indian Sacred Sites) 

Executive Order 13007, Indian Sacred Sites, provides presidential direction to federal 

agencies to give consideration to the protection of American Indian sacred sites and allow 

access where feasible. In a government-to-government relationship, the tribal government 

is responsible for notifying the agency of the existence of a sacred site. A sacred site is 

defined as a site that has sacred significance due to established religious beliefs or 

ceremonial uses, and which has a specific, discrete, and delineated location that has been 

identified by the tribe. The Angoon Community Association has identified Hawk Inlet, 

the Hawk Inlet Cannery, and the Hawk Inlet overland route as sacred places. Access to 

the federally managed lands in the Hawk Inlet area, including the overland route, will 

remain unrestricted to the traditional uses identified by the Angoon Community 

Association. The Forest Service will continue to work with the Angoon Community 

Association and other tribal entities in identifying and protecting sacred places in the 

Hawk Inlet area. 

Executive Order 13112 (Invasive Species) 

Executive Order 13112 requires federal agencies (in part) to evaluate whether the 

proposed activities will affect the status of invasive species; and to not carry out activities 

that promote the introduction or spread of invasive species unless it has determined that 

the benefits of such action outweigh the potential harm caused by invasive species; and 

that all feasible and prudent measure to minimize risk of harm will be taken in conjunction 
Record of Decision

Greens Creek Mine Tailings Disposal Facility Expansion Record of Decision ▪35

with the actions. The Selected Alternative implements specific measures to minimize the 

introduction and spread of invasive species. 

Executive Order 13175 (Consultation with Indian Tribal Governments) 

Executive Order 13175 directs federal agencies to respect tribal self-government, 

sovereignty, and tribal rights, and to engage in regular and meaningful government-togovernment consultation with tribes on proposed actions with tribal implications. 

Throughout the span of the Greens Creek EIS process, the District Ranger invited 

consultation with the Central Council of the Tlingit and Haida Indian Tribes of Alaska, the 

Angoon Community Association, Douglas Indian Association, Kootznoowoo, Inc., 

Hoonah Indian Association, Huna Totem Inc., Goldbelt Inc., and Sealaska Inc. 

Consultation took place with all tribal organizations except Hoonah Indian Association, 

Hoonah Totem Inc., Goldbelt Inc., and Sealaska Inc. Extensive consultation and updates 

were performed regularly between the District Ranger and Angoon Community 

Association and Kootznoowoo Inc. Tribal consultation does not imply that the tribes 

endorse the selected action or any of the alternatives. 

Executive Order 13186 (Migratory Birds) 

The Migratory Bird Treaty Act of 1918 (amended in 1936 and 1972) prohibits the taking 

of migratory birds, unless authorized by the Secretary of Interior. The law provides the 

primary mechanism to regulate waterfowl hunting seasons and bag limits, but its scope is 

not just limited to waterfowl. The migratory species that may stay in the area utilize most, 

if not all, of the habitats described in the analysis for breeding, nesting, and raising their 

young. The effects on these habitats were analyzed for this project. 

The decision will not have a significant direct, indirect, or cumulative effect on any 

migratory bird species in the project area. Effects of the Selected Alternative will be 

minor due to the amount of overall clearing and low potential for population-level impacts 

to migratory birds; surrounding habitat would remain functional and could maintain the 

species. 

Federal and State Permits 

Federal and State permits necessary to implement the authorized activities are listed at the 

end of Chapter 1 in the Final EIS. 

Implementation Process and Process for Considering 

Changes and New information 

Implementation of this decision may occur no sooner than 50 days following publication 

of the legal notice of the decision in the Ketchikan Daily News, the newspaper of record, 

published in Ketchikan, Alaska. Implementation of activities authorized by this ROD will 

be monitored to ensure that they are carried out as planned and described in the Final EIS. 

Minor changes are expected during implementation to better meet on-site resource 

management and protection objectives. 

Proposed changes to the authorized project actions or new information will be subject to 

the requirements of the National Environmental Policy Act (NEPA), the National Forest 
Record of Decision 

36 ▪ Record of Decision Greens Creek Mine Tailings Disposal Facility Expansion 

Management Act of 1976, Section 810 of the ANILCA, and other laws concerning such 

changes. 

Changes made during implementation will be reviewed, documented, and approved by the 

Responsible Official through the Tongass Change Analysis process (Tongass National 

Forest Supplement Forest Service Handbook (FSH) 1909.15-2009-1). In determining 

whether and what kind of NEPA action is required for changes during implementation, the 

Forest Supervisor will consider the criteria in the Code of Federal Regulations (40 CFR 

1502.9(c)) and FSH 1909.15, sec. 18 to determine whether to supplement or revise an 

existing environmental impact statement. I will determine whether the proposed change is 

a substantial change to the Selected Alternative as planned and already approved, and 

whether the change is relevant to environmental concerns. Connected or interrelated 

changes to particular areas or specific activities will be considered in making this 

determination. The cumulative impacts of these changes will also be considered. 

Right to Appeal 

This decision is subject to administrative review (appeal) pursuant to Title 36 CFR Part 

215. Individuals or organizations who submitted comments during the comment period 

specified at 36 CFR 215.6 may appeal this decision. The notice of appeal must be in 

writing, meet the appeal content requirements at 36 CFR 215.14 and be filed with the 

Appeal Deciding Officer: 

Beth Pendleton, Regional Forester 

Alaska Region 

US Department of Agriculture 

709 W. 9th Street 

P.O. Box 21628 

Juneau, AK 99802-1628 

Email address: appeals-alaska-regional-office@fs.fed.us 

Fax (907) 586-7840 

The Notice of Appeal, including attachments, must be filed (regular mail, fax, e-mail 

express delivery or messenger service) with the Appeal Deciding Officer at the correct 

location within 45 calendar days of the date that the legal notification of this decision is 

published in the Ketchikan Daily News, the official newspaper of record. The publication 

date in the newspaper of record is the exclusive means for calculating the time to file an 

appeal. Those wishing to appeal this decision should not rely upon dates or timeframe 

information provided by any other source. 

Hand-delivered appeals will be accepted at the Regional Office during normal business 

hours (8:00 a.m. through 4:30 p.m.), Monday through Friday, excluding holidays. 

When appeals are filed, implementation may occur on, but not before, the 15th business 

day following the date of the last appeal disposition. If no appeals are received, 

implementation of decisions subject to appeal pursuant to 36 CFR Part 215 may occur on, 

but not before, 5 business days from the close of the appeal filing period. 


Greens Creek Mine

Tailings Disposal Facility Expansion

Final Environmental Impact Statement

United States Department of Agriculture, Forest Service Alaska Region

Lead Agency: USDA Forest Service

Tongass National Forest

Cooperating Agencies: U.S Army Corps of Engineers 

U.S. Environmental Protection Agency 

State of Alaska

City and Borough of Juneau 

Responsible Official: Forrest Cole, Forest Supervisor 

648 Mission Street

Ketchikan, Alaska 99901 

For Information Contact: Chad VanOrmer

Monument Ranger 

Admiralty Island National Monument

8510 Mendenhall Loop Road

Juneau, AK 99801 

(907) 789-6202 

Abstract: The purpose and need for the environmental impact statement includes evaluating the 

impacts associated with an expansion of the tailings disposal facility (TDF) at an active lead/zinc 

mine located within the Admiralty Island National Monument (Monument) in Southeast Alaska. The 

scoping process identified water quality, aquatic resources, wetlands, and Monument resources as 

significant issues. The analysis includes five alternatives:

Alternative A (No Action) proposes no new authorization to expand the TDF. Authorized ongoing 

activities would continue until the TDF reaches full capacity in about 2019. 

Alternative B (Proposed Action) calls for a 30- to 50-year expansion of facilities within the 

Monument. 

Mitigated Alternative B presents a modification of the proposed action that reduces expansion within 

the Monument. Mitigated Alternative B was considered in the Draft EIS, but not as a standalone 

alternative. For ease of comparison, the Final EIS has been revised to include Mitigated Alternative 

B as a standalone alternative.

Alternative C calls for some expansion of the TDF to accommodate an additional 3 years of tailings 

disposal. A new TDF would be built to the north to accommodate additional tailings disposal, 

extending the life of the mine an additional 30–50 years.

Alternative D calls for some expansion of the TDF to accommodate an additional 10 to

15 years of tailings disposal. A new TDF would be built to the north to accommodate additional 

tailings disposal, extending the life of the mine an additional 30–50 years.

Alternative B is the preferred alternative.
ii Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 
Summary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS iii

SUMMARY 

This environmental impact statement (EIS) was developed in support of the Tongass 

National Forest’s proposal to modify the existing General Plan of Operations (GPO) for 

the Greens Creek Mine. The Greens Creek Mine is located on Admiralty Island 

approximately 18 miles southwest of Juneau, Alaska. The mine has been in operation 

since 1989 with a 2-year period of temporary closure. Major mine facilities include the 

underground mine, mill, waste rock disposal areas, tailings disposal facility (TDF), a port 

site and camp, roads and power infrastructure among the mine components. The mine 

produces lead and zinc concentrates that also contain silver. The Greens Creek Mine is 

operated by Hecla Greens Creek Mining Company (HGCMC). 

HGCMC has proposed a modification to its GPO to expand the TDF so that it can 

accommodate an additional 30 to 50 years’ worth of tailings and waste rock. Tailings are 

disposed via dry stacking along with co-disposed waste rock. The TDF is currently 

approved to hold 5.3 million cubic yards of tailings and waste rock and cover 

approximately 62 acres. At the current mining rate, the TDF will be filled to capacity in 

2019. This represents a change from information presented in the 2012 Draft EIS, which 

indicated that there was enough capacity to accommodate waste placement through 

approximately 2014. This change is based on revised input received from HGCMC. In 

order to continue operations, HGCMC has requested an expansion of the TDF to hold an 

additional 14.2 million cubic yards of tailings and waste rock. 

Major portions of the mine are located on National Forest System lands and most of the 

TDF is located in the Admiralty Island National Monument (Monument). The Forest 

Service, U.S. Department of Agriculture (Forest Service) developed the first EIS for the 

Greens Creek Mine in 1983 and approved the original GPO in 1984. As common with 

large mines, there have been changes to the GPO since mine development. The Forest 

Service has approved various GPO modifications and developed documents under the 

National Environmental Policy Act (NEPA), where applicable, for these approvals. The 

NEPA background is described in Chapter 1 of this EIS. 

This EIS focuses on evaluation of the environmental effects associated with expansion of 

the TDF and alternatives. The Forest Service is the lead agency in preparing this EIS. 

The cooperating agencies participating in the EIS process include the U.S. Army Corps 

of Engineers (USACE), the U.S. Environmental Protection Agency (USEPA), the State 

of Alaska (represented by the departments of Natural Resources, Environmental 

Conservation, and Fish and Game) and the City and Borough of Juneau (CBJ). These 

agencies are cooperating agencies because they also need to comply with NEPA, or they 

are using the NEPA analysis for their own decisions, or they bring special expertise to 

assist the Forest Service in developing the EIS. Chapter 1 provides information on the 

permits and approvals required by the cooperating agencies and other agencies for 

expansion of the TDF. 

Purpose and Need and Federal Decisions to be Made 

The purpose and need for the federal actions covered by this EIS is to act on HGCMC’s 

proposed modification to the GPO to expand the TDF. Specifically, HGCMC is 

proposing to extend the footprint of the existing TDF south into the Monument providing 

capacity for an additional 14.2 million cubic yards of tailings and waste rock. In addition 
Summary 

iv Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

to increased disposal capacity and disturbance footprint, the proposed action would 

include an increase of the HGCMC’s existing lease area to accommodate additional 

tailings disposal. Ancillary facilities associated with the TDF, combined with the TDF 

expansion itself, would result in a total of 115 acres of new disturbance under the 

proposed action. 

The Forest Service will make a decision on HGCMC’s GPO modification proposal and 

will decide whether to select the proposed action or another alternative for 

implementation. In addition, the Forest Service could add stipulations or require 

additional mitigation measures. 

Expanding the TDF or creation of a new TDF would require the discharge of fill material 

into waters of the U.S. This activity requires a Clean Water Act (CWA) Section 404 

permit. Therefore, the USACE’s decision is whether to issue or deny the CWA 404 

permit. The USACE could also add stipulations or require additional mitigation 

measures. 

Scoping and Significant Issues 

The Notice of Intent (NOI) to prepare the EIS for the Greens Creek Mine TDF Expansion 

Project was published in the Federal Register on October 5, 2010. The publication of the 

NOI initiated the scoping process and a public review and comment period required 

under NEPA. Scoping is a process intended to assist the Forest Service and the 

cooperating agencies in identifying areas and issues of concern associated with the 

proposed TDF expansion, and is designed to ensure that all significant issues are fully 

addressed during the course of the EIS process. 

Public scoping meetings were held on October 14, 2010, in Juneau and on October 15, 

2010, in Angoon. Oral and written comments were accepted at the public scoping 

meetings and throughout the scoping process. The Forest Service collected additional 

comments sent from the public; local, state, and federal agencies; non-governmental 

organizations; professional and trade organizations; and native corporations and tribal 

organizations. The formal scoping period ended on November 19, 2010. 

Scoping comments were distilled into significant issues that were used to develop 

alternatives to the proposed action and identify key areas that need to be addressed in the 

environmental impacts analysis. The following significant issues of public concern were 

identified by the Forest Service as key issues to be addressed in this EIS. 

Issue 1: Water quality may be impacted directly by runoff from acid-generating material 

or by direct impacts of the expanded facilities or by permitted marine discharges of mine 

water. The impacts to water quality could adversely impact aquatic life. 

Issue 2: Expansion of the mine TDF may cause direct and indirect impacts to wetlands. 

Loss of wetlands can affect migrating and resident birds as well as other wildlife species. 

Any impacts to wetlands must be mitigated. 

Issue 3: Construction of the tailings and waste rock disposal facility, contact water ponds, 

and roads along or over creeks could negatively impact anadromous and resident 

salmonids and other fish species. 

Issue 4: The Greens Creek Mine and proposed expansion occurs partially within the 

Admiralty Island National Monument. The Monument was established for the purpose of 
Summary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS v

protecting objects of ecological, cultural, geological, historical, prehistorical, and 

scientific interests. Any lease of Monument lands for mining must not cause irreparable 

harm to Monument resources. 

Other Issues: Other issues were identified during the scoping process as important, but 

did not influence the development of alternatives. These issues were taken into 

consideration in the impact analysis and development of mitigation measures. These 

issues included air quality and dust concerns, adequacy of financial assurance for mine 

closure and long-term water treatment, and potential impacts to transportation and utility 

corridors. 

Chapter 1 of the EIS describes these issues in more detail and metrics that guided the 

impact analysis in relation to the issues. 

Alternatives 

Based on the proposed action and the significant issues, the Forest Service and 

cooperating agencies developed the following alternatives for analysis in this EIS: 

 Alternative A (No Action): Under this alternative, tailings disposal (and therefore 

mining) would cease in approximately 2019 when the currently approved TDF 

reaches its full capacity. The TDF would be reclaimed and closed. 

 Alternative B (Proposed Action): Under this alternative, the tailings lease area and 

TDF footprint would be extended south into the Monument providing capacity to 

dispose of an additional 14.2 million cubic yards of tailings and waste rock. This 

equates to an additional 30–50 years of mine life. 

 Mitigated Alternative B: The TDF, reclamation material storage areas and quarry 

would be reconfigured to reduce disturbance within the Monument. Tailings 

placement would be extended to the northeast of the existing TDF. Reclamation 

material storage areas and one quarry would be developed to the north of the existing 

TDF providing capacity to dispose of an additional 14.2 million cubic yards of 

tailings and waste rock. This equates to an additional 30–50 years of mine life. 

 Alternative C (TDF located outside the Monument on the Juneau Ranger District): 

The existing TDF would be expanded to accommodate an additional 1 million cubic 

yards of tailings (approximately three additional years of capacity). A new, separate 

TDF would be built outside the Monument with capacity to accommodate an 

additional 13.2 million cubic yards of tailings and waste rock. 

 Alternative D (Modified Proposed Action): The existing TDF would be expanded to 

accommodate an additional 3 million cubic yards of tailings (approximately 10 years 

of capacity). A new, separate TDF would be built outside the Monument on the 

Juneau Ranger District to accommodate an additional 11.2 million cubic yards of 

tailings and waste rock disposal corresponding to a total mine life of an additional 

30–50 years. 

The major difference among the alternatives is the location and configuration of the TDF 

(or TDFs). The type of tailings disposal (dry stack), TDF construction methods, water 

management and treatment, and reclamation and closure plans are the same for all 

alternatives. In addition, mining, milling, and concentrate transport are the same for all 

alternatives. Alternatives C, D, and Mitigated Alternative B would require pumping of 

the effluent from additional TDF collection points to a water treatment plant that would 
Summary 

vi Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

be required as long as active treatment is required in order to meet Alaska Water Quality 

Standards (WQS), perhaps in perpetuity. 

Each of the action alternatives (B through D) also includes construction of water 

management ponds, access roads, and laydown areas for storage of reclamation materials. 

In addition, rock quarries would be needed to obtain materials to construct the TDF 

extension (or new TDF). Table ES-1 provides the estimated disturbance areas for the 

alternatives. The alternatives are described in detail in Chapter 2. 

Table ES-1. Estimated TDF Disturbance for No Action and Action Alternatives (in Acres). 

Project Component b Alternative A b Alternative B b Mitigated 

Alternative B b Alternative C b Alternative D b

Tailings — a 48 43 111 104 

Reclamation Material 

Storage — a 19 13 10 14 

Quarry — a 17 15 8 15 

Ponds — a 12 14 7 7 

Roads, including ditches 

and pipelines — a 30 b 39 b 36 b 43 b

Truck Wheel Wash — a 1 1 1 1 

Water Treatment Plant — a 1 1 1 1 

Total New Disturbance b — a 128 b 126 b 174 b 185 b

Total Disturbance 65 c 181 167 224 245 

New disturbance within the 

Monument 0 100 69 2.3 23.3 

Notes: 

a. Component of the existing disturbance associated with tailings disposal. 

b. Includes 26 acres of existing ancillary disturbance that would be redisturbed under all action alternatives.

c. Total disturbance following the 2003 ROD. 

Identification of the Environmentally Preferred and Preferred Alternatives 

The Council on Environmental Quality (CEQ) recommends that an environmentally 

preferred alternative be identified during the preparation of the EIS although NEPA 

requires that the environmentally preferred alternative be identified in the Record of 

Decision (ROD). The environmentally preferable alternative is the alternative (or 

alternatives) that has the least impact on the physical and biological environment and 

which best protects, preserves, and enhances historic, cultural, and natural resources. 

Economic, social, technical, and agency mission factors are not considered in the 

identification of this alternative. 

The regulations implementing NEPA (40 CFR 1502.14(e) requires that a preferred 

alternative is identified in the Draft EIS, if one exists, and that a preferred alternative is 

identified in the Final EIS. The following subsections discuss the environmentally 

preferred and preferred alternatives. 

Environmentally Preferred Alternative 

Alternative A (No Action) is the environmentally preferable alternative because it would 

not result in additional impacts to the environment from expansion of the tailings facility. 
Summary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS vii

Alternative B is the most environmentally preferable of the action alternatives. This 

alternative meets the purpose and need, includes reasonable mitigation to protect 

resources, requires the smallest overall physical disturbance, and results in smallest 

overall disturbance to wetlands. Alternative B would affect fewer acres of productive old 

growth (POG) and winter deer range habitat compared to alternatives C and D. While 

Alternative B would result in the largest increase in disturbance within the Monument 

and would result in the filling of over 4,000 feet of Tributary Creek, a Class I fish stream, 

it would confine the tailings within a single facility and minimize the footprint and 

infrastructure requirements for post-closure long-term water management, including 

allowing the entire TDF to gravity-drain to a single collection point. 

Forest Service Preferred Alternative 

Alternative B is the preferred alternative because it confines the TDF expansion to the 

Tributary Creek watershed (limiting impacts on Cannery and Fowler Creek watersheds) 

and avoids constructing a second facility and associated operational, maintenance, and 

management requirements. 

Affected Environment and Environmental Consequences 

Chapter 3 of the Final EIS describes the affected environment and environmental 

consequences for each alternative. Because this EIS is focused on expanding tailings 

disposal capacity, the project area for the impact assessment includes the areas and 

watersheds of the proposed TDF expansion. Areas beyond the TDF are also described 

and consequences evaluated if they could be subject to indirect or cumulative effects for a 

particular resource. 

Chapter 3 is divided into separate sections for each resource considered in the EIS (e.g., 

air, wetlands, water quality, cultural resources, etc.). Each resource section is further 

divided into subsections that provide the following information: 

Pre-mining environment: An overview of the pre-mining environment is provided 

based on information in the 1983 EIS. This information is simply summarized since the 

reader can refer to the 1983 EIS for more detail. 

Current (baseline) conditions: The current (baseline) conditions for each resource are 

described. Since the mine has been in operation for more than 20 years, the baseline 

conditions may include impacts that have occurred as a result of existing operations. 

Environmental consequences of each alternative: The environmental consequences 

sections consider the future impacts that would occur for each of the alternatives based on 

the current conditions. When the EIS identified potential impacts, mitigation measures 

were identified to reduce impacts. In addition, monitoring is identified to assess the 

effectiveness of mitigation measures and allow for adaptive management decisions to 

revise the measures. In addition, monitoring is identified where there is some uncertainty 

associated with the impacts analysis. 

A summary of the predicted environmental effects for each resource area for the 

proposed action and alternatives is presented in Table ES-2. 
Summary 

viii Greens Creek Mine Tailings Disposal 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource. 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Duration of Mine Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 

Air Quality Uncontrolled: PM10-2.5

tons per year (tpy) 

142 171 164 233 

 PM2.5 tpy 17 22 21 30  Controlled: PM10-2.5

tpy 

77 90 87 123 

 PM2.5 tpy 9 12 11 16  Greenhouse gas 

emissions (tons CO2 

emissions per year) 

707 707 707 946 

Water Resources–Surface Water 

Percent of watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 20 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 11 

Tributary Creek: 15 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 3 South Hawk Inlet: 11 

Tributary Creek: 3 Cannery Creek: 2 Fowler Creek: 2 North Hawk Inlet: 11 Middle Hawk Inlet: 1 South Hawk Inlet: 2 

 Total acres of 

watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 81 Cannery Creek: 19 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 28 

Tributary Creek: 62 Cannery Creek: 23 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 12 South Hawk Inlet: 29 

Tributary Creek: 12 Cannery Creek: 15 Fowler Creek: 107 North Hawk Inlet 28 Middle Hawk Inlet: 6 South Hawk Inlet: 6 

 Reduction in stream 

flow 

Minor reduction of flow in two creeks (Tributary and Cannery) 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A. Impacts to Tributary Creek slightly less than Alternative B. 

Minor reduction in flow in three creeks (Tributary, Canneryand Fowler) 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Duration of Mine Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 

Water Resources–Surface Water (continued) 

Additional water management infrastructure such as diversions, groundwater slurry walls, and water management ponds 

Yes as TDF expands to currently approved size 

Yes; more water management infrastructure required than Alternative A 

Yes; more water management infrastructure required than Alternative B; additional water management infrastructure required, including construction and maintenance of pipeline and pump stations. 

Yes; more total infrastructure requirthan Alternative B aAlternative Mitigated B; additional water management infrastructure requirfor new TDF, including constructioand maintenance of pipeline and pump stations 

 Need for long-term 

water treatment 

Yes Yes Yes Yes 

Water Resources–Groundwater 

Change in flow or quality 

Minimal effect on local hydrogeology; no impacts to groundwater quality 

Similar to Alternative A Similar to Alternative A Similar to Alternative 

A but new TDF located in additionagroundwater area 

Aquatic Resources 

Habitat permanently lost (feet) 

Class I Tributary: 0 

Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 0 Fowler: 0 

Class II Tributary: 0 

Fowler: 0 

Tributary: 2,400 Fowler: 0 

Tributary: 1,169 Fowler: 0 

Tributary: 0 Fowler: 1,044 

Risk of chemical or mining product spill 

Low, due to BMPs and Spill Prevention, Control, and Countermeasure Plan requirements 

Similar to Alternative A, although risk would continue over 30 to 50 years due to extended operations 

Similar to Alternative B Similar to Alternative 

B except the area opotential spills would expand to include Fowler Creek drainage 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Summary 

x Greens Creek Mine Tailings Disposal 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Geochemistry Likelihood of TDF 

ARD developing (uncontrolled) 

Low due to very low permeability, low availability of oxygen and closure and reclamation of TDF 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Geotechnical Stability 

Likelihood of TDF failure 

Very low probability of TDF failure due to design measures 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Soils New loss in soil 

productivity (measured in acres disturbed) 

0 128a 126a 174a 

Vegetation Acres of new 

disturbance 

0 POG: 73 acres 

Unproductive forest: 55 acres 

POG: 64 acres Unproductive forest: 62 acres 

POG: 114 acres Unproductive forest60 acres 

Off-site effects Elevated metals levels in 

lichens may continue through life of operations; duration of effects would depend on the effectiveness of control measures 

Similar to Alternative A; however, off-site effects may continue longer due to longer mine life 

Similar to Alternative B Similar to 

Alternative B 

Wetlands Acres and types of 

new disturbance 

0 Bog/Bog Woodland: 20 

Forested: 36 Sedge Fen/Fen: 28 Marsh: 1 Total: 85 

Bog/Bog Woodland: 12Forested: 35 Sedge Fen/Fen: 27 Marsh: 3 Total: 77 

Bog/Bog WoodlandForested: 78 Sedge Fen/Fen: 25 Marsh: 1 Total: 112 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Wildlife New decrease in 

brown bear buffers (acres) 

None 30 29 6 

New removal of POG habitat (acres) within brown bear buffers 

None 35 27 5 

Duration of activities that could disturb wildlife and marine mammals 

Through 2019 Additional 30–50 years Additional 30–50 years Additional 

30-50 years 

New temporary reduction in deer winter range habitat (acres) 

None 128 125 174 

Result in “take” of Endangered Species Act (ESA)-listed speciesb

No No No No 

Number of goshawk nests potentially affected 

0 0 0 1 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Summary 

xii Greens Creek Mine Tailings Disposal 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Threatened (FT) and endangered (FE) species / Forest Service Sensitive Species (FSS)/Forest Service Rare (FSR) 

Humpback whale (FE)b Not likely to adversely effect 

Steller sea lions (FE)b Not likely to adversely effect Yellow-billed loon (candidate and FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, 

federal listing 

Chinook salmon; coho salmon; sockeye salmon; steelhead (FT or FE, depending on the run) 

No effect 

Green Sturgeon (FT) No effect Pacific Herring (candidate and FSS 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Queen Charlotte goshawk (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Black oystercatcher (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Mountain lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Large yellow lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Alaska rein orchid 

(FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Bog adder's-mouth 

orchid (FSR) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Land Use Meet management 

prescriptions 

Yes Yes Yes Yes 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Recreation Duration of operations 

(when public may be excluded from areas) 

Through 2019 plus reclamation period 

Additional 30–50 years plus reclamation period 

Additional 30–50 years plus reclamation period

Same duration as Alternative B; disturbance at new TDF initiated in approximately 3-5 years 

Scenic Resources 

Compliance with applicable scenic integrity objective (SIO) 

Yes Yes Yes Yes 

 Duration of visual 

effects 

Around 2019 plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Reclamation at existing TDF to begin approximately 3-5 years; reclamatiof new TDF at end omining activity (30-50 years); reclamation establishment perioapplies to both facilities 

 Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion acurrent location and new site to the north 

Subsistence Duration of mine life Through 2019 30–50 more years 30–50 more years 30–50 more years 

New temporary reduction in deer winter range habitat (acres) during operations and until forested canopy develops post reclamation 

None 128 125 174 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
Summary 

xiv Greens Creek Mine Tailings Disposal 

Table ES-2. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Subsistence (continued) 

Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion acurrent location and new site to the north 

Cultural Resources 

Effects on historic properties 

Historic properties not adversely affected; Hawk Inlet identified as a sacred place by Angoon affected over the long term 

Same as Alternative A Same as Alternative A Same as Alternative 

Socioeconomics Duration of annual economic and 

employment benefit from operations 

Through 2019 30–50 more years 30–50 more years 30–50 more years 

Monument Resources 

New disturbance within Monument (acres) 

0 

104 83 18 

 Post-mining condition Near-natural condition 

following reclamation 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Environmental Justice 

Disproportionately affect minority or low income populations 

No No No No 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xv

Table of Contents 

Chapter 1. Purpose and Need for the Proposed Action ......................................................... 1-1

1.1 Background ................................................................................................................. 1-1

1.2 Purpose and Need ....................................................................................................... 1-7

1.3 Proposed Action .......................................................................................................... 1-7

1.4 Decisions to Be Made ................................................................................................. 1-8

1.5 Scoping and Public Involvement ................................................................................ 1-9

1.5.1 Scoping ............................................................................................................... 1-9

1.5.2 Draft Environmental Impact Statement ............................................................ 1-11

1.5.3 Alaska National Interest Land Conservation Act Section 810 Hearings .......... 1-11

1.6 Government-to-Government Tribal Consultations and Native Corporation 

Consultations .................................................................................................... 1-11

1.7 Significant Issues ...................................................................................................... 1-12

1.8 Agency Responsibilities, Approvals, and Compliance ............................................. 1-15

1.8.1 Applicable Laws, Statutes and Ordinances ...................................................... 1-15

1.8.2 Permits and Decisions for Continued Operation of the Greens Creek 

Mine ................................................................................................................. 1-16

1.8.3 Federal Agencies .............................................................................................. 1-16

1.8.4 State and Local Government ............................................................................ 1-25

Chapter 2. Description of Proposed Action and Other Alternatives .................................... 2-1

2.1 Greens Creek Mine Overview ..................................................................................... 2-1

2.2 Issues and Alternative Development ........................................................................... 2-2

2.3 Alternatives ................................................................................................................. 2-3

2.3.1 Alternative A: No Action Alternative ................................................................ 2-4

2.3.2 Alternative B: Proposed Action ......................................................................... 2-6

2.3.3 Mitigated Alternative B ...................................................................................... 2-8

2.3.4 Alternative C: New TDF Located Outside Monument .................................... 2-10

2.3.5 Alternative D: Modified Proposed Action ....................................................... 2-15

2.3.6 Identification of the Environmentally Preferred and Preferred 

Alternatives ...................................................................................................... 2-19

2.4 Project Component Details ....................................................................................... 2-20

2.4.1 Mining Activities .............................................................................................. 2-20

2.4.2 Ore Concentrate Milling ................................................................................... 2-20

2.4.3 Waste Disposal ................................................................................................. 2-21

2.4.4 Water Management .......................................................................................... 2-23

2.4.5 Rock Quarries ................................................................................................... 2-24

2.4.6 Reclamation Materials Stockpiles .................................................................... 2-25

2.4.7 Truck Wheel Wash Facility .............................................................................. 2-25

2.4.8 Support and Service Roads .............................................................................. 2-25

2.4.9 Reclamation and Closure ................................................................................. 2-27

2.5 Alternatives Considered but Not Carried Forward .................................................. 2-31

2.5.1 Alternative Facility Locations .......................................................................... 2-32

2.5.2 Alternative Facility Designs ............................................................................. 2-33

2.5.3 Reduction of the Pyrite Concentration in the Tailings ..................................... 2-33

2.6 Mitigation and Monitoring ........................................................................................ 2-34

2.6.1 Contemporaneous Reclamation ........................................................................ 2-34

2.6.2 Mitigation and Monitoring ............................................................................... 2-35

2.6.3 Adaptive Management ..................................................................................... 2-44
Contents 

xvi Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.7 Comparison of Alternatives ....................................................................................... 2-45

2.7.1 Exposure to Risk ............................................................................................... 2-45

2.7.2 Summary of Alternatives .................................................................................. 2-45

Chapter 3. Affected Environment and Environmental Consequences ................................. 3-1

3.1 Introduction ................................................................................................................. 3-1

3.2 Air Quality ................................................................................................................... 3-3

3.2.1 Air Quality – Pre-mining Environment .............................................................. 3-5

3.2.2 Air Quality – Baseline Conditions ...................................................................... 3-6

3.2.3 Air Quality – Environmental Consequences ....................................................... 3-8

3.2.4 Air Quality – Summary ..................................................................................... 3-21

3.3 Geotechnical Stability ............................................................................................... 3-22

3.3.1 Geotechnical Stability – Pre-mining Environment ........................................... 3-22

3.3.2 Geotechnical Stability – Baseline Conditions ................................................... 3-23

3.3.3 Geotechnical Stability – Environmental Consequences ................................... 3-24

3.3.4 Geotechnical Stability – Summary ................................................................... 3-27

3.4 Geochemistry ............................................................................................................. 3-27

3.4.1 Geochemistry – Pre-Mining Environment ........................................................ 3-27

3.4.2 Geochemistry – Existing Conditions ................................................................ 3-27

3.4.3 Geochemistry – Environmental Consequences ................................................ 3-35

3.4.4 Geochemistry – Summary ................................................................................ 3-38

3.5 Water Resources – Surface Water ............................................................................. 3-39

3.5.1 Water Resources – Surface Water – Pre-mining Environment ......................... 3-39

3.5.2 Water Resources – Surface Water - Baseline Conditions ................................. 3-44

3.5.3 Surface Water – Environmental Consequences ................................................ 3-54

3.5.4 Surface Water – Summary ................................................................................ 3-69

3.6 Water Resources – Groundwater ............................................................................... 3-70

3.6.1 Water Resources - Groundwater – Pre-mining Environment ........................... 3-70

3.6.2 Water Resources – Groundwater – Baseline Conditions .................................. 3-74

3.6.3 Water Resources – Groundwater – Environmental Consequences ................... 3-80

3.6.4 Groundwater – Summary .................................................................................. 3-83

3.7 Aquatic Resources ..................................................................................................... 3-84

3.7.1 Aquatic Resources – Pre-mining Environment ................................................. 3-84

3.7.2 Aquatic Resources – Baseline Conditions ........................................................ 3-91

3.7.3 Aquatic Resources – Environmental Consequences ....................................... 3-101

3.7.4 Aquatic Resources – Summary ....................................................................... 3-111

3.8 Wetlands .................................................................................................................. 3-113

3.8.1 Wetlands – Pre-Mining Environment ............................................................. 3-114

3.8.2 Wetlands – Baseline Conditions ..................................................................... 3-114

3.8.3 Wetlands – Environmental Consequences ...................................................... 3-121

3.8.4 Wetlands – Summary ...................................................................................... 3-132

3.9 Soils ........................................................................................................................ 3-133

3.9.1 Soils – Pre-mining Environment ..................................................................... 3-134

3.9.2 Soils – Baseline Conditions ............................................................................ 3-134

3.9.3 Soils – Environmental Consequences ............................................................. 3-135

3.9.4 Soils – Summary ............................................................................................. 3-139

3.10 Vegetation................................................................................................................ 3-140

3.10.1 Vegetation – Pre-Mining Environment ........................................................... 3-140

3.10.2 Vegetation – Baseline Conditions ................................................................... 3-141

3.10.3 Vegetation – Environmental Consequences ................................................... 3-141

3.10.4 Vegetation – Summary ................................................................................... 3-147
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xvii

3.11 Wildlife ................................................................................................................... 3-148

3.11.1 Wildlife – Pre-mining Environment ............................................................... 3-151

3.11.2 Wildlife – Baseline Conditions ...................................................................... 3-151

3.11.3 Wildlife – Environmental Consequences ....................................................... 3-165

3.11.4 Wildlife – Summary ....................................................................................... 3-185

3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants .................................................................. 3-187

3.12.1 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Pre-mining Environment ...................... 3-193

3.12.2 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Baseline Conditions .............................. 3-194

3.12.3 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Affected Environment .......................... 3-198

3.12.4 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Environmental Consequences ............... 3-203

3.12.5 Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Summary .............................................. 3-208

3.13 Land Use ................................................................................................................. 3-210

3.13.1 Land Use – Pre-mining Environment ............................................................. 3-212

3.13.2 Land Use – Baseline Conditions .................................................................... 3-212

3.13.3 Land Use – Environmental Consequences ..................................................... 3-212

3.13.4 Land Use – Summary ..................................................................................... 3-215

3.14 Scenic Resources .................................................................................................... 3-215

3.14.1 Scenic Resources – Pre-mining Environment ................................................ 3-215

3.14.2 Scenic Resources – Baseline Conditions ........................................................ 3-215

3.14.3 Scenic Resources – Environmental Consequences ........................................ 3-219

3.14.4 Scenic Resources – Summary ........................................................................ 3-228

3.15 Recreation ............................................................................................................... 3-228

3.15.1 Recreation – Pre-mining Environment ........................................................... 3-228

3.15.2 Recreation – Baseline Conditions .................................................................. 3-229

3.15.3 Recreation – Environmental Consequences ................................................... 3-231

3.15.4 Recreation – Summary ................................................................................... 3-234

3.16 Subsistence .............................................................................................................. 3-234

3.16.1 Subsistence – Pre-mining Environment ......................................................... 3-236

3.16.2 Subsistence – Baseline Conditions ................................................................. 3-237

3.16.3 Environmental Consequences ........................................................................ 3-244

3.16.4 Subsistence – Summary ................................................................................. 3-248

3.17 Cultural Resources .................................................................................................. 3-248

3.17.1 Cultural Resources – Pre-mining Environment ............................................... 3-249

3.17.2 Cultural Resources – Baseline Conditions ..................................................... 3-252

3.17.3 Cultural Resources – Environmental Consequences ...................................... 3-252

3.17.4 Cultural Resources Summary ......................................................................... 3-256

3.17.5 Recommended Mitigation .............................................................................. 3-256

3.18 Socioeconomics ...................................................................................................... 3-257

3.18.1 Socioeconomics – Pre-mining Environment .................................................. 3-257

3.18.2 Socioeconomics – Baseline Conditions ......................................................... 3-258

3.18.3 Socioeconomics – Environmental Consequences .......................................... 3-264

3.18.4 Socioeconomics – Summary .......................................................................... 3-267
Contents 

xviii Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.19 Monument Resources .............................................................................................. 3-267

3.19.1 Monument Resources – Pre-mining Environment .......................................... 3-268

3.19.2 Monument Resources – Baseline Conditions ................................................. 3-269

3.19.3 Monument Resources – Environmental Consequences .................................. 3-272

3.19.4 Monument Resources – Summary .................................................................. 3-278

3.20 Inventoried Roadless Areas ..................................................................................... 3-278

3.20.1 Background ..................................................................................................... 3-278

3.20.2 Inventoried Roadless Areas – Baseline Conditions ........................................ 3-279

3.20.3 Inventoried Roadless Areas – Environmental Consequences ......................... 3-284

3.20.4 Roadless Areas – Summary ............................................................................ 3-289

3.21 Environmental Justice ............................................................................................. 3-289

3.21.1 Background ..................................................................................................... 3-289

3.21.2 Environmental Justice – Baseline Conditions ................................................. 3-291

3.21.3 Environmental Justice – Environmental Consequences ................................. 3-292

3.21.4 Environmental Justice – Summary ................................................................. 3-293

3.22 Cumulative Effects .................................................................................................. 3-293

3.22.1 Basis for Assessment ...................................................................................... 3-293

3.22.2 Descriptions of Selected Relevant Actions ..................................................... 3-295

3.22.3 Cumulative Effects by Resource ..................................................................... 3-301

3.23 Irretrievable and Irreversible Commitment of Resources ....................................... 3-313

Chapter 4. List of Preparers ...................................................................................................... 4-1

Tetra Tech Team .................................................................................................................... 4-1

Lead Agency Reviewers ......................................................................................................... 4-2

USDA Forest Service ....................................................................................................... 4-2

Cooperating Agency Reviewers ............................................................................................. 4-2

U.S. Environmental Protection Agency ........................................................................... 4-2

U.S. Army Corps of Engineers ........................................................................................ 4-2

State of Alaska ................................................................................................................. 4-2

City and Borough of Juneau ............................................................................................ 4-2

List of Recipients .................................................................................................................... 4-3

Federal Agencies .............................................................................................................. 4-3

State Agencies .................................................................................................................. 4-3

Individuals ....................................................................................................................... 4-3 

Libraries ........................................................................................................................... 4-5

Organizations and Businesses .......................................................................................... 4-5 

Public Officials, Tribes, and Cities .................................................................................. 4-6

Chapter 5. References ................................................................................................................. 5-1

Chapter 6. Glossary .................................................................................................................... 6-1

Chapter 7. Index ......................................................................................................................... 7-1
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xix

List of Appendices 

Appendix A, Part 1. Forest Service Responses to Comments 

Appendix A, Part 2. U.S. Army Corps of Engineers Responses to Comments 

Appendix B. Alaska National Interest Lands Conservation Act Findings 

Appendix C. Financial Assurance Procedures 

Appendix D. Alternatives Development 

Appendix E. Maps Showing Years 1–10 

Appendix F. General Plan of Operations, Appendix 14, Attachment A, Detailed 

Reclamation Plan Cost Estimates 

Appendix G. Subsistence 

Appendix H. Cultural Resources 
Contents 

xx Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

List of Tables 

Table 2.3-1. Estimated TDF Disturbance for No Action and Action Alternatives (in Acres). .......... 2-4 

Table 2.4-1. Waste Disposal at Greens Creek Mine...................................................................... 2-21 

Table 2.6-1. Required Mitigation Measures by Resource. ............................................................ 2-35 

Table 2.6-2. Monitoring Requirements and Authority. ................................................................ 2-40 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource. .............................. 2-46 

Table 3.1-1. Study Areas for Direct and Indirect Effects. ............................................................... 3-3 

Table 3.2-1. National and Alaska Ambient Air Quality Standards. ................................................ 3-4 

Table 3.2-2. Alaska Department of Environmental Conservation Air Quality Site Inspections. ..... 3-6 

Table 3.2-3. Summary of Emission Units Currently Permitted at the Greens Creek Mine. ............ 3-7 

Table 3.2-4. Estimated Maximum Fugitive Dust Emissions............................................................ 3-9 

Table 3.2-5. Mobile Greenhouse Gas Emissions. .......................................................................... 3-11 

Table 3.2-6. Regulatory Formats to Control Fugitive Dust on Unpaved Roads and Open 

Areas. ..................................................................................................................... 3-13 

Table 3.3-1. Minimum Safety Factors for Slope Stability Analyses. ............................................. 3-25 

Table 3.3-2. Summary of Factors of Safety for TDF Cover Stability. ........................................... 3-25 

Table 3.4-1. Tailings Mineral Composition by Weight. ................................................................ 3-28 

Table 3.4-2. Pyrite Oxidation Estimates for Greens Creek Tailings. ............................................ 3-31 

Table 3.4-3. Chemical Composition of Solutions Associated with Greens Creek Tailings. ............ 3-34 

Table 3.5-1. Monthly and Annual Precipitation, 2000–2010. ........................................................ 3-40 

Table 3.5-2. Example of Water Quality Standards for Area Streams. .......................................... 3-46 

Table 3.5-3. Summary of Surface Water Quality Monitoring Stations. ........................................ 3-48 

Table 3.5-4. Alaska Marine Water Quality Standards (Adjusted to Total Values). ...................... 3-54 

Table 3.5-5. Average Marine Water Quality in Hawk Inlet for 2005–2009. .................................. 3-54 

Table 3.5-6. NPDES Effluent Limits Established for the Hawk Inlet NPDES Outfall. .................. 3-55 

Table 3.5-7. Average Predicted Water Quality for Tailings Wastewaters for Alternative A. ........ 3-57 

Table 3.5-8. Average Predicted Water Quality for Tailings Wastewaters for Alternative B. ........ 3-58 

Table 3.5-9. Average Predicted Water Quality for Tailings Wastewaters for 

Alternative C – North Stack. ................................................................................... 3-59 

Table 3.5-10. Average Predicted Water Quality for Tailings Wastewaters for 

Alternative D – North Stack. ................................................................................... 3-60 

Table 3.6-1. Pre-mining Groundwater Quality in Peat/Sand Aquifer (Data from 1988). .............. 3-73 

Table 3.6-2. Pre-mining Groundwater Quality in Glacio-Marine Aquifer (Data from 1988). ....... 3-74 

Table 3.6-3. Groundwater Quality in Peat/Sand Aquifer Wells (after Hecla 2009). ...................... 3-77 

Table 3.6-4. Groundwater Quality in Glacio-Marine Deposit Aquifer Wells (after 

Hecla 2009). ............................................................................................................ 3-78 

Table 3.6-5. Sulfate Concentration and Specific Conductance in Bedrock Aquifer Wells 

(adapted from EDE 2007). ................................................................................... 3-3-79 

Table 3.7-1. Project Area Major Stream and Watershed Characteristics. ................................. 3-3-85 

Table 3.7-2. Fish Species Found in Streams in or near the Greens Creek Mine Project Area. ...... 3-85 

Table 3.7-3. Features of Major Marine Habitat Types in Hawk Inlet, Admiralty Island. ............. 3-89 

Table 3.7-4. Number of Years Dolly Varden Char Total Body Metals Concentration Ranked 

Relative to Indicated Sites (2001–2010). .................................................................. 3-96 

Table 3.7-5. Commercial Fish and Shellfish Harvest in Hawk Inlet Area, 2001–2010. .................. 3-97 

Table 3.7-6. Hawk Inlet Sediment Data: Pre-Production Baseline, Production Period and 

Current Year Comparison. ..................................................................................... 3-98 

Table 3.7-7. Average and Standard Deviation Values for Preproduction and Production 

Sediment Data. ....................................................................................................... 3-99 

Table 3.7-8. Stream Habitat and Estimated Coho Salmon Smolt Potential Production lost 

by Stream Class. ................................................................................................... 3-105 

Table 3.8-1. Wetlands Occurring within the Study Area. ........................................................... 3-116 

Table 3.8-2. Wetland Service Ratings. ........................................................................................ 3-118 

Table 3.8-3. Wetlands Disturbed by Alternative B. .................................................................... 3-123 

Table 3.8-4. Wetlands Disturbed by Mitigated Alternative B. .................................................... 3-125 

Table 3.8-5. Wetlands Disturbed by Alternative C. .................................................................... 3-131 
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xxi

Table 3.8-6. Wetlands Disturbed by Alternative D. ................................................................... 3-132 

Table 3.8-7. Summary of Wetland Acreage Impacted by Alternative. ....................................... 3-133 

Table 3.9-1. Acres of Disturbance to Soil Map Units based on Existing Operations. .................. 3-135 

Table 3.11-1. Management Indicator Species and Other Species of Concern in the 

Vicinity of the Greens Creek Mine........................................................................ 3-149 

Table 3.11-2. Acres of Productive Old-growth Forest by Size-Density Model Classes and 

Other Habitats within the Study Area. ................................................................. 3-153 

Table 3.11-3. Existing and Estimated Productive Old Growth that would be Removed 

under Each Action Alternative within the Study Area. ......................................... 3-171 

Table 3.11-4. Summary of Level of Impacts from Each Alternative of the Project to 

Management Indicator Species and Other Species of Concern. ............................. 3-186 

Table 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants in Alaska and in the Vicinity of the 

Greens Creek Mine. ............................................................................................. 3-188 

Table 3.12-2. Summary of Effects Determinations for the Project to Species that Occur in 

or near the Project Area. ...................................................................................... 3-196 

Table 3.13-1. Disturbance Inside and Outside the Monument by Alternative. ........................... 3-213 

Table 3.15-1. Game Management Unit 4 Deer Hunter Residency and Success, 

Regulatory Years 2003 through 2007. ................................................................... 3-230 

Table 3.15-2. Admiralty Island Brown Bear Hunting Effort by Residency, Regulatory 

Years 2003 through 2007. ..................................................................................... 3-231 

Table 3.18-1. Annual Employment and Earnings CBJ, 2010. .................................................... 3-258 

Table 3.18-2. Income and Poverty, 2009. ................................................................................... 3-260 

Table 3.18-3. Population 1990 to 2010. ...................................................................................... 3-261 

Table 3.18-4. Race and Ethnicity, 2010. .................................................................................... 3-262 

Table 3.18-5. Juneau School District K-12 Enrollment. ............................................................. 3-263 

Table 3.18-6. Housing in Juneau, 2010. ..................................................................................... 3-263 

Table 3.18-7. Estimated Funding Sources for the City and Borough of Juneau Fiscal 

Year 2010. ............................................................................................................ 3-264 

Table 3.18-8. Annual Socioeconomic Impacts............................................................................ 3-265 

Table 3.19-1. Specific Resources Identified in Proclamation or Legislation Applicable to 

Non-wilderness Areas of the Monument. .............................................................. 3-269 

Table 3.19-2. New Acres of Productive Old Growth Removal within the Monument ................. 3-274 

Table 3.19-3. Comparison of Alternatives with Respect to Monument Disturbances. ................ 3-275 

Table 3.20-1. Roadless Characteristics and Discussion Section. ................................................. 3-279 

Table 3.20-2. IRA Effects by Alternative. .................................................................................. 3-285 

Table 3.22-1. Relationship of Selection Criteria to Environmental Resources. ........................... 3-296 

Table 3.22-2. General Criteria Applied in Selecting Relevant Actions for this Evaluation. ........ 3-297 

Table 3.23-1. Irreversible and Irretrievable Resource Commitments. ....................................... 3-314 

 
Contents 

xxii Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

List of Figures 

Figure 1.1-1. Greens Creek Project – General Location Map......................................................... 1-2 

Figure 1.1-2. Greens Creek Project General Location of Existing Facilities. .................................. 1-4 

Figure 1.1-3. Greens Creek Tailings Facility (2009). ...................................................................... 1-5 

Figure 2.3-1. Greens Creek Mine Alternative A. ............................................................................ 2-5 

Figure 2.3-2. Greens Creek Mine Alternative B Final. ................................................................... 2-7 

Figure 2.3-3. Facility Locations of Mitigation Options under Alternative B. .................................. 2-9 

Figure 2.3-4a. Greens Creek Mine Alternative C – Final North Layout. ...................................... 2-12 

Figure 2.3-4b. Greens Creek Mine Alternative C – Final Central Layout. ................................... 2-13 

Figure 2.3-4c. Greens Creek Mine Alternative C – Final South Layout........................................ 2-14 

Figure 2.3-5a. Greens Creek Mine Alternative D – Final North Layout. ...................................... 2-16 

Figure 2.3-5b. Greens Creek Mine Alternative D – Final Central Layout. ................................... 2-17 

Figure 2.3-5c. Greens Creek Mine Alternative D – Final South Layout........................................ 2-18 

Figure 2.4-1. Conceptual Drawing of TDF at Closure with Typical 4 Layer Engineered Cover 

for Reclamation Placed on a 3:1 Slope..................................................................... 2-30 

Figure 3.1-1. Project and Study Areas. .......................................................................................... 3-2 

Figure 3.2-1. Annual Prevailing Wind Speed and Direction. .......................................................... 3-5 

Figure 3.2-2. Maximum Controlled and Uncontrolled PM10 Emissions for TDF and Roads. ........ 3-10 

Figure 3.2-3. Maximum Controlled and Uncontrolled PM2.5 Emissions for TDF and Roads. ....... 3-10 

Figure 3.2-4. Alternative A Average Annual PM10 Emissions, Years 1–10. ................................... 3-14 

Figure 3.2-5. Alternative A Average Annual PM2.5 Emissions, Years 1–10. .................................. 3-15 

Figure 3.2-6. Alternative B Average Annual PM10 Emissions, Years 1–50. ................................... 3-16 

Figure 3.2-7. Alternative B Average Annual PM2.5 Emissions, Years 1–50. .................................. 3-16 

Figure 3.2-8. Mitigated Alternative B Average Annual PM10 Emissions, Years 1–50. ................... 3-17 

Figure 3.2-9. Mitigated Alternative B Average Annual PM2.5 Emissions, Years 1–50. .................. 3-18 

Figure 3.2-10. Alternative C Average Annual PM10 Emissions, Years 1–50. ................................. 3-19 

Figure 3.2-11. Alternative C Average Annual PM2.5 Emissions, Years 1–50. ................................ 3-19 

Figure 3.2-12. Alternative D Average Annual PM10 Emissions, Years 1–50. ................................. 3-20 

Figure 3.2-13. Alternative D Average Annual PM2.5 Emissions Years, 1–50. ................................ 3-21 

Figure 3.4-1. Acid-base Accounting of Greens Creek Tailings. .................................................... 3-30 

Figure 3.4-2. Model Results for Zinc over Time, for each Alternative. ......................................... 3-37 

Figure 3.4-3. Model Results for Sulfate over Time, for each Alternative. ..................................... 3-37 

Figure 3.5-1. Surface Water. ....................................................................................................... 3-42 

Figure 3.5-2. Surface Water Quality Monitoring Sites. ................................................................ 3-47 

Figure 3.5-3. Marine Water, Mussel, and Sediment Sampling Sites. ............................................ 3-53 

Figure 3.5-4. Impacts to Watersheds and Streams by Alternative (South).................................... 3-63 

Figure 3.5-5. Impacts to Watersheds and Streams by Alternative (North). .................................. 3-67 

Figure 3.7-1. Dolly Varden Char Density at Biomonitoring Sites on Greens and Tributary 

Creeks. ................................................................................................................... 3-94 

Figure 3.7-2. Coho Salmon Juvenile Density at Biomonitoring Sites on Greens and Tributary 

Creeks. ................................................................................................................... 3-94 

Figure 3.8-1. Wetlands. ............................................................................................................. 3-115 

Figure 3.8-2. Wetland Functions................................................................................................ 3-119 

Figure 3.8-3. Wetland Values. ................................................................................................... 3-120 

Figure 3.8-4. Impacts to Wetlands by Alternative (South).......................................................... 3-122 

Figure 3.8-5. Impacts to Wetland Functions by Alternative (South). .......................................... 3-126 

Figure 3.8-6. Impacts to Wetland Values by Alternative (South)................................................ 3-127 

Figure 3.8-7. Impacts to Wetlands by Alternative (North). ........................................................ 3-128 

Figure 3.8-8. Impacts to Wetland Functions by Alternative (North)........................................... 3-129 

Figure 3.8-9. Impacts to Wetland Values by Alternative (North). .............................................. 3-130 

Figure 3.10-1. Vegetation........................................................................................................... 3-142 

Figure 3.13-1. Land Use Designations. ....................................................................................... 3-211 

Figure 3.14-1. Existing View of Mine Facilities from Hawk Inlet. .............................................. 3-217 

Figure 3.14-2. Existing View from Northern Portion of Hawk Inlet. ............................................... 3-217 
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xxiii

Figure 3.14-3. Viewshed Analysis Points with Views of Proposed Expansion of Existing TDF 

(Alternatives A–D)................................................................................................ 3-220 

Figure 3.14-4. Viewshed Analysis Points with Views of Proposed New TDF 

(Alternatives C–D). .............................................................................................. 3-222 

Figure 3.14-5. Alternative A: Photo-Simulation from Hawk Inlet showing Approved TDF 

Expansion at Maximum Height before Revegetation. ........................................... 3-223 

Figure 3.14-6. Alternative B: Photo-Simulation from Hawk Inlet showing Alternative B 

TDF Expansion at Maximum Height before Revegetation. ................................... 3-223 

Figure 3.14-7. Alternative C: Photo-Simulation from Hawk Inlet showing Alternative C 

New TDF at Maximum Height before Revegetation. ............................................. 3-223 

Figure 3.14-8. Simulation of Alternative C South Tailings Disposal Facility. ............................. 3-227 

Figure 3.14-9. Simulation of Alternative D North Tailings Disposal Facility. ............................. 3-227 

Figure 3.14-10. Simulation of Alternative D South Tailings Disposal Facility. ........................... 3-227 

Figure 3.16-1. Angoon Subsistence Use Areas. .......................................................................... 3-238 

Figure 3.16-2. Angoon Seasonal Round of Harvest Activities. ................................................... 3-239 

Figure 3.16-3. Hoonah Subsistence Use Areas. .......................................................................... 3-241 

Figure 3.16-4. Hoonah Seasonal Round of Harvest Activities. ................................................... 3-243 

Figure 3.16-5. Tenakee Springs Subsistence Use Area. .............................................................. 3-245 

Figure 3.16-6. Tenakee Springs Seasonal Round of Harvest Activities....................................... 3-246 

Figure 3.20-1. Inventoried Roadless Areas. ............................................................................... 3-280 

Figure 3.20-2. Greens Creek IRA Affected by Each Alternative. ............................................... 3-286 

Figure 3.20-3. Mansfield IRA Affected by Alternatives C and D. .............................................. 3-287 

 
Contents 

xxiv Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

 
Contents 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS xxv

List of Acronyms 

ADEC Alaska Department of Environmental Conservation 

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

ANILCA Alaska National Interest Lands Conservation Act 

APDES Alaska Pollutant Discharge Elimination System 

ARD acid rock drainage 

 

BA biological assessment 

BMP best management practice 

 

Cannery cannery facility 

CBJ City and Borough of Juneau 

CEQ Council on Environmental Quality 

CWA Clean Water Act 

 

DPS distinct population segment 

 

EFH essential fish habitat 

EIS environmental impact statement 

EPT ephemeroptera, plecoptera, and trichoptera 

ESA Endangered Species Act 

 

Forest Service U.S. Department of Agriculture Forest Service, Tongass National 

Forest 

FSH Forest Service Handbook 

FSM Forest Service Manual 

FWMP Fresh Water Monitoring Program 

 

GHG greenhouse gas 

GMU Game Management Unit 

GPO General Pan of Operations 

 

HGCMC (the 

proponent) 

Hecla Greens Creek Mining Company 

 

IRA Inventoried roadless area 

 

KGCMC Kennecott Greens Creek Mining Company 

 

LUD Land Use Designation 

 

MBTA Migratory Bird Treaty Act 

MIS Management Indicator Species 

MMPA Marine Mammal Protection Act 

Monument Admiralty Island National Monument 

MOU Memorandum of Understanding 

MSFCMA Magnuson-Stevens Fishery Conservation and Management Act 

MSHA Mine Safety and Health Administration 

 
Contents 

xxvi Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

NAAQS National Ambient Air Quality Standards 

NAWS non-agricultural wage and salary 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NMFS National Marine Fisheries Service 

NOI Notice of Intent 

NPDES National Pollutant Discharge Elimination System 

NRHP National Register of Historic Places 

 

POG 

PSD 

productive old growth 

Prevention of Significant Deterioration 

 

ROD Record of Decision 

 

SDM size-density model 

SHPO State Historic Preservation Officer 

SIO scenic integrity objective 

 

TDF tailings disposal facility 

tpy tons per year 

 

USACE U.S. Army Corps of Engineers 

USEPA U.S. Environmental Protection Agency 

USFWS U.S. Fish and Wildlife Service 

 

VCU value comparison unit 

VPR Visual Priority Travel Route and Use Area 

 

WAA Wildlife Analysis Area 

WQS Water Quality Standards 

WWTP wastewater treatment plant 
1.1 Background 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-1 

CHAPTER 1. PURPOSE AND NEED FOR THE 

PROPOSED ACTION 

1.1 Background ________________________________ 

The Greens Creek Mine is an underground metals mine (primarily lead, zinc, silver, and 

gold) located near Hawk Inlet on northern Admiralty Island. It is located approximately 

18 miles southwest of Juneau, Alaska, and 38 miles north of Angoon, Alaska (refer to 

Figure 1.1-1). The mine access and processing facilities are situated in the Greens Creek 

watershed while the tailings disposal facility (TDF) is located in portions of the Tributary 

Creek, South Hawk Inlet, and Cannery Creek watersheds. The mine and portions of the 

TDF are within the Admiralty Island National Monument (Monument); at its nearest 

point, the Kootznoowoo Wilderness is less than 2 miles from the mine’s mill and mine 

portal. In 1980, Congress provided for mining within the Monument at the Greens Creek 

site in Section 503 of the Alaska National Interest Lands Conservation Act (ANILCA). 

The remainder of the mine’s facilities (north end of the TDF and the A Road) are located 

in the Juneau Ranger District or on privately held land near Hawk Inlet (cannery camp 

and port facilities). On an annual basis, production from the Greens Creek Mine yields 

approximately 7 million ounces of silver, 40,000 ounces of gold, and a total of 200,000 

tons of zinc, lead, and bulk concentrates. 

Before mining operations began, the Forest Service, U.S. Department of Agriculture 

(Forest Service), published the Greens Creek Final Environmental Impact Statement 

(EIS) (Forest Service 1983) and issued its Record of Decision (ROD) for overall 

development and operation of the mine. In early 1984, the Forest Service approved a 

General Plan of Operations (GPO) for Noranda Mining, Inc., the owner and operator at 

that time. 

That original 1984 GPO called for underground mining with ore crushed and 

concentrated via flotation in a mill near the mine portal. Under the plan, the ore 

concentrate was to be trucked approximately nine miles to a port on Hawk Inlet at a 

former cannery facility (Cannery); from there, it was to be shipped to smelters outside 

Alaska for processing and refining. The tailings—the material left after most of the 

target metal minerals have been removed—were to be piped along the road corridor as a 

slurry, or watery mixture, to a site near the Cannery for disposal. While planning was 

still going on, ownership of the mine changed, and in early 1986, Amselco assumed 

control of operations. The new owner changed some aspects of the GPO, particularly the 

method of tailings disposal. Instead of disposing the tailings as a slurry, Amselco 

proposed to remove most of the water from the tailings via thickening and filtration and 

truck the dry tailings to a smaller area at the same site near the Cannery for disposal. In 

July 1987, the Forest Service determined that this and other proposed changes to the GPO 

required a review under the National Environmental Policy Act (NEPA). The following 

year, the Forest Service published the Environmental Assessment for Proposed Changes 

to the General Plan of Operations for the Development and Operation of the Greens 

Creek Mine (Forest Service 1988). 
Chapter 1. Purpose and Need for the Proposed Action 

1-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 1.1-1. Greens Creek Project – General Location Map. 

 
1.1 Background 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-3 

Full-scale development of the mine began in 

1987. Workers excavating for the mill site 

found a large, unanticipated volume of porous 

soil that had to be removed in order to provide a 

suitable foundation for the mill. Because this 

soil was placed in the mine’s approved waste 

rock disposal site, higher volumes of waste rock 

than anticipated were disposed of at the TDF, which decreased available capacity for 

tailings. Also, ongoing exploration had identified additional ore reserves. In response to 

these changed circumstances, in 1990 the project’s operator, then Kennecott Greens 

Creek Mining Company (KGCMC), sought approval for additional waste rock disposal 

capacity. As a result, in 1991 the Forest Service began a third NEPA review and the 

following year published the Environmental Assessment for Additional Waste Rock 

Disposal Capacity at Greens Creek Mine (Forest Service 1992). 

In April 1993, KGCMC temporarily suspended mining operations due to depressed 

metals prices. On April 1, 1996, Congress passed the Greens Creek Land Exchange Act, 

which granted Greens Creek title to the subsurface of 7,500 acres of public land 

immediately adjacent to their claims. As a result of the implementation of the agreement 

ratified by the act, the United States acquired 139 acres of private inholdings in the 

Admiralty Island National Monument and 50 acres of private inholdings in the Misty 

Fjords National Monument. Upon completion of mining and after reclamation, the 

exchanged 7,500 acres, as well as all lands currently owned or yet to be acquired by 

KGCMC on Admiralty Island, will revert to the United States and will be included in the 

Admiralty Island National Monument, Tongass National Forest. KGCMC reopened the 

project in July 1996, and in conjunction with the resumption of mining operations, the 

Forest Service approved an amendment to the GPO. Based on the need for additional 

surface tailings disposal, in January 2001, KGCMC submitted a proposal to the Forest 

Service requesting a modification of the existing GPO for expansion of both the area and 

the disposal capacity of the TDF existing at that time. In November 2003, the Forest 

Service released the Greens Creek Tailings Disposal Final Environmental Impact 

Statement (Forest Service 2003). The ROD resulting from the 2003 EIS approved an 

expansion of the TDF to accommodate an additional 3.3 million cubic yards of tailings 

disposal capacity which was intended to address KGCMC’s tailings disposal needs 

through 2025. Figure 1.1-2 illustrates the general locations of existing facilities at the 

site, which were previously authorized. Figure 1.1-3 illustrates a detailed aerial view of 

the existing TDF disturbance. 

In April 2008, the Hecla Greens Creek Mining Company (HGCMC) purchased the 

project from KGCMC and assumed control of the mine’s operation. In April 2009, 

HGCMC submitted a request to the State of Alaska and the Forest Service to co-dispose 

waste rock that was being stored at “Site E,” with tailings at the TDF. The co-disposal 

request resulted from concerns about the formation of acid rock drainage (ARD) at Site 

E, which was unlined and without adequate drainage control. Site E contains 

approximately 365,000 cubic yards of material, of which approximately 270,000 cubic 

yards is waste rock that had been placed into the facility between 1988 and 1994. The 

remaining 95,000 cubic yards is glacial till from the original mill site excavation. The 

proposal involved the removal of waste rock from Site E, disposing of the waste rock at 

the TDF, and storage of the till material for use in later reclamation. 

Tailings and waste rock conversion:

1.8 tons of tailings = 1 cubic yard

1.7 tons of waste rock = 1 cubic yard
Chapter 1. Purpose and Need for the Proposed Action 

1-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 1.1-2. Greens Creek Project General Location of Existing Facilities. 
1.1 Background 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-5 

Figure 1.1-3. Greens Creek Tailings Facility (2009). 
Chapter 1. Purpose and Need for the Proposed Action 

1-6 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Plans for reclamation of Site E require HGCMC to consolidate, hydroseed, and stabilize 

the till within the existing footprint of Site E, control drainage and recontour slopes. 

Ultimate reclamation of the site once the till material is removed will include regrading 

the site to match, as closely as possible, original contours. HGCMC’s submittal included 

documentation supporting the geotechnical stability of co-disposal of the waste rock 

within the TDF. The Forest Service conducted a change analysis on the submittal and 

determined that the modifications did not represent a substantial change requiring a 

revision or supplement to the 2003 Tailings Expansion Final EIS and ROD. The Forest 

Service approved the modification in June 2009. Additionally, the Alaska Department of 

Environmental Conservation (ADEC) reviewed the proposal for co-disposal and 

approved the modification in April 2009. Reclamation of Site E removal will be as 

described in Hecla’s Site E Removal Plan (HGCMC 2009); subject to annual removal 

plans approved by the Forest Service and ADEC. 

HGCMC has revisited the approved capacity of the TDF. Based on current production 

levels, HGCMC estimates that the TDF has the capacity to accommodate tailings and 

waste rock placement through late 2019. This represents a change from information 

presented in the 2012 Draft EIS, which indicated that there was enough capacity to 

accommodate waste placement through approximately 2014. This change is based on 

revised input received from HGCMC during the public comment period on the Draft EIS. 

The apparent “loss” in disposal capacities and volumes anticipated in the 2003 EIS and 

GPO compared to current calculations results from two sources. The first is a reduction 

in capacity of the approved TDF. Capacity is reduced because geotechnical conditions 

(i.e., steep slopes and unstable material) prevented the safe use of some of the areas that 

had been approved for tailings disposal in 2003. The second reason is an increase in the 

average annual production of tailings and waste rock being placed into the TDF. While 

the 2003 EIS volumes reflect a tailings disposal rate of approximately 150,000 cubic 

yards per year, the metered volume over the last 5 years has been closer to 215,000 cubic 

yards of tailing, waste rock, and other permitted materials annually. 

With continued discovery of new ore and improved metal prices, HGCMC believes they 

can extend the life of the mine for another 30 to 50 years through systematic and 

sustained exploration that results in continued discovery and delineation of new ore 

reserves. This has been the case since the mine opened in 1989. 

The request for the expansion is based on the need for a long-term tailings disposal 

strategy to sustain mine operations currently approved in the GPO. The expansion would 

address defined reserves, ongoing waste rock disposal requirements, and anticipated 

discovery of additional reserves accessible through the existing Greens Creek Mine 

portal. This will provide a comprehensive long-term plan; however, actual construction 

will be performed in phases that limit impacts to defined actual needs at the time of each 

phase. Based on that need for long-term expansion, in February 2010, HGCMC 

submitted a letter to the Forest Service requesting a modification of the existing GPO for 

expansion of both the area and the disposal capacity of the existing TDF. HGCMC’s 

request for the “Stage 3” tailings expansion noted that all other aspects of the operation, 

including production rates, employment levels, and shipping procedures would remain 

the same. 
1.2 Purpose and Need 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-7 

The Forest Service reviewed the HGCMC proposal and developed a proposed action to 

carry forward. The Forest Service determined that an EIS should be prepared. In 

October 2010, the Forest Service issued a Notice of Intent (NOI) to prepare an EIS to 

analyze and discuss the effects of proposed changes to the TDF. In the process of 

preparing the analysis, the Forest Service encouraged public comment through the 

scoping process (initiated October 5, 2010) and through government-to-government 

consultations with local Alaska Native tribal organizations. Based on the input gathered 

during scoping, the Forest Service identified significant issues. Significant issues focus 

the environmental analyses on aspects of the project that are of the greatest concern to the 

public or regulatory agencies or have the most potential for producing adverse 

environmental effects (Section 1.7). Through the consideration of these significant 

issues, the Forest Service formulated alternatives to the proposed action, including a No 

Action Alternative. This EIS analyzes the proposed action and alternatives to the 

proposed action and their effects on pertinent physical, biological, and social resources. 

1.2 Purpose and Need __________________________ 

The purpose of this EIS is for the Forest Service to consider certain changes to the 

approved HGCMC GPO regarding tailings and waste rock disposal and related 

infrastructure. 

The proposed action, which is the action proposed by HGCMC, is to extend the TDF 

footprint south into the Monument providing capacity for tailings and waste rock disposal 

for an additional 30 to 50 years. With continued exploration identifying additional ore, 

improved metal prices, and ongoing operational efficiencies, there is a need for additional 

tailings and waste rock disposal capacity and related infrastructure at the Greens Creek 

Mine to allow for continuous site operations in a safe, environmentally sound, technically 

feasible, and economically viable manner, while remaining in compliance with regulatory 

requirements. 

This EIS analyzes impacts that could result from expansion of the TDF. Other mine 

project components (e.g., the underground mine, mine road, waste rock disposal site, 

Hawk Inlet terminal, etc.) are not addressed because they were analyzed in previous EISs. 

1.3 Proposed Action ____________________________ 

Annual exploration activity by the Greens Creek Mine has continued to maintain its 

reserves at the 10-year life-of-mine level. Therefore, the mine has operated as a “10-

year” mine for the last 20 years with the likelihood that new reserves will continue to be 

identified well into the future. The combination of new reserves and high metal prices 

has driven the need for additional tailings disposal capacity to allow for the continued 

operations of the Greens Creek Mine. HGCMC has estimated that pre-tailings 

construction work would need to begin in 2017 to prepare the site for tailings placement 

in 2019. This represents a change from information presented in the Draft EIS, which 

indicated that construction work would need to begin in 2012. This change is based on 

revised input received from HGCMC during the public comment period on the Draft EIS. 

The TDF at the Greens Creek Mine is built and operated using the dry stack tailings 

disposal technique. This technique allows less ground disturbance than either 

conventional slurry tailings or paste tailings disposal by reducing the overall volume of 
Chapter 1. Purpose and Need for the Proposed Action 

1-8 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

waste material. HGCMC proposes to extend the existing TDF in a southward direction 

for the targeted additional capacity. 

The TDF expansion would accommodate an estimated additional 14.2 million cubic 

yards of tailings and waste rock with development proceeding incrementally in 10-year 

phases, with the Forest Service and ADEC approval required prior to each phase of 

construction. This expansion would include capacity for ongoing operations and project 

reserves, and provide volume for waste rock co-disposal and an expanded resource base 

being defined by ongoing on-site exploration activities. Based on these assumptions the 

expanded TDF could provide enough capacity for the next 30–50 years of mine 

operations. Waste rock co-disposed could include material generated in the mining 

process as well as waste rock currently located in existing on-site disposal facilities. The 

planned expansion would also meet HGCMC management direction to design and permit 

a “long-term” TDF capable of handling projected operational requirements. HGCMC 

proposes to use the same tailings disposal techniques, environmental management 

procedures, and reclamation measures that were analyzed in the 2003 EIS for the site. 

The expanded TDF proposed by HGCMC would add roughly 54 acres to the TDF, 

essentially doubling the size of the currently approved facility. Based on preliminary 

engineering analyses, the tailings expansion would increase the height of the overall 

facility. 

As part of the proposed expansion, HGCMC would incorporate additional supporting 

infrastructure, including storm water facilities, quarry sites, reclamation material storage 

areas, new access roads, a new truck wash facility, a new or expanded water treatment 

plant, and an upgraded water discharge outfall line into Hawk Inlet. 

As the TDF expanded, HGCMC would have the ability to initiate interim or concurrent 

reclamation on sections of the TDF as they reached full design capacity. Concurrent 

reclamation would be conducted on facilities that would not be disturbed again, such as 

borrow areas. In addition, HGCMC would continue to use the operational, maintenance, 

and monitoring techniques for tailings that the operator has employed since the late 

1980s, as well as the more recently approved procedures that allow co-disposal of waste 

rock into the TDF. The company would continue to meet the requirements set forth 

under the State Waste Management Permit and the Alaska Pollutant Discharge 

Elimination System (APDES) permit. 

1.4 Decisions to Be Made ________________________ 

The Forest Supervisor of the Tongass National Forest is the responsible official for 

deciding whether to select the proposed action or another alternative for implementation. 

In addition to increased disposal capacity and disturbance footprint, the proposed action 

would include an increase of the HGCMC’s existing lease area to accommodate 

additional tailings disposal1. 

The U.S. Army Corps of Engineers (USACE) will decide whether to issue permits under 

Section 404 of the Clean Water Act (CWA). Section 404 permits are required for some 

 

1

 The Forest Service issued Lease No. 4050-10 for the Greens Creek Mine in 1988 covering approximately 

40 acres for the construction, operations and maintenance of a tailings disposal facility. In 2004, the Forest 

Service amended the lease to cover a total of 123 acres. 
1.5 Scoping and Public Involvement 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-9 

of the activities related to expansion of the TDF. Section 1.8 provides additional 

information on the USACE’s responsibilities; Appendix A to the Draft EIS presents the 

USACE’s public notice and HGCMC’s Section 404 permit application. The Alaska 

District Engineer is the responsible official for the USACE. The USACE is a 

cooperating agency in developing the EIS. 

The Forest Supervisor and Alaska District Engineer will identify any additional 

mitigation measures and monitoring required for this project. The Forest Supervisor and 

Alaska District Engineer will document their respective decisions in records of decision, 

which will include the reasons applicable within their respective authorities for their 

decision based on the analyses presented in the Final EIS. It should be noted that in the 

case of this document, the No Action Alternative is not a “no-build” alternative. 

Selection of the No Action Alternative as a result of the EIS would deny the proposed 

changes to the currently approved GPO but would allow the company to continue mining 

operations and placement of tailings and waste rock under the terms of the ROD for the 

2003 EIS and the approved operating plan. A No Action Alternative that considered the 

effects of no mining in the project area was evaluated under NEPA in the 1983 Final EIS. 

Selection of one of the action alternatives would authorize HGCMC to expand tailings 

disposal to accommodate an additional 30 to 50 years’ worth of mining wastes. 

However, the expansion would occur in stages or phases, with each stage accommodating 

approximately 10 years’ worth of capacity. The Forest Service, USACE and ADEC will 

need to approve each stage prior to HGCMC initiating construction activities. The Forest 

Service would manage the process through the procedures outlined in Forest Service 

Handbook Section 1909.15.18. The operator would submit detailed designs that would 

be reviewed for consistency with this NEPA analysis and ROD. The submittals would 

need to be timed to coincide with every other reissuance of the ADEC Waste 

Management Permit (which is authorized on 5-year intervals). At that time, the 

responsible official(s) would conduct an interdisciplinary review of the proposed new 

phase of development and document the results in a supplemental information report. If 

the proposed new phase was not consistent with the current (2013) decision or new 

information or changed circumstances were not within the scope and range of effects 

considered in the original analysis, the action would be subject to further analysis and 

documentation requirements under NEPA. 

1.5 Scoping and Public Involvement _______________ 

1.5.1 Scoping 

The NOI to prepare the EIS for the Greens Creek Mine Tailings Disposal Facility 

Expansion was published in the Federal Register on October 5, 2010. The publication of 

the NOI initiated the scoping process and a public review and comment period required 

under NEPA at 40 CFR Part 1501.7. After a 15-day extension, the formal scoping period 

ended on November 19, 2010. 
Chapter 1. Purpose and Need for the Proposed Action 

1-10 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Scoping is a process intended to assist the Forest Service and the cooperating agencies in 

identifying issues of concern associated with the proposed project, and is designed to 

ensure that all significant issues are fully addressed during the course of the EIS process. 

The main objectives of the scoping process are to: 

 Provide the public, stakeholders, and regulatory agencies with a basic understanding 

of the proposed project; 

 Provide a framework for the public to ask questions, raise concerns, and identify 

specific issues with the proposed options; and recommend options other than those 

currently proposed; 

 Ensure that potentially significant issues from the public, tribes, and agencies are 

identified and fully addressed during the course of the EIS process; and 

 Explain where to find additional information about the project. 

The scoping document for the Greens Creek Mine Tailings Disposal Facility Expansion 

EIS was distributed along with the NOI. The scoping document was distributed to a 

mailing list generated from previously completed similar projects and with input from the 

cooperating agencies. The scoping document provided a brief background on the Greens 

Creek Mine; a description of the proposed action, agency involvement, permits and 

authorizations, and the scoping process; an EIS preparation schedule; and information 

sources. In addition to the NOI, the Forest Service placed a public notice in the 

Ketchikan Daily News and the Juneau Empire on October 8, 2010, which ran for four 

days, and also used email to advertise public meetings. Public meetings were held in 

Juneau on October 14, 2010, and in Angoon on October 15, 2010. The purposes of the 

scoping meetings were to solicit public comments about the project and to respond to 

public requests for background information needed to fully understand the project 

description and proposed scope of the EIS. 

Throughout the scoping process, the Forest Service collected comments from the public; 

local, state, and federal agencies; non-governmental organizations; professional and trade 

organizations; and Native corporations and tribal organizations. Fifteen people signed 

the attendance sheets at the public meeting in Juneau, and 20 signed in at the Angoon 

meeting. 

The scoping process produced 16 individual comment submittals, which are traditional 

letters, emails, or written comment forms. Many comment submittals included more than 

one comment. An interdisciplinary team, consisting of resource experts, reviewed the 

comment submittals to identify and catalog individual comments. A total of 155 

comments were identified. The Forest Service released a Scoping Summary Document2

that summarized the nature of the scoping comments received during this process and 

identified in which part of the EIS the comments would be addressed. 

 

2

 The Scoping Summary Document is available online at: 

http://www.fs.fed.us/r10/tongass/projects/nepa_project.shtml?project=32662. 
1.6 Government-to-Government Tribal Consultations and Native Corporation Consultations 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-11 

1.5.2 Draft Environmental Impact Statement 

The Forest Service published a Notice of Availability of the Draft EIS in the Federal 

Register (77 FR 23713 [2021-04-20]), which coincided with public distribution of paper 

and electronic copies to the public. The document was posted concurrently on the 

Tongass National Forest website 

(http://www.fs.fed.us/nepa/project_content.php?project=32662). The Notice of 

Availability was published in the Juneau Empire and Ketchikan Daily News on April 20, 

2012. The Forest Service and the USACE held open house public meetings in Juneau 

(May 15, 2012) and Angoon (May 16, 2012) to solicit comment on the Draft EIS and the 

USACE Public Notice of Permit Application, which was included as Appendix A to the 

Draft EIS. Meeting announcements were posted in the Ketchikan Daily News on May 11, 

2012. Nineteen people signed in for the public meeting in Juneau while 10 people signed 

in for the meetings in Angoon. 

The Forest Service received 763 comments contained within 110 comment “letters” 

which were submitted in the form of letters, emails, and hand-written comments. In 

addition, 10 comment letters were addressed to the USACE. Two comment documents 

were addressed to both agencies. All comments have been read and considered in this 

analysis. Where appropriate, the Final EIS has been revised to address comments 

received during the comment period. Copies of comment letters and responses to each of 

the comments are presented in Appendix A of this Final EIS. 

1.5.3 Alaska National Interest Land Conservation Act 

Section 810 Hearings 

ANILCA Section 810(a) requires that the Forest Service conduct an evaluation of 

subsistence uses and needs for any determination to “withdraw, reserve, lease or 

otherwise permit the use, occupancy or disposition of public lands.” The evaluation 

under ANILCA is discussed further in Section 3.16 (Subsistence) and in Appendix B. 

ANILCA Section 810(a)(2) also requires the Forest Service to give notice of and hold a 

hearing in the vicinity of the area involved. Consistent with this requirement, the Forest 

Service held public hearings in Hoonah, Alaska, on September 14, 2012, and in Angoon, 

Alaska, on November 8, 2012. One person testified during the hearings in Hoonah and 

12 individuals provided testimony in Angoon. Transcripts of the meetings are included 

in the administrative record. 

1.6 Government-to-Government Tribal Consultations 

and Native Corporation Consultations __________ 

The Forest Service conducts ongoing consultations with Alaska Native groups to comply 

with Executive Order 13175, which addresses consultation and coordination with Indian 

tribal governments. The Forest Service conducted government-to-government 

consultations in association with the scoping process to solicit comments on the project 

from the Central Council of Tlingit and Haida on October 4, 2010, and with the Angoon 

Community Association on October 15, 2010. Additional consultation occurred with the 

Angoon Community Association on October 13, 2011. The purpose of the meetings was 

to explain the nature of the project and to solicit comments and concerns. 
Chapter 1. Purpose and Need for the Proposed Action 

1-12 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The Forest Service sent letters to number of federally recognized tribes and Alaska 

Native Claims Settlement Act Native Corporations on May 8, 2012, notifying them of the 

release of the Draft EIS. The recipients of the letter included the Angoon Community 

Association, Douglas Indian Association, Hoonah Indian Association, Central Council of 

Tlingit and Haida Indian Tribes of Alaska, Kootznoowoo Inc., Huna Totem Corporation, 

Goldbelt Inc., and Sealaska Inc. The Forest Service had subsequent correspondence with 

the Angoon Community Association resulting in a consultation meeting with the Tribal 

Council in Angoon on May 16, 2012 prior to the Draft EIS public meeting. The Forest 

Service also consulted with the Douglas Indian Association on June 4, 2012. Results of 

this consultation are discussed in Section 3.21, Environmental Justice, and meeting notes 

are included in the administrative record. 

The Forest Service contacted members of the Aak’w Kwaan tribal group (non-federally 

recognized tribe) in August 2012 via email, mail and phone, inviting them to an 

information sharing meeting on August 21, 2012. The Forest Service presented a 

summary of the Draft EIS findings and answered questions from attendees. The meeting 

was attended by members of the Aak’w Kwaan along with representatives from local 

non-governmental organizations. 

Forest Service representatives met with Kootznoowoo Incorporated on October 15, 2010, 

and held a follow-up meeting on November 10, 2010. Following release of the Draft 

EIS, the Forest Service project manager and Monument Ranger again met with 

Kootznoowoo Incorporated on May 14, 2012. The Sealaska Corporation declined Forest 

Service offers to meet. 

1.7 Significant Issues ___________________________ 

With respect to an EIS, issues are points of discussion, debate, or dispute about the 

environmental impacts of the proposed action. Issues may be determined to be 

significant based on the extent, duration, or magnitude of the environmental effect. 

Significant issues focus the environmental analyses in the EIS on the aspects of the 

project that are of the greatest concern to the public or regulatory agencies or have the 

most potential for producing adverse environmental effects. Alternatives to the proposed 

action or specific mitigation measures are developed in response to significant issues. By 

associating measures with individual issues, the public and decision-makers are better 

able to differentiate among different alternatives in terms of environmental impacts. The 

significant issues summarized below are based on public, tribal, and agency comments 

made during the scoping process. The measures to be used to assess each of the issues 

across alternatives are provided at the end of each item. 

Issue 1: Water quality may be impacted directly by runoff from acid-generating tailings 

and waste rock, or by direct impacts of the expanded facilities or by marine discharges of 

mine water. The impacts to water quality could adversely impact aquatic life. 

This issue was identified after considering scoping comments including the following 

comments: 

 Alternative and mitigation measures that minimized adverse impacts to groundwater 

and surface water should be analyzed, especially in areas that may be hydrologically 

connected; 
1.7 Significant Issues 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-13 

 The geochemical stability of the tailings and compliance with Alaska water quality 

standards (WQS) should be investigated; 

 The EIS should discuss past and current monitoring of the marine habitat and water 

quality; 

 Potential impacts to surface waters, even from seepage, should be clearly discussed; 

and 

 Water quality monitoring plans for Tributary Creek, whose headwaters contain 

portions of the TDF, should include biological components such as fish populations, 

macrobenthic invertebrates, and periphyton. These organisms are common indicators 

of water quality. Additionally a suite of toxicology tests should be employed to 

determine if the biological community is adversely affected by any exceedences of 

WQS. 

Assessment Measures: 

 Percent of drainage area and flow lost in area streams; 

 Ability of effluent and storm water discharges to meet applicable Alaska WQS in 

marine and fresh water; 

 Potential for ARD conditions developing in the TDF; 

 Ability to control or prevent discharges of TDF drainage to surface and groundwater; 

and 

 Extent and complexity of water management and treatment infrastructure (e.g., 

surface and groundwater diversions, water management ponds, pipelines, treatment 

and wheel wash facilities) required to protect surface and groundwater and manage 

storm water. 

Issue 2: Expansion of the mine TDF may cause direct and indirect impacts to wetlands. 

Loss of wetlands can affect migrating and resident birds as well as other wildlife species. 

Any impacts to wetlands must be mitigated. 

This issue was identified after considering scoping comments including the following 

specific comments: 

 An approved delineation showing all of the proposed activities that may result in 

impacts to waters of the United States relative to pertinent jurisdictional boundaries 

(i.e., wetland boundaries). Wetland delineation should clearly depict all proposed 

impacts in both linear feet and acreage for streams, and acreage for other waters. 

Both direct and indirect impacts to waters and wetlands should be described in the 

EIS; 

 The loss of wetlands could be mitigated by considering creating shallow water 

wetlands in reclaimed areas to provide habitat for migrating and resident birds as well 

as other wildlife species; 

 Concern for the temporal loss of wetlands was expressed and it was recommended 

that mitigation by habitat restoration or fees be considered to offset impacts of the 

project; 

 Design criteria should include reasonable options for a new remote tailings disposal 

site, predominately an upland site to avoid impacting wetlands; and 

 Impacts to anadromous streams and wetlands that support unique plant or animal 

communities should be avoided and adequate buffers should be established. 
Chapter 1. Purpose and Need for the Proposed Action 

1-14 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Assessment Measures: 

 Acres of wetlands affected; 

 Type of wetlands affected; and 

 Habitat functions of areas affected. 

Issue 3: Construction related to expansion of the tailings and waste rock disposal facility, 

contact water ponds, and roads along or over creeks could negatively impact anadromous 

and resident salmonids and other fish species. 

This issue was identified after considering scoping comments including the following 

specific comments: 

 Potential impacts of situating storm water collection ponds, tailings disposal sites, and 

a road crossing along/over a tributary to Greens Creek should be considered. 

Infrastructure may have negative implications for water quality and natural 

hydrologic function of a tributary, which will impact anadromous and resident 

salmonids in the tributary and main stem of Greens Creek; 

 Impacts to surface water or groundwater could impact fish or fish habitat in Tributary 

and Zinc Creek; 

 Tributary and Zinc creeks provide habitat for anadromous and resident salmonids as 

well as other fish species; and 

 Given the anadromous fish in Greens Creek, alternative sites not adjacent to a 

tributary should be used for tailings disposal and infrastructure. 

Assessment Measures: 

 Length of anadromous (class I) and resident (class II) streams lost, by watershed; 

 Area of facilities that could affect groundwater discharge (wetland fills); and 

 Potential flow reduction due to basin fill and water capture (percent of watersheds 

affected by new disturbance). 

Issue 4: The Greens Creek Mine and proposed expansion occurs partially within the nonwilderness portion of the Admiralty Island National Monument. The Monument was 

established for the purpose of protecting objects of ecological, cultural, geological, 

historical, prehistorical, and scientific interests. Any lease of Monument lands for mining 

must not cause irreparable harm to Monument resources. 

This issue was identified after considering scoping comments including the following 

specific comments: 

 Requests for the feasibility criteria used to determine the relationship of alternative 

sites and impacts on Monument lands as well as alternative sites not located in 

Monument lands; 

 Requests for baseline conditions for the Monument including the community of 

Angoon as well as current structure and function; and 

 The EIS should disclose any reasonable foreseeable activities that would encroach on 

the intrinsic and ecological resources of the Monument. 

Assessment Measures: 

 Availability of suitable lands within existing mine claims, HGCMC controlled lands, 

or off of the Monument; 

 The potential for reclamation of impacted areas to pre-project conditions; 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-15 

 Whether or not surface waters within the Monument will be impacted in the long 

term; and 

 Acres disturbed within the Monument. 

Other Issues: Other issues were identified during the scoping process as important, but 

did not drive the alternatives for this EIS. However these other issues are taken into 

consideration for the impact analysis and for potential mitigation measures. Other issues 

include the following: 

 Current operation plans used to minimize/restrict air emissions and fugitive dust and 

how they may be revised upon expansion should be disclosed; 

 High levels of contaminants in lichens are a concern in light of expansion plans. 

Fugitive dusts have a potential to be released over a greater surface area, with a 

possibility of reaching the Kootznoowoo Wilderness and beyond. Contaminant 

concentrations in lichens are above Tongass thresholds in all of the locations at the 

Greens Creek Mine. Many of the contaminants were the highest found in lichens on 

the Tongass National Forest, including lead, cadmium and sulfur; 

 Impacts to seafloor flora and fauna as a result of the marine discharge of treated mine 

water should be considered. The EIS should disclose all monitoring results of 

seafloor sediment and biota, as well as contaminated sediments at the loading dock; 

 Adequacy of the reclamation and closure bond. Closure bonds should be re-evaluated 

in context of HGCMC’s obligation to protect the environment, including the 

Monument, from significant damage. Adequate bonding for long term water quality 

management, monitoring and treatment should be examined; 

 Potential impacts to transportation and utility corridors should be considered. 

Alternatives should take into consideration impacts on transportation and utility 

corridors and easements created by Congress and the Angoon Community 

Association; and 

 Hawk Inlet area is identified as sacred to the Angoon Community Association 

because of use as a traditional trade route, important food source and area where 

traditions were taught. 

1.8 Agency Responsibilities, Approvals, and 

Compliance ________________________________ 

This section describes the primary roles of each agency involved in developing the EIS. 

The Forest Service is the lead NEPA agency. The USACE, U.S. Environmental 

Protection Agency (USEPA), State of Alaska, and City and Borough of Juneau (CBJ) are 

cooperating agencies. The Forest Service coordinated with the cooperating agencies in 

developing the EIS. The Forest Service consulted with the other agencies identified in 

this section. 

This section also includes a description of the major permits and authorizations required 

for the project. It addresses how this document or the TDF expansion itself complies 

with environmental laws as they pertain to each of the responsible agencies. 

1.8.1 Applicable Laws, Statutes and Ordinances 

The following list presents some of the laws, statutes, and ordinances applicable to 

operation of the Greens Creek Mine: 
Chapter 1. Purpose and Need for the Proposed Action 

1-16 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

 Clean Water Act (CWA); 

 Clean Air Act; 

 General Mining Law of 1872; 

 Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA); 

 National Historic Preservation Act (NHPA); 

 National Environmental Policy Act (NEPA); 

 Migratory Bird Treaty Act (MBTA); 

 Fish and Wildlife Coordination Act; 

 Bald and Golden Eagle Protection Act; 

 Marine Mammal Protection Act (MMPA); 

 Endangered Species Act (ESA); 

 Alaska National Interest Lands Conservation Act (ANILCA); 

 Greens Creek Land Exchange Act; 

 Wilderness Act of 1964; 

 Forest Service Roadless Area Conservation (2001 Roadless Rule); 

 Alaska Administrative Code Title 18, Chapters 50, 60, 70, 72, 83, and 97; 

 Alaska Statute AS 16.05.841, AS 16.05.871, AS 27.19 and 46.17; 

 City and Borough of Juneau Exploration and Mining Ordinance (CBJ Title 49, 

Chapter 49.65, Article I); and 

 2008 City and Borough of Juneau Comprehensive Plan. 

1.8.2 Permits and Decisions for Continued Operation 

of the Greens Creek Mine 

The Forest Service, USACE, State of Alaska, and CBJ must all issue permits, 

authorizations, or approvals for the HGCMC to expand the TDF. These permits and 

authorizations include the following: 

 EIS ROD – Forest Service and USACE; 

 Approval of expansion of the lease of National Forest lands – Forest Service; 

 Approval of changes to the GPO – Forest Service; 

 Readjustment of the Reclamation Bond – Forest Service, ADEC, Alaska Department 

of Natural Resources (ADNR), and CBJ; 

 Section 404 permit for discharge of fill into waters of the United States – USACE; 

 Waste Management Permit – ADEC; 

 Reclamation and closure plan approval – ADNR; and 

 Large Mine Permit – CBJ. 

1.8.3 Federal Agencies 

1.8.3.1 Forest Service 

The Forest Service is responsible for NEPA compliance and issuing a ROD for the Final 

EIS. The Forest Service is also responsible for the following: 

 Approval of 2010 Amended GPO; 

 Approval of a lease expansion 

 Compliance with Section 106 of the NHPA; 

 Compliance with Sections 313 and 319 of the CWA; 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-17 

 Compliance with Section 7 of the ESA; 

 Compliance with Section 305 of the MSFCMA, including consultation with the 

National Marine Fisheries Service (NMFS) on essential fish habitat (EFH); 

 Compliance with applicable Executive Orders (specifically 11988, Floodplain 

Management; 11990, Protection of Wetlands; 12088, Federal Compliance with 

Pollution Control Standards; 12898, Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations; 12962, Recreational 

Fisheries; and 13175, Consultation and Coordination with Indian Tribal 

Governments); and 

 Consistency with 2008 Tongass National Forest Land and Resource Management 

Plan. 

The Forest Service is the lead agency in the preparation of the Greens Creek Mine 

Tailings Disposal Facility Expansion EIS. The Forest Service’s authority to require, 

evaluate, and approve or modify the operator’s GPO is based on the Organic Act of 1897 

and on the Mining Law of 1872, which is described in 36 CFR Part 228, Subpart A. If 

another agency cannot meet its regulatory responsibilities, the Forest Service is ultimately 

responsible for ensuring that federal and state regulations are implemented on National 

Forest System lands. 

All alternatives are consistent with the 2008 Tongass National Forest Land and Resource

Management Plan (Forest Service 2008a). The site is in an area with the following 

designated land uses: Non-wilderness National Monument and Semi-remote Recreation. 

The goals for management in the Non-wilderness National Monument are as follows: 

 To manage Admiralty Island National Monument for public access and uses 

consistent with ANILCA; 

 To facilitate the development of significant mineral resources located within portions 

of Admiralty Island National Monument, as specified by ANILCA; 

 To protect objects of ecological, cultural, geological, historical, pre-historical, and 

scientific interest, as specified by ANILCA, and the GPO, as well as minimize effects 

on non-mineral resources to the extent feasible. In the long term, when mining is 

completed, to reclaim areas disturbed by mining to a near-natural condition; and 

 To limit mining activities to claims with valid existing rights, and to the land area 

actually needed to carry out mining operations. 

The goals for management of the Semi-remote Recreation areas are as follows: 

 To provide predominantly natural or natural-appearing settings for semi-primitive 

types of recreation and tourism, and occasional enclaves of concentrated recreation 

and tourism facilities; and 

 To provide opportunities for a moderate degree of independence, closeness to nature, 

and self-reliance in environments requiring challenging motorized or non-motorized 

forms of transportation. 

Forest Plan Objectives 

Forest Plan objectives include: 

 Ensure that the Plan of Operations for each mineral development specify the activities 

to be conducted, the location and timing of those activities, and how the environment 
Chapter 1. Purpose and Need for the Proposed Action 

1-18 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

and resources in each area will be protected through compliance with federal and 

state requirements (Forest Service 2008a, page 3-26). 

 In areas affected by mining, manage activities to maintain the productivity of 

anadromous fish and other foodfish habitat to the maximum extent feasible. Stress 

protection of fish habitat to prevent the need for mitigation (Forest Service 2008a, 

page 3-26). 

 In areas affected by mining, manage public recreation use as directed in the Plan of 

Operations. Outside these areas, manage recreation use and activities to meet the 

appropriate levels of social encounters on-site developments, methods of access, and 

visitor impacts indicated for the adopted or existing Recreation Opportunity 

Spectrum, as appropriate (Forest Service 2008a, page 3-26). 

 Locate and manage trails to direct the public away from mining operations (Forest 

Service 2008a, page 3-27). 

 Develop reclamation plans prior to project initiation. Include, as needed, 

rehabilitation of fish and wildlife habitats, soil resources, and the scenery (Forest 

Service 2008a, page 3-27). 

The process of alternatives development described in Chapter 2 took these objectives into 

account. 

Standards and Guidelines for Minerals and Geology 

Standards and guidelines are designed so that all activities are integrated to meet land 

allocation objectives. Standards and guidelines are intended to be used in conjunction 

with national and regional policies, and direction contained in Forest Service manuals 

and handbooks. Forest-wide Standards and Guidelines apply to all or most areas of the 

Forest and provide for the protection and management of forest resources. They are used 

in conjunction with the additional standards and guidelines given in the management 

prescriptions for each Land Use Designation (LUD). Forest-wide Standards and 

Guidelines for Minerals and Geology that applicable to this analysis are provided below 

(MG2 I, II, III, and VI, Forest Service 2008a). 

Minerals and Geology Administration MG2: 

I. Forest Lands Withdrawn from Mineral Entry 

A. Claimants with claims located in areas withdrawn from mineral entry retain 

valid existing rights, if such rights are established prior to the withdrawal 

date. 

B. Conduct on-the-ground validity examinations by a certified minerals 

examiner to establish or reject valid existing rights on active mining claims 

within Wilderness areas and other areas withdrawn from mineral entry. 

C. Permit reasonable access to mining claims in accordance with the provisions 

of an approved Plan of Operations. Motorized access to sites may be 

authorized as part of the Plan of Operations. Use of off-highway vehicles 

may be allowed and must be in accordance with 36 CFR 212, 251, and 261 – 

Travel Management; Designated Routes and Areas for Motor Vehicle Use. 

II. Forest Lands Open to Mineral Entry 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-19 

A. Encourage the exploration, development, and extraction of locatable, salable, 

and leasable minerals and energy resources. 

B. Assure prospectors and claimants their right of ingress and egress granted 

under the General Mining Law of 1872, ANILCA, and the National Forest 

Mining Regulations (36 CFR 228). 

C. Permit reasonable access to mining claims and mineral leases in accordance 

with the provisions of an approved Plan of Operations. 

III. Locatable Mineral Operations 

A. An NOI and/or a Plan of Operations is required for locatable operations 

(Consult FSM 2810 and 36 CFR 228). 

1. A Plan of Operations will receive prompt evaluation and action within 

the time frames established in 36 CFR 228. 

2. Conduct an environmental analysis with appropriate documentation for 

all operating plans. 

3. Locatable mineral exploration and/or development situated in areas 

identified in the Forest Plan for intensive development (minerals 

overlay) must be consistent with standards and guidelines for mineral 

development. 

4. Following locatable mineral exploration and/or development site 

rehabilitation and restoration will be designed to return the site to as near 

as practicable to a condition consistent with the underlying non-mineral 

LUD. 

B. Work with claimants to develop a Plan of Operations that adequately 

mitigates adverse impacts to LUD objectives. Include mitigation measures 

for locatable actions that are compatible with the scale of proposed 

development and commensurate with potential resource impacts. 

1. Maintain the habitats, to the maximum extent feasible, of anadromous 

fish and other foodfish, and maintain the present and continued 

productivity of such habitats when such habitats are affected by mining 

activities. Assess the effects on populations of such fish in consultation 

with appropriate state agencies (consult ANILCA, Section 505(a)). 

2. Apply appropriate Transportation Forest-wide Standards and Guidelines 

to the location and construction of mining roads and facilities. 

3. Reclaim disturbed areas in accordance with an approved Plan of 

Operations. Apply approved seed mixtures as needed (Consult 

Standards and Guidelines for Plants and FSH 2080). 

4. Apply Best Management Practices (BMPs) to maintain water quality for 

the beneficial uses of water (Consult FSH 2509.22). 

5. Periodically inspect minerals activities to determine if the operator is 

complying with the regulations of 36 CFR 228 and the approved Plan of 

Operations. 
Chapter 1. Purpose and Need for the Proposed Action 

1-20 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

VI. Bonds 

A. A bond will be required for locatable, leasable, and salable mineral 

operations to ensure operator performance and site reclamation are completed 

(Consult 36 CFR 228). 

Pursuant to the Organic Administration Act and 36 CFR 228, Subpart A, the Forest 

Service requires that mine operators submit a reclamation bond, or financial assurance, 

prior to approval or modification of the GPO. The purpose of the reclamation bond is to 

assure reclamation of surface disturbances to prevent or control damage to the 

environment, to control erosion, landslides, water runoff and toxic materials and to 

provide for rehabilitation of fish and wildlife habitat. 

The State of Alaska requires financial assurance from mines in accordance with Alaska 

Statutes 27.19 (Reclamation) and 38.05 (Alaska Land Act) and the Alaska Administrative 

Code, Title II and Chapter 97 (Mining Reclamation). The CBJ also requires financial 

warranties to be in place for mining operations prior to issuance of the Large Mine Permit 

(CBJ 49.65.140). For large mine operations, the reclamation bond is usually in the form 

of a surety or irrevocable letter of credit because of the significant obligation that 

reclamation typically represents. 

Because the Greens Creek Mine already exists, the Forest Service and State of Alaska 

jointly hold a reclamation bond to assure reclamation of the currently approved 

operations. At this time, the reclamation bond value is being recalculated as part of its 

regular review cycle. The current reclamation bond value is over $26 million. 

As required by 36 CFR 228.13 (c), if the approved plan of operations is modified, the 

agencies would review the initial bond for adequacy and, if necessary, would adjust the 

bond to conform to the operations plan as modified. The modification will only be 

approved when the required bond is received. After the Forest Service selects an 

alternative and issues its ROD, HGCMC may, depending on the alternative selected, 

submit an updated reclamation plan and cost estimate for the first stage of expansion of 

the TDF to the Forest Service and State of Alaska. Agency engineers and Certified 

Locatable Mineral Administrators would review the plan and cost estimate to ensure it 

was adequate. If the Forest Service and State of Alaska conclude that an increase in the 

bond amount would be necessary, HGCMC must submit the additional bond amount 

before the approved modifications can be executed. The bond amount is the agencies’ 

estimated cost to complete full reclamation of the site in the event the operator cannot or 

will not perform the required reclamation. Reclamation is not only defined as surface 

reclamation; it can also include long-term water management and treatment. The 

reclamation plan and bond would be developed and reviewed in stages consistent with 

the staged TDF expansion and commensurate with actual disturbances. HGCMC would 

not be required to post bond for reclamation of facilities that would not be built for 

decades. 

See Appendix C for additional detailed information on reclamation bond requirements. 

Alaska National Interest Lands Conservation Act 

ANILCA establishes requirements for mining operations within the Monument (Section 

503), maintaining fisheries habitat associated with mineral activities on the Monument 

(Section 505), and ensuring that such activities will not significantly restrict subsistence 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-21 

uses (Section 810). Appendix B addresses each of these issues explaining how the Forest 

Service arrived at the relevant findings under each particular ANILCA section. 

National Historic Preservation Act 

Prior to approving a revision to the existing GPO, the Forest Service must comply with 

Section 106 of the NHPA. Compliance with NHPA generally involves the following: 

 Identification of historic features that may be affected; 

 Assessment of effects to those features; 

 Consultation with the State Historic Preservation Officer (SHPO) and interested 

parties; and 

 Consideration of comments by the Advisory Council on Historic Preservation if 

historic features could be affected. 

The Forest Service has initiated consultation with the SHPO and will continue the 

process through development of the EIS. Review comments provided by the SHPO have 

been incorporated into this document. The Forest Service has made a determination of 

No Adverse Effect for each of the alternatives. The SHPO has concurred with this 

determination. 

Clean Water Act 

Under agreement between the Forest Service and the ADEC, the Forest Service is 

committed to ensuring that activities on National Forest System lands are consistent with 

the requirements of the CWA, Sections 319(b)(2)(f); 319(k); 313; and Executive Order 

12088. Section 319 addresses nonpoint source pollution, and Section 313 and Executive 

Order 12088 require the Forest Service to adhere to the goals set forth in state WQS. 

Numerous comments beginning with scoping and continuing through the Draft EIS have 

requested the Forest Service consider aspects of the ADEC-authorized wastewater 

discharge as part of the alternatives analysis. Reissuance of the permit is a process 

independent from to the proposed action under consideration – neither action depends on 

the outcome of the other. As noted in comment responses (Appendix A) and in the body 

of this document, the Forest Service is responsible for ensuring that the CWA 

requirements are met on National Forest System lands. Regulations in 36 CFR 228.8(h) 

state that “certification or other approval issued by state agencies or other federal 

agencies of compliance with laws and regulations relating to mining operations will be 

accepted as compliance...with these regulations.” The Forest Service therefore accepts 

the APDES permit as compliance with CWA requirements. 

The Forest Service recently issued National Core BMPs (Forest Service 2012) for water 

quality management on National Forest lands. Directives for using these BMPs, which 

are targeted at non-point source discharges, are currently in development. Once the 

directives have been developed, HGCMC will be responsible for integrating the most 

current BMP guidance into their operations. 

Magnuson-Stevens Fishery Conservation and Management Act and 

Recreational Fisheries Executive Order 

An EFH assessment has been prepared in consultation with the NMFS. Section 305(b)(2) 

of the MSFCMA states that all federal agencies must consult the National Oceanic and 

Atmospheric Administration NMFS for actions or proposed actions that may adversely 
Chapter 1. Purpose and Need for the Proposed Action 

1-22 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

affect EFH. The act promotes the protection of EFH through review, assessment and 

mitigation of activities that may adversely affect these habitats. The MSFCMA requires 

a determination on the effects of the Greens Creek TDF expansion project on EFH. The 

EFH assessment, which includes a description of the proposed activities and a description 

of the proposed mitigation measures that will be implemented to protect these essential 

habitats, was addressed in a parallel process with this EIS. During that process, NMFS 

provided comments on the EFH assessment, including conservation recommendations, on 

July 19, 2012. The Forest Service responded to each of their conservation 

recommendations in a response letter and will continue to consult with NMFS. 

Consultation records are included in the administrative record

Recreational Fishery Executive Order 

Executive Order 12962 directs federal agencies to conserve, restore and enhance aquatic 

systems to provide for increased recreational fishing opportunities nationwide. This 

order directs federal agencies to evaluate effects on aquatic ecosystems and recreational 

fisheries, develop and encourage partnerships, promote restoration, provide access and 

promote awareness of opportunities for recreational fishery resources. The effects of this 

project on freshwater and marine resources were evaluated during the analysis. 

Wetlands and Floodplains Executive Orders 

Executive Orders 11988 and 11990 address minimizing impacts on the nation’s wetlands 

and/or floodplains are discussed below in Section 1.8.3.2, U.S. Army Corps of Engineers. 

Tribal Consultation Executive Order 

Executive Order 13175 requires federal agencies to establish a consultation process for 

interactions with Indian tribes in the development of regulatory policies that have tribal 

implications. Executive Order 13175 is addressed by ongoing consultation with Alaska 

Native groups, as discussed in Section 1.6, Government-to-Government Consultations, 

Section 3.21, Environmental Justice, and Section 4.2, Federal Consultation. 

Environmental Justice Executive Order 

Executive Order 12898 requires federal agencies to identify and address 

disproportionately high and adverse human health or environmental effects of proposed 

activities on minority and low-income populations. This document addresses Executive 

Order 12898 by considering the potential impacts of each alternative on minority and 

low-income populations in the discussions of recreation, socioeconomic impacts, and 

environmental justice. 

1.8.3.2 U.S. Army Corps of Engineers 

The USACE is responsible for deciding whether to issue the CWA Section 404 permit for 

the discharge of fill needed to construct the TDF expansion. The USACE is a 

cooperating agency in developing this EIS since the USACE has an independent 

requirement to comply with NEPA before making its 404 decision. The USACE’s 

decision will be documented in a ROD. The USACE responsibilities include the 

following: 

 Participation as a NEPA cooperating agency in development of the EIS; 

 NEPA compliance for issuance of the Section 404 permit; 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-23 

 Issuance of a ROD; 

 Issuance of a Section 404 Permit: CWA (Dredge and Fill); 

 Compliance with all executive orders (specifically 11988, 11990, 12088, 12898, 

12962, 13045, and 13175); 

 Compliance with Section 106 of the NHPA; and 

 Compliance with the MSFCMA. 

CWA Section 404 authorizes the USACE to issue permits for discharge of dredged or fill 

material into waters of the United States. The CWA prohibits such a discharge except 

pursuant to a Section 404 permit. Various activities undertaken by HGCMC in 

connection with the proposed action and alternatives have the potential to affect waters of 

the United States, including expansion of the TDF and construction and operation of 

access roads, truck wash facility, contact water facilities, quarry sites, disposal areas, a 

water treatment plant, and a water discharge outfall line into Hawk Inlet. To the extent 

that these activities would involve the placement of fill in waters of the United States, 

including jurisdictional wetlands, a Section 404 permit would be required. The USACE 

is responsible for determining whether an action complies with CWA Section 404(b)(1) 

guidelines; a Section 404 permit may not be issued without such compliance. 

All federal agencies, including the USACE, must comply with Executive Orders 11990 

and 11988, which address minimizing impacts on the nation’s wetlands and floodplains, 

respectively. The USACE’s regulatory program provides some flexibility when 

considering the national goal of “no net loss” of wetlands. Because the “no net loss” goal 

cannot always be achieved on an individual project-by-project basis, the Alaska District 

of the USACE may consider site-specific conditions and impacts when determining the 

extent of compensatory mitigation required for wetland losses. Under Executive Order 

11988, any bridges proposed under each of the alternatives would need to be constructed 

to ensure public safety and minimize impacts on the floodplain. 

The MSFCMA requires the USACE to consult with NMFS regarding the protection of 

EFH before a Section 404 permit may be issued. The previous section described the 

MSFCMA requirements and how this EIS includes the MSFCMA evaluation. 

Like the Forest Service, the USACE needs to comply with the NHPA and executive 

orders requiring tribal consultation and environmental justice considerations. The 

USACE is relying on this EIS and is cooperating with the Forest Service on these issues. 

1.8.3.3 U.S. Environmental Protection Agency 

The USEPA has a range of responsibilities related to the proposed TDF expansion at 

Greens Creek including the following: 

 Participation as a NEPA cooperating agency; 

 Compliance with the CWA (review of the CWA 404 permit public notice and 

oversight of the CWA 402 permit developed by ADEC); 

 Compliance with the Clean Air Act (oversight of the ADEC air permit and review 

and comment on the EIS); and 

 Notification of hazardous waste activity. 

The USEPA is a cooperating agency with the Forest Service on this EIS. The USEPA 

has primary responsibility for implementing CWA Sections 301, 306, 311, and 402. The 

USEPA shares responsibility for Section 404 with the USACE. Sections 301 and 306 of 
Chapter 1. Purpose and Need for the Proposed Action 

1-24 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the CWA require that USEPA develop wastewater effluent standards for specific 

industries, including metals mines. These standards are established for both existing 

sources and new sources. 

The USEPA initially issued a National Pollutant Discharge Elimination System (NPDES) 

permit for the Greens Creek mine in 1987; the permit was re-issued in 1998 and again in 

2005. The ADEC achieved primacy for issuing discharge permits under the CWA and as 

described below (subsection Alaska Department of Environmental Conservation) has 

authority for the wastewater discharge program. 

The USEPA also has authority under CWA Section 404 to review project compliance 

with Section 404(b)(1) guidelines and Section 404(c) guidelines. Under Section 

404(b)(1) the USEPA must ensure that the USACE has selected the least damaging 

practicable alternative. Under Section 404(c), the USEPA may prohibit or withdraw the 

specification (permitting) of a site upon determination that use of the site would have an 

unacceptable adverse effect on municipal water supplies, shellfish beds, fishery areas, or 

recreational areas. 

Section 311 of the CWA establishes requirements related to discharges or spills of oil or 

hazardous substances. Under 40 CFR Part 112, the USEPA requires each facility that 

handles substantial quantities of oil to prepare a Spill Prevention, Control and 

Countermeasures plan. A registered engineer must certify the Spill Prevention, Control 

and Countermeasures plan. The USEPA Regional Administrator would make a 

determination regarding whether a facility response plan is required. 

The most basic goals of the Clean Air Act are to protect public health and welfare. The 

Clean Air Act Section 309 requires the USEPA to review and comment on EISs. In 

addition, the USEPA approves state implementation plans for air quality and reviews Air 

Quality Control Permit to Operate applications, including requirements for prevention of 

significant deterioration (PSD). 

1.8.3.4 U.S. Fish and Wildlife Service 

The U.S. Fish and Wildlife Service (USFWS) is responsible in this process for the 

following: 

 Consultation on the ESA; 

 Compliance with the Bald Eagle Protection Act; and 

 Coordination under the Fish and Wildlife Coordination Act. 

The USFWS and NMFS share responsibility for implementing the ESA (16 USC 1531 et 

seq.). Generally, USFWS manages land and freshwater species, while NMFS manages 

marine and “anadromous” species. The USFWS also administers the Bald Eagle 

Protection Act of 1940, as amended, and the Fish and Wildlife Coordination Act. The 

Forest Service must consult with USFWS regarding any threatened or endangered species 

that may be impacted by the proposed project. If any impacts are projected, specific 

design measures must be developed to protect the affected species. The Fish and 

Wildlife Coordination Act provides a procedural opportunity for the USFWS to 

coordinate with the Forest Service and offers means and measures to benefit fish and 

wildlife resources through mitigation of impacts to water resources and associated fish 

and wildlife. A biological assessment (BA) was prepared for this project evaluating 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-25 

effects to threatened and endangered species. No ESA listed species managed by the 

USFWS occur within the project area. 

1.8.3.5 National Marine Fisheries Service 

The NMFS is responsible in this process for the following: 

 Consultation on ESA; 

 Consultation on EFH; 

 Consultation on the MMPA; and 

 Consultation on the Research and Sanctuaries Act. 

The NMFS manages marine and anadromous ESA species. Section 7(a)(2) of the ESA 

requires federal agencies to consult with the NMFS on activities that may affect a listed 

species. These interagency consultations are designed to assist federal agencies in 

fulfilling their duty to ensure federal actions do not jeopardize the continued existence of 

a species or destroy or adversely modify critical habitat. If any impacts are projected, 

specific design measures must be developed to protect the affected species. A BA was 

prepared for this project (Tetra Tech 2013). A determination of “no effect” is rendered in 

regard to all threatened and endangered species with the exception of the humpback 

whale and Steller sea lion where a “not likely to adversely affect” determination was 

made. The NMFS concurred with this determination and added that, given the limited 

scope of action impacts in marine waters as well as the required protections in place, this 

action would have, at most, an insignificant or discountable effect on humpback whales 

and Stellar sea lions species. 

The NMFS also manages EFH. Section 305(b)(2) of the MSFCMA states that all federal 

agencies must consult the National Oceanic and Atmospheric Administration NMFS for 

actions or proposed actions that may adversely affect EFH. An EFH assessment has been 

prepared in consultation with the NMFS. The NMFS provided comments on the EFH 

assessment, including conservation recommendations, on July 19, 2012. See Section 

3.7.4.1 and the EFH Assessment (Tetra Tech 2012) available in the project record. 

1.8.4 State and Local Government 

1.8.4.1 State Authorities 

The State of Alaska is a cooperating agency. Below, the responsibilities of ADNR, 

ADEC, and Alaska Department of Fish and Game (ADF&G) are presented. 

Alaska Department of Natural Resources 

The ADNR has a range of responsibilities in the process of approving the proposed 

expansion at Greens Creek, including the following: 

 Coordination of all State of Alaska agency reviews; 

 Water rights authorizations; 

 Right-of-way authorization; and 

 Reclamation Plan approval, including financial assurance adequacy. 

The ADNR is the lead State of Alaska agency involved in permitting mining projects in 

the State of Alaska. In addition to ADNR, State of Alaska agencies involved in 

permitting or oversight of the Greens Creek Mine include ADEC, ADF&G, and Alaska 
Chapter 1. Purpose and Need for the Proposed Action 

1-26 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Department of Law. The State of Alaska established a large mine project team from 

these agencies to coordinate permitting activities for the Greens Creek Mine TDF 

expansion. 

The ADNR is responsible for issuing water rights authorizations for the use of surface 

and subsurface waters of the State of Alaska. These permits require compliance with 

instream flow requirements. The ADNR Division of Mining, Land and Water is 

responsible for approval of the reclamation and closure plan. 

Alaska Department of Environmental Conservation 

The ADEC is responsible for the following decisions related to the TDF expansion: 

 Waste Management Permit covering disposal of mine tailings, waste rock, 

overburden, and solid waste, management of groundwater, storage and containment 

of hazardous chemicals, facility reclamation and facility closure; 

 Air Quality Permit to Operate; 

 CWA Section 401 certifications of reasonable assurance for USACE Section 404 

permit; and 

 Alaska Pollutant Discharge Elimination System Permit (including storm water). 

The ADEC is responsible for issuing an integrated waste management permit that 

includes requirements for solid waste disposal, groundwater protection, mine reclamation 

and closure, financial assurance, and monitoring. 

The ADEC is responsible for issuing the facility’s air quality permits for construction 

activities and operations at the port and the mine. The ADEC will evaluate the changes 

to emissions sources associated with development of the Greens Creek Mine and, based 

on the review, require new permits or modification of existing permits as applicable. 

Under Section 401 of the CWA, ADEC responsibilities include certification of the 

USACE Section 404 permit. The ADEC must certify that the requirements of these 

permits comply with state WQS. 

On October 31, 2008, the ADEC assumed initial authority over permitting, compliance, 

and enforcement of the APDES program under Section 402 of the CWA; ADEC’s 

authority over mining APDES permits began on October 31, 2010. APDES permit limits 

and other requirements are established to ensure compliance with state WQS for both 

marine water and freshwater. The New Source Performance Standards specifically 

include effluent limits applicable to discharges of mine drainage; they also prohibit the 

discharge of process water (including tailings effluent). An exception is provided for 

excess flows associated with net precipitation where the discharge of such flow is subject 

to the comparable effluent limits for mine drainage. USEPA is authorized to oversee 

ADEC’s implementation of the program and can intervene on any permit issued, 

renewed, or modified by the State of Alaska. The Greens Creek Mine’s NPDES permit 

was assigned the designation of APDES when it transferred from USEPA to ADEC 

under Phase III of the NPDES transfer of authority program. The permit establishes 

water quality based effluent limits and monitoring requirements for treated process water 

being discharged to Hawk Inlet. It also establishes storm water monitoring requirements 

at 10 locations throughout the Greens Creek Mine area. 

At the time this EIS is being prepared, the ADEC is in the process of reissuing the 

APDES permit for the Greens Creek Mine. The reissuance of the permit and the 
1.8 Agency Responsibilities, Approvals, and Compliance 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 1-27 

conditions set by the permit are independent of, and unrelated to, the TDF expansion 

considered in this NEPA analysis. Until the APDES permit is reissued, the conditions 

and limitations of the 2005 permit will remain in effect. Under the APDES permit, the 

Permittee is authorized to discharge pollutants from outfalls 002 and 003 to Hawk Inlet, 

outfall 004 to wetlands, outfall 005.2 to Zinc Creek, and outfalls 005.3, 005.4, 005.5, 006, 

007, 008, and 009 to forest duff or Greens Creek, within the limits and subject to the 

conditions set forth in the APDES permit. The APDES permit authorizes the discharge 

of only those pollutants resulting from facility processes, waste streams, and operations 

that have been clearly identified in the permit application process. 

Alaska Department of Fish and Game 

The ADF&G’s authority to issue permits covers a variety of activities (water removal, 

instream work, water diversions, etc.) in anadromous water bodies and in resident fish 

streams. The Anadromous Fish Act (AS 16.05.871-.901) requires that an individual or 

government agency provide prior notification and obtain permit approval from ADF&G 

before altering or affecting “the natural flow or bed” of a specified waterbody or fish 

stream. All activities within or across a specified anadromous waterbody require 

approval from ADF&G, Division of Habitat, including construction; road crossings; 

gravel removal; mining; water withdrawals; the use of vehicles or equipment in the 

waterway; stream realignment or diversion; bank stabilization; blasting and the 

placement, excavation, deposition, or removal of any material. 

The Fish Passage Act (AS 16.05.841) requires that an individual or government agency 

notify and obtain authorization from ADF&G, Division of Habitat, for activities within or 

across a stream used by fish if it is determined that such uses or activities could represent 

an impediment to the efficient passage of resident or anadromous fish. 

 Fish Habitat Permit. 

1.8.4.2 Local Authorities: City and Borough of Juneau 

The Greens Creek Mine is located within the CBJ which is responsible in this process for 

the following: 

 Participation as a cooperating agency in the NEPA/EIS process; and 

 Issuance of an Allowable Use Permit. 

The City and Borough of Juneau Land Use Code Section 49.65.115(c) establishes the 

Greens Creek Mine as a rural mine subject to the Allowable Use Permit process. City 

and Borough of Juneau Land Use Code establishes 50-foot no-development setbacks 

from anadromous streams; 330-foot no-development buffer from eagle nests; building 

and grading permits; and compliance with the August 2010 City and Borough of Juneau 

Manual of Storm Water Best Management Practices. The CBJ is participating as a 

cooperating agency and will use information from the EIS to provide the required 

information and analysis for the Allowable Use Permit process related to expansion of the 

TDF. 

 
Chapter 1. Purpose and Need for the Proposed Action 

1-28 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 
2.1 Greens Creek Mine Overview 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-1 

CHAPTER 2. DESCRIPTION OF PROPOSED 

ACTION AND OTHER ALTERNATIVES 

Chapter 2 describes the proposed action for the Greens 

Creek Mine Tailings Disposal Facility Expansion and a 

range of alternatives. The chapter describes how the 

alternatives were developed as well as the similarities 

and the differences among them. The alternatives 

described focus on whether, where, and how to develop 

additional tailings disposal capacity to accommodate 

resources identified by Hecla Greens Creek Mining 

Company (HGCMC or the operator). The comparison 

of the proposed action with alternatives is a requisite of 

the National Environmental Policy Act (NEPA). 

This chapter begins with a brief overview of mining 

activities at the Greens Creek Mine that would be 

similar under all alternatives to provide context as to 

how each alternative would fit within the existing 

operation. The subsequent subsections discuss 

alternatives development within the NEPA process, detailed descriptions of the 

alternatives themselves, the components of mining operations, alternatives considered but 

eliminated from further analysis, mitigation and monitoring opportunities and 

requirements, and summary tables briefly comparing the effects of each alternative across 

the range of resource areas analyzed in detail in Chapter 3. 

2.1 Greens Creek Mine Overview _________________ 

The Greens Creek Mine is located on Admiralty Island, approximately 18 miles 

southwest of Juneau, Alaska, and 38 miles north of Angoon, Alaska. Hoonah, Alaska, 

and Tenakee Springs, Alaska, are located on nearby Chichagof Island. The existing 

operation is shown in Figure 1.1-3. The existing tailings disposal facility (TDF) is 

located entirely on National Forest System lands, including parts of both the Juneau 

Ranger District and the Admiralty Island National Monument (Monument). Many 

aspects of the day-to-day operations of the Greens Creek Mine would remain the same 

under all alternatives or would need to be maintained in some fashion under each 

alternative. These components include the mining activity itself, mineral processing, 

concentrate transport, waste disposal, and water management. This subsection provides a 

brief overview of these various components of the mining operations. 

Underground mining methods are used to remove ore from the mine. Ore is removed 

from the mine and placed in stockpiles near the mill building. Ore moving through the 

mill ultimately becomes either concentrate, which is trucked to the port facility and 

shipped to smelters around the world, or tailings. The mill at the Greens Creek Mine 

yields a silver/gold product (doré), and zinc, lead, and bulk concentrates. 

Tailings Disposal Facility – for 

simplicity, the text refers to the 

tailings disposal facility (TDF). 

However, while the majority of 

material placed into the TDF is 

tailings, waste rock, sludge 

from the wastewater treatment 

plant (WWTP), and solid 

wastes are also placed into 

the facility in accordance with 

the Plan of Operations and 

State of Alaska Waste 

Management Permit.
Chapter 2. Description of Proposed Action and Other Alternatives 

2-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Waste material produced at the site principally consists of tailings and waste rock. Waste 

rock is synonymous to non-mineralized material or rock that has mineral values below 

those that can be economically processed. Waste rock must be removed to gain access to 

the ore. As part of the mining activity, waste rock and tailings are backfilled into some of 

the voids created by the mining process to provide structural stability within the mined 

out areas. Tailings that are not backfilled are trucked to the TDF where they are placed in 

a series of layers (lifts) within disposal locations (cells). 

All water coming in contact with mine-related activities is collected and either recycled 

back to the mill or treated and discharged into Hawk Inlet as authorized in the Alaska 

Pollutant Discharge Elimination System (APDES) permit. The flow of water is 

controlled using a series of ditches, ponds, and sumps located around all the facilities. 

The water treatment plant at the mill treats water used in the milling process, mine water, 

and contact water collected in the immediate vicinity of the mill. Water discharged from 

this treatment plant can be directed back to the mill for re-use or to a water management 

pond from which it passes through a second water treatment plant prior to discharge to 

Hawk Inlet. 

No changes to the mining or mineral processing are being considered in this analysis; 

alternatives focus on tailings disposal. 

2.2 Issues and Alternative Development ___________ 

The proposal to develop additional tailings disposal capacity requires approval from the 

Forest Service, U.S. Department of Agriculture (Forest Service) for a modification in the 

General Plan of Operations (GPO). The Forest Service’s decision regarding whether or 

not to approve modification of the GPO is a major federal action that requires a NEPA 

review, including development of an environmental impact statement (EIS). The Forest 

Service conducted the scoping process to determine the range of issues to be addressed in 

the EIS. The significant issues (see Chapter 1) derived from the scoping process shaped 

the development of the alternatives and forms the comparison of the proposed action and 

alternatives. 

The following describes how the significant issues (water quality, wetlands, fish habitat, 

and Admiralty Island National Monument) influenced the alternatives development 

process: 

Water Quality: After assessing the potential benefit of incorporating additives to 

the tailings to modify the TDF’s geochemical behavior as assessed in the 2003 

EIS, any alternative would require similar water management and long-term 

treatment. There are no fundamental differences among the alternatives with 

respect to water management measures (e.g., clean water diversions, minimizing 

contact water, controlling runoff) and treatment (long term treatment required) 

needs. Alternatives C and D, however, would expand tailings disposal into new 

watersheds, Fowler Creek, and North Hawk Inlet. 

Wetlands: During alternatives development, an emphasis was placed on avoiding 

wetlands with the highest priority placed on wetlands located in the headwaters of 

anadromous streams. Two alternatives (C and D) were developed that would 

limit impact to Tributary Creek wetlands by creation of a new TDF outside of the 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-3 

Tributary Creek watershed. Alternative C minimizes expansion in the Tributary 

Creek wetlands. Alternative D also reduces impacts to Tributary Creek wetlands 

compared to the proposed action. Development of a new TDF site, however, 

requires more space and would ultimately affect more wetlands (by acres). 

Fish Habitat: During alternatives development, an emphasis was placed on 

avoiding impacts to fish habitat. Alternative C is located so that it minimizes the 

extent of stream impacts. Based on the size of the disposal facility, it was not 

possible to avoid all stream impacts when siting the facility. 

Admiralty Island National Monument: Two alternatives (C and D) were 

developed that limit expansion within the Monument by creation of a new TDF 

outside the Monument. Alternative C would allow a smaller expansion footprint 

within the Monument than Alternative D. 

Appendix D provides additional detail on the alternative screening and selection process. 

2.3 Alternatives ________________________________ 

The proposed action is the basis for conducting the NEPA analysis and for the 

development of alternatives. In addition to the proposed action three alternatives were 

developed for detailed analysis in this EIS. NEPA requires the consideration of a No 

Action Alternative reflecting the outcome should the lead agency chose not to move 

forward with the action under consideration. Other alternatives developed in response to 

the significant issues, must meet the purpose and need of the project and present 

reasonable approaches for implementing the proposal. Another set of alternatives 

described below are those that were considered in the planning stages but not carried 

forward for detailed analysis. 

Under the No Action Alternative (Alternative A), mining would cease in approximately 

2019 when the currently approved TDF reaches its full capacity. The proposed action 

(Alternative B) would extend the tailings lease area and TDF footprint south into the 

Monument providing capacity for tailings and waste rock disposal for an additional 30 to 

50 years. Alternatives C and D address the need for the same volume of waste disposal 

(tailings and rock) but would result in a smaller increase in the footprint of the existing 

TDF within the Monument; however, they would require construction of a new TDF 

located approximately 3 miles to the north of the existing TDF. Alternatives B through D 

would be sized to accommodate tailings and waste rock (see Section 2.4.3) generated at 

current production rates for a period of approximately 30 to 50 years of operation. 

Alternatives B through D would also allow for disposal of waste rock currently stored at 

other locations. A detailed description of each alternative is provided below. Under 

alternatives B through D, the development would be incremental with the Forest Service 

approving each step or phase (see Section 1.4) in the process of reaching the full build 

out depicted in the figures (also see Section 2.6.3, Adaptive Management). Appendix E 

presents figures of each alternative at the end of the first 10 years of operation along with 

figures of reclaimed facilities at the end of 50 years of operation. 

 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.3.1 Alternative A: No Action Alternative 

The 2003 Record of Decision (ROD) approved an 

additional disturbance footprint of 65.3 acres, with a total 

tailings lease area of 123 total acres. The 2003 ROD 

authorized 3.3 million cubic yards of new tailings disposal 

capacity increasing the total capacity to 5.3 million cubic 

yards. Under the No Action Alternative, tailings would 

continue to be placed in the approved, existing TDF until 

2019. Tailings would be generated at a rate of 

approximately 360,000 cubic yards per year with 

approximately half (about 180,000 cubic yards per year) 

used as backfill underground. The remaining tailings would continue to be placed in the 

existing TDF along with other wastes and waste rock relocated from “Site E” (see 

Section 2.4.3). No new rock quarries or reclamation material storage areas would be 

developed under Alternative A. Disposing of tailings at current rates and waste rock 

disposal from Site E would result in the approved TDF reaching its capacity in 2019 (see 

Table 2.3-1 and Figure 2.3-1). HGCMC would employ temporary stabilization during 

operations, allowing them to conduct final reclamation using the best technology 

available at the time of final closure. As discussed further in Section 2.4.9 below, it is 

anticipated that drainage from the TDF would require treatment for at least 100 years 

after closure and perhaps in perpetuity. 

Table 2.3-1. Estimated TDF Disturbance for No Action and Action Alternatives (in Acres). 

Project Component b Alternative A b Alternative B b Mitigated 

Alternative B b Alternative C b Alternative D b

Tailings — a 48 43 111 104 

Reclamation Material 

Storage — a 19 13 10 14 

Quarry — a 17 15 8 15 

Ponds — a 12 14 7 7 

Roads, including ditches 

and pipelines — a 30 b 39 b 36 b 43 b

Truck Wheel Wash — a 1 1 1 1 

Water Treatment Plant — a 1 1 1 1 

Total New Disturbance b — a 128 b 126 b 174 b 185 b

Total Disturbance 65 c 181 167 224 245 

New disturbance within the 

Monument 0 100 69 2.3 23.3 

Notes: 

a. Component of the existing disturbance associated with tailings disposal. 

b. Includes 26 acres of existing ancillary disturbance that would be redisturbed under all action alternatives. 

c. Total disturbance following the 2003 ROD. 

Alternative A: No Action 

Alternative – Mining 

activities and tailings 

disposal would continue 

until 2019 when the 

existing permitted TDF will 

reach its tailings capacity. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-5 

Figure 2.3-1. Greens Creek Mine Alternative A. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-6 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.3.2 Alternative B: Proposed Action 

The proposed action includes expansion of the existing 

TDF from its currently permitted capacity of 5.3 million 

cubic yards of tailings and waste rock to a total capacity of 

19.5 million cubic yards of tailings and waste rock, an 

increase in capacity of approximately 14.2 million cubic 

yards. Under this alternative, HGCMC proposed 

construction for the expansion of the existing TDF 

beginning in 2014. Figure 2.3-2 illustrates the facility 

layout at the final stage of expansion. The final TDF 

expansion would extend the life of the mine for 

approximately 30 to 50 years at current production and disposal rates. For purposes of 

this EIS, this timeframe represents a minimum of 30 years from the time the currently 

approved capacity is reached to a maximum of 50 years. The timeline reflects the 

variable nature of production and backfill rate. 

During the southward extension of the existing TDF (years 1–30), contact water from 

disturbed sites would be routed into water management ponds, including new ponds 

down-gradient of the proposed tailings expansion, and then pumped to the existing 

Pond 7 where the water would be treated before being discharged to Hawk Inlet. Interim 

stages of development would require a series of collection ponds that would eventually 

be covered by tailings. As part of expansion proposed during years 31–50, HGCMC 

would construct a new water treatment plant and a new water management pond to 

replace Pond 7 (refer to Figure 2.3-1), although HGCMC plans to maintain the treated 

water discharge point at the same location in Hawk Inlet. 

Maintaining surface water drainage is and would continue to be an ongoing activity that 

would be adapted as needed as the active tailings placement area moved within the TDF 

and as the TDF expanded in size. HGCMC would implement sediment control measures 

to limit tailings erosion. Directing runoff to armored/rocked areas or diversion tubes3

, 

maintaining road ditches and outside slopes, and cleaning ditches as sediment 

accumulates are among the techniques that HGCMC uses and would continue to use to 

control erosion at the site. A new truck wheel wash facility would be constructed at an 

appropriate location to prevent tracking of tailings and waste materials away from the 

TDF. A new West Road would be constructed to the west of the TDF providing access to 

new reclamation material storage areas and rock quarries. New reclamation material 

storage areas would be developed around the existing TDF (see Figure 2.3-2). The 

expansion would occur in stages that would involve the development of a series of 

quarries, reclamation material storage sites, water management ponds, and diversion 

ditches. Table 2.3-1 summarizes the final acreage disturbed associated with development 

of the project. HGCMC would employ temporary stabilization of all ancillary 

disturbances during operations. Final reclamation would be the same as Alternative A, 

but over the larger area disturbed under this alternative. Similar to Alternative A, it is 

anticipated that drainage from the TDF would require treatment for at least 100 years 

after closure and perhaps in perpetuity. 

 

3

 Diversion tubes are flexible, water conveying tubes used for storm water diversion and erosion control. 

Alternative B: Proposed 

Action – The existing TDF 

would be expanded south, 

farther into the Monument 

to accommodate an 

additional 30–50 years of 

tailings disposal. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-7 

Figure 2.3-2. Greens Creek Mine Alternative B Final. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-8 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.3.3 Mitigated Alternative B 

Mitigated Alternative B incorporates mitigation measures, in the form of design 

modifications, developed to address the significant issues as they apply to the proposed 

action. The design modification includes a slight reconfiguring of the TDF and 

relocating some of the proposed facilities (reclamation material storage areas and 

quarries) outside of high-value wetlands, the Tributary Creek drainage, and the 

Monument (Figure 2.3-3). The total expansion would provide the same additional 

disposal capacity as the proposed action, extending the life of the mine an additional 30–

50 years. As with the proposed action, the 30–50 year timeframe reflects the variable 

nature of production and backfill rates. In a change from the Draft EIS, which presented 

the same reconfiguration as mitigation measures that could be applied to the proposed 

action, this reconfiguration is presented as a stand-alone alternative in the Final EIS for 

clarity. 

The TDF reconfiguration would involve extending tailings placement to the northeast of 

the existing facility. Approximately 2 million cubic yards of material would be placed in 

this area with half being placed during the initial expansion phase to serve as a base. The 

second half would be placed during the final stage when the pile is expanded to full 

height. Tailings placement in this area would require the construction of another water 

management pond. 

Expansion of the existing TDF to the south would occur in a similar manner as proposed 

under Alternative B, except to a lesser extent. During the southward extension of the 

existing TDF, contact water from disturbed sites would be routed into water management 

ponds, including new ponds down-gradient of the proposed tailings expansion, then 

pumped to the existing Pond 7 where the water would be treated before being discharged 

to Hawk Inlet. Interim stages of development would require a series of collection ponds 

that would be covered by tailings eventually. As part of expansion proposed during years 

31–50, HGCMC would construct a new water treatment plant and a new water 

management pond to replace Pond 7 (Figure 2.3-3), although HGCMC plans to maintain 

the treated water discharge point at the same location in Hawk Inlet. 

Similar to the proposed action, Mitigated Alternative B includes development a new 

truck wheel wash facility at an appropriate location to prevent tracking of tailings and 

waste materials away from the TDF. The new West Road would be constructed to the 

west of the TDF providing access to new rock quarries (Figure 2.3-3). 

As discussed in Section 2.4.9, it is anticipated that drainage from the TDF will require 

treatment for at least 100 years after closure and perhaps in perpetuity. The reclamation 

material storage areas and one of the quarries currently proposed at the southern end of 

the TDF and inside the Monument would instead be developed to the north of the 

existing TDF. Rather than developing a quarry in the southeastern portion of the 

Tributary Creek drainage, as is currently proposed under Alternative B, the quarry 

immediately north of the existing TDF would be deepened. The overall result of the TDF 

reconfiguration and relocation of associated facilities would be a reduction in the volume 

of tailings placed in the Monument and Tributary Creek drainage as well as a smaller 

overall footprint (see Table 2.3-1 and Figure 2.3-3). 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-9 

Figure 2.3-3. Facility Locations of Mitigation Options under Alternative B. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-10 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

 2.3.4 Alternative C: New TDF Located Outside 

Monument 

Under Alternative C, the capacity of the existing TDF 

would be expanded by 8.1 acres with the capacity to 

store approximately 1 million cubic yards, for a total of 

6.3 million cubic yards, providing disposal capacity for 

an additional 3 years. Under this alternative, a new 

TDF would be developed north of the existing TDF, 

outside of the Monument on Juneau Ranger District 

Forest Service semi-remote recreation land (see figures 

2.3-4a, 2.3-4b, and 2.3-4c). The new TDF would be 

developed to accommodate the remaining 13.2 million 

cubic yards, providing adequate capacity to contain the 

same amount of tailings and waste rock considered 

under the proposed action. The development of the new 

TDF to the north would require 3–5 years for site 

preparation and construction. As with the proposed 

action, the 30-50 year timeframe reflects the variable nature of production and backfill 

rate. 

Expansion of the existing TDF would occur in a similar manner as proposed under 

Alternative B, except to a lesser extent, such that tailings disposal or new ponds and 

reclamation material storage areas would not directly affect Tributary Creek. Alternative 

C would eliminate the West Road proposed under Alternative B. Contact water from 

disturbed sites would be routed into water management ponds, including an expanded 

Pond 9 (see Figure 2.3-4c), and then pumped to the existing Pond 7, from where it would 

be pumped to the water treatment plan for treatment before being discharged to Hawk 

Inlet. An existing reclamation material storage site located near Pond 7 would be 

expanded. The new TDF would be developed in the same manner as the existing TDF, 

including the design and construction and operation of the sub-drains, liner, and tailings 

placement. New finger and blanket drains would be placed to form the facility 

underdrain system. The underdrains would be built on a pad of unreactive material. The 

underlying pad would be graded and the underdrain system designed so that, if the liner 

was compromised, contact water from the new TDF would drain toward Hawk Inlet and 

avoid Fowler Creek, which supports anadromous fish populations. New diversions 

would also be constructed to route non-contact surface water runoff around the facility. 

Non-contact ground and surface waters diverted around the TDF would be routed to their 

original drainage basin, Hawk Inlet or Fowler Creek. 

All drainage and runoff from within the new TDF would be captured and routed to a new 

settling pond before being pumped to the existing water treatment plant and discharged 

through the existing outfall. An above ground pipeline would be constructed following 

the existing road network for approximately 20,000 feet to transport contact water from 

the new TDF to the existing water treatment plant (see figures 2.3-4a and 2.3-4b). This 

would require additional pump stations to transfer the water to the water treatment plant. 

The expansion of the existing TDF and the construction of the new TDF would make use 

of the existing water treatment plant for approximately 30 years, after which a 

replacement to the water treatment plant would be necessary (due to normal operational 

Alternative C: New TDF 

located outside the 

Monument – The existing 

TDF would be expanded to 

accommodate an additional 3 

years of tailings disposal. A 

new TDF would be built to 

the north to accommodate 

additional tailings disposal, 

extending the life of the mine 

an additional 30–50 years. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-11 

lifetime of the water treatment plant).There would be no water treatment plant at the new 

TDF site. 

Construction of the new TDF would also involve developing a reclamation material 

storage area and two new rock quarries, one of which would ultimately be used for 

tailings disposal at the new TDF. Rock from the quarries would be used for the 

construction of internal roads in the new TDF. 

A new truck wheel wash facility and associated water collection system would also be 

constructed at the new TDF to prevent tracking of tailings and waste materials away from 

the TDF. Establishing this truck wash would require HGCMC to obtain a water right to 

use water from Fowler Creek. The A Road would be upgraded to accommodate 

construction traffic and haul truck use (see figures 2.3-4a and 2.3-4 b). Rock used for 

road construction must meet the specification for materials including index and 

geochemical parameters. If geochemically stable rock materials are encountered, these 

may also be used for general site road maintenance outside the TDF. 

Maintaining drainage would be an ongoing activity at both TDF sites. HGCMC would 

implement sediment control measures to limit tailings erosion. Directing runoff to 

armored/rocked areas or diversion tubes, maintaining road ditches and outside slopes, and 

cleaning ditches as sediment accumulates are among the techniques that HGCMC uses to 

control erosion at the site. Because the expansion at the existing TDF would be less than 

under the proposed action, less contact water capacity would be necessary and fewer 

basins and ponds would be built at the existing TDF. 

Alternative C would involve placement of the final cover and revegetation of the existing 

TDF with closure of the final active disposal areas as soon as possible following tailings 

placement (beginning in approximately 3 years). Under this alternative, portions of the 

new TDF would be reclaimed in the interim as conditions allowed, until final reclamation 

occurred. Final reclamation would be conducted at the end of tailings disposal and would 

include covering, revegetation, and ongoing water management. 

Table 2.3-1 summarizes the additional acreage of disturbance associated with the 

development and the final footprint of the project. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-12 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 2.3-4a. Greens Creek Mine Alternative C – Final North Layout. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-13 

Figure 2.3-4b. Greens Creek Mine Alternative C – Final Central Layout. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-14 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 2.3-4c. Greens Creek Mine Alternative C – Final South Layout. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-15 

2.3.5 Alternative D: Modified Proposed Action 

Under Alternative D the capacity of the existing TDF 

would be expanded by 24.2 acres with the capacity to 

hold approximately 3 million cubic yards of tailings 

and waste rock. The expansion would result in an 

overall capacity of 8.3 million cubic yards of tailings 

and waste rock in the existing TDF. Under this 

alternative, a new TDF would also be developed north 

of the existing TDF on Juneau Ranger District Forest 

Service semi-remote recreation land, outside of the 

Monument at approximately the same location as the 

new TDF in Alternative C (see figures 2.3-5a, 2.3-5b, 

and 2.3-5c). The new TDF would be developed to 

accommodate the remaining 11.2 million cubic yards, 

providing adequate capacity to contain the same amount of tailings and waste rock 

considered under the proposed action. As with the proposed action, the 30–50 year 

timeframe reflects the variable nature of production and backfill rate. The expansion of 

the footprint of the existing TDF would occur over the next 10–15 years of operations. 

Tailings placement in the new facility would occur in later years. 

Similar to Alternative C, all drainage and runoff from the new TDF would be captured 

and routed to a new settling pond before being pumped to the existing water treatment 

plant and discharged through the existing outfall. A pipeline would be constructed 

following the existing road network to transport contact water from the new TDF to the 

existing water treatment plant (see figures 2.3-5a and 2.3-5b). 

Expansion of the existing TDF would occur in a similar manner as proposed under 

alternatives B and C, except the extent of disturbance at the existing location would be 

less than Alternative B and greater than Alternative C. Contact water from disturbed 

sites would be routed into water management ponds, including an expanded Pond 9 and a 

new pond south of the TDF (see Figure 2.3-5c). Contact water would then be pumped to 

the existing Pond 7 before it would be treated, and then discharged to Hawk Inlet. The 

existing truck wash would be moved or replaced to make room for tailings placement. 

Alternative D would require developing a new rock quarry north of the existing TDF, and 

expanding one and creating a new reclamation material storage area near the existing 

TDF. 

The new TDF would be developed in the same manner as the existing TDF, including the 

design and implementation, construction, and operation of the sub-drains, liner, and 

tailings placement. The underdrains would be built on a pad of unreactive material 

graded so that, in the absence of active management, contact water from the new TDF 

would drain toward Hawk Inlet and avoid Fowler Creek. New diversions would also be 

required to route non-contact surface water runoff around the facility. Non-contact 

ground and surface waters diverted around the new TDF would be routed to their original 

drainage basin, Hawk Inlet or Fowler Creek. 

 

Alternative D: Modified 

Proposed Action – The existing 

TDF would be expanded to 

accommodate an additional 10 

years of tailings disposal. A 

new TDF would be built to the 

north to accommodate 

additional tailings disposal, 

extending the life of the mine 

an additional 30–50 years.
Chapter 2. Description of Proposed Action and Other Alternatives 

2-16 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 2.3-5a. Greens Creek Mine Alternative D – Final North Layout. 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-17 

Figure 2.3-5b. Greens Creek Mine Alternative D – Final Central Layout. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-18 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 2.3-5c. Greens Creek Mine Alternative D – Final South Layout. 

 
2.3 Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-19 

All drainage and runoff from within the new TDF would be captured and routed to a new 

settling pond before being pumped to the existing water treatment plant and discharged 

through the existing outfall. A water management pond would be constructed adjacent to 

the new TDF and an above ground pipeline would be constructed following 

approximately 20,000 feet the existing road network to transport contact water from the 

new TDF to the existing water treatment plant (see figures 2.3-5a and 2.3-5b). This 

would require additional pump stations to transfer the water to the water treatment plant. 

The expansion of the existing TDF and the construction of the new TDF would make use 

of the existing water treatment plant for approximately 30 years, after which a 

replacement to the water treatment plant would be necessary (due to normal operational 

lifetime of the water treatment plant). As with Alternative C, there would be no water 

treatment plant at the new TDF site. 

Construction of the new TDF would involve developing a reclamation material storage 

area at the new site and a rock quarry in an area that would partially be used for tailings 

disposal in later stages. Rock from the quarry would be used for the constructed internal 

roads in the new TDF. A new truck wheel wash facility and associated water collection 

system would also be constructed at the new TDF. The A Road would be upgraded to 

accommodate construction traffic and haul truck use (see figures 2.3-5a and 2.3-5 b). 

Rock used for road construction must meet the specification for materials including index 

and geochemical parameters. If geochemically stable rock materials are encountered, 

these may also be used for general site road maintenance outside the TDF. 

Maintaining drainage would be an ongoing activity at both TDF sites. HGCMC would 

implement the same sediment control measures to limit tailings erosion as with the other 

alternatives. Because the expansion at the existing TDF would be less than under the 

proposed action, less contact water capacity would be necessary and fewer basins and 

ponds would be required at the existing site. 

Alternative D would involve placement of the final cover and revegetation of the existing 

TDF as soon as possible following tailings placement (beginning in approximately 

10 years). Under this alternative, portions of the new TDF would be reclaimed in the 

interim as conditions allowed, until final reclamation occurs. Final reclamation would be 

conducted at the end of tailings disposal and would include covering, revegetation, and 

ongoing water management. 

Table 2.3-1 summarizes the additional acreage of disturbance associated with the 

development and the final footprint of the project. 

2.3.6 Identification of the Environmentally Preferred 

and Preferred Alternatives 

The Council on Environmental Quality (CEQ) recommends that an environmentally 

preferred alternative be identified during the preparation of the EIS although NEPA 

requires that the environmentally preferred alternative be identified in the ROD. The 

environmentally preferable alternative is the alternative (or alternatives) that has the least 

impact on the physical and biological environment and which best protects, preserves, 

and enhances historic, cultural, and natural resources. Economic, social, technical, and 

agency mission factors are not considered in the identification of this alternative. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-20 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Section 1505.14(e) requires that a preferred alternative is identified in the Draft EIS, if 

one exists, and that a preferred alternative is identified in the Final EIS. The following 

subsections discuss the environmentally preferred and preferred alternatives. 

2.3.6.1 Environmentally Preferred Alternative 

Alternative A (No Action) is the environmentally preferable alternative because it would 

not result in additional impacts to the environment from expansion of the tailings facility. 

Alternative B is the most environmentally preferable of the action alternatives. This 

alternative meets the purpose and need, includes reasonable mitigation to protect 

resources, requires the smallest overall physical disturbance, and results in smallest 

overall disturbance to wetlands. Alternative B would affect fewer acres of productive old 

growth and winter deer range habitat compared to alternatives C and D; however, 

Alternative B would affect more acres of productive old growth compared to Mitigated 

Alternative B (111 acres versus 89 acres respectively). While Alternative B would result 

in the largest increase in disturbance within the Monument and would result in the filling 

of over 4,000 feet of Tributary Creek, a Class I fish stream, it would confine the tailings 

within a single facility and minimize the footprint and infrastructure requirements for 

post-closure long-term water management, including allowing the entire TDF to gravitydrain to a single collection point. Mitigated Alternative B would require pumping of 

contact water from the Cannery Creek drainage as well as from a collection point in the 

Tributary Creek drainage; the additional complexity of additional pumping requirements 

favors Alternative B over the long term. 

2.3.6.2 Forest Service Preferred Alternative 

Alternative B is the preferred alternative because it confines the TDF expansion to the 

Tributary Creek watershed (limiting impacts on Cannery and Fowler Creek watersheds) 

and avoids constructing a second facility and associated operational, maintenance, and 

management requirements. 

2.4 Project Component Details 

2.4.1 Mining Activities 

Underground mining methods are used to remove ore from the mine. The HGCMC 

employs a combination of cut and fill and long-hole mining methods to remove ore and 

waste rock. Cut and fill is the primary mining method used to extract the ore. Long-hole 

stoping is also used in select ore zones conducive to this bulk mining method. As part of 

the mining process waste rock and tailings are backfilled into some of the voids created 

by the mining process to provide structural stability within the mined out areas. The 

waste rock brought to the surface is placed into a disposal facility (Site 23), or, based on 

need, used in the TDF to build roads that serve as the working surface for tailings 

placement. No changes to the mining process are being considered in this analysis. 

Alternatives focus on tailings disposal. Mining activities are guided by the GPO. 

2.4.2 Ore Concentrate Milling 

Ore is removed from the mine and placed in stockpiles near the mill building at a rate of 

approximately 2,200 tons per day. Ore is fed into the mill where it is ground in a 
2.4 Project Component Details 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-21 

semiautogenous grinding mill and ball mill with water to create a slurry. A portion of the 

gold and silver are recovered through gravity concentration. The slurry is then pumped 

into a series of tanks that are used to separate the valuable metals-bearing materials 

(concentrate) from the non-valuable waste product (tailings). Then reagents are added to 

cause minerals of interest to attach to air bubbles, allowing them to be floated into and 

recovered from a froth in a series of flotation cells. The concentrates and tailings are then 

filter pressed to create moisture levels acceptable for transport. No changes to the 

mineral processing are being considered in this analysis. Concentrate is trucked to the 

port facility and shipped to smelters; tailings are either trucked to the TDF or used to 

make backfill and used underground to fill voids from mining, which provides ground 

support. 

2.4.3 Waste Disposal 

Waste material consists mainly of tailings and waste rock. As noted above, tailings and 

waste rock may be either placed back underground or disposed of on the surface. 

Tailings brought to the surface for disposal may only be placed in the TDF. Waste rock 

disposed of above ground is primarily placed at the approved disposal facility (Site 23) or 

used in the TDF for erosion control or to build roads that serve as the working surface for 

tailings placement. Table 2.4-1 depicts typical disposal options for waste generated at the 

mine. HGCMC will be responsible for developing and applying measures consistent 

with recently issued National Core Best Management Practices (BMPs) (USFS 2012) to 

avoid, minimize or mitigate adverse effects to soil, water quality and riparian resources 

from the storage and disposal of mine waste. 

Table 2.4-1. Waste Disposal at Greens Creek Mine a. 

Waste Underground TDF Site 23 Off Site

Tailings b X X 

Waste Rock X X c X 

Relocated Site E Waste Rock d X 

Hazardous Materials X 

Other Materials 

Pressed sludge from sewage and water treatment e X 

Incinerator Ash f X 

Sediments removed from settling ponds, ditches, and basins X 

Tires and miscellaneous refuse g X 

Notes: 

a. Per Waste Management Permit and GPO. 

b. Approximately half of tailings generated are backfilled underground. 

c. Waste rock is permitted in the TDF for co-disposal. 

d. Co-disposal of waste rock was authorized by the Forest Service and State of Alaska in 2009. 

Annually, about 40,000 cubic yards of waste rock from Site E is moved to the TDF (based on 2009 and 

2010 records). 

e. Respectively, about 50 and 500 cubic yards of sewage and water treatment plant sludge are disposed 

of at the TDF annually. 

f. About 16 cubic yards of incinerator ash is disposed of at the TDF annually. 

g. About 5,350 cubic yards of tires and other refuse were disposed of underground in 2010, in 

accordance with the Waste Management Permit. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-22 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.4.3.1 Tailings 

Tailings are the non-valuable waste product of mineral processing. Approximately half 

of the tailings generated are backfilled into underground voids created by the mining 

process. The remainder of the tailings (about 180,000 cubic yards annually) are filtered 

and then transported by covered haul truck to the TDF for permanent disposal. Tailings 

are placed into the TDF as a series of 1-foot layers (lifts) within discrete disposal 

locations (cells) to provide for control over compaction, drainage, and pore-pressure 

dissipation. As part of site reclamation, an engineered soil cover will be placed over the 

TDF; this is discussed further in sections 2.4.9.2 and 2.4.9.3. 

The construction design for the existing TDF is similar to that used for a landfill. Much 

of the TDF is underlain by naturally occurring low permeability materials or a liner 

system designed to prevent groundwater from flowing into the facility as well as water 

leaching from the facility into the local groundwater system. Prior to placement of the 

liner system, peat and other unsuitable foundation materials are stripped from the site. 

Clean surface waters are diverted around the TDF. 

2.4.3.2 Waste Rock 

Waste rock is rock that has metals concentrations 

below those that can be economically processed. 

Waste rock must be removed from the mine to gain 

access to the ore material. Waste rock excavated 

during underground operations is either directly 

backfilled underground into areas that have been 

mined out or hauled from the mine to the surface and 

stockpiled. 

Waste rock hauled to the surface from ongoing 

operations is permitted to be permanently placed at 

Site 23 or the TDF. From 2008 through 2010, an 

average of about 17,000 cubic yards of waste rock 

was placed at Site 23 annually, ranging from about 

12,000 cubic yards in 2010 to 24,400 cubic yards in 

2008. Waste rock is also placed at the TDF for use 

as erosion control and internal road material. These 

roads are known as “dirty roads” and are needed to 

prevent rutting of tailings material, especially during 

wet weather (The roads discussed in Section 2.4.8 are 

considered “clean roads.”). HGCMC is authorized to 

co-dispose waste rock with tailings at the TDF. 

2.4.3.3 Co-Disposal (Tailings and Waste Rock) 

Co-disposal refers to the placement of a mixture of waste rock and tailings within the 

TDF. The primary purpose of co-disposal is to allow potentially acid-generating material 

at Site E to be moved to the TDF for permanent disposal. Co-disposal would reduce the 

rates of pyrite oxidation and metal leaching from waste rock by surrounding it with the 

tailings. The tailings provide a fine-grained bedding material which reduces the amount 

Waste Rock Classification – 

HGCMC classifies waste rock 

based on its geochemical 

reactivity. The material most 

subject to acid formation and 

metals leaching is placed back 

into mined out areas (voids) 

within the mine without being 

brought to the surface. Less 

reactive material is disposed of 

on the surface. For operational 

production rock management, 

visual classification based on 

geology and periodic sampling 

and analysis are performed. 
2.4 Project Component Details 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-23 

of waste rock surface area exposed to oxygen. The benefit of co-disposal of waste rock 

with tailings at the TDF include: 

 Lowering oxidation rates in the waste rock and extending its acid neutralization 

capacity; 

 Improving pore water chemistry relative to that of tailings and waste rock disposed of 

separately; 

 Improved drainage quality at sites where waste rock is removed; and 

 Consolidation of waste sites reduces the overall number of sites needing engineered 

covers at closure. 

HGCMC is authorized to place waste rock from the mine in Site 23 and to co-dispose of 

the waste rock with tailings at the TDF. Sources of waste rock for co-disposal include (or 

could include) rock used for erosion control and internal roads. Waste rock from inactive 

or active waste rock disposal sites and from the mine may also be moved to the TDF as 

part of co-disposal. Between 2009 and 2010, about 54,000 cubic yards of waste rock 

were co-disposed of at the TDF annually. 

2.4.3.4 Other Wastes 

Other non-hazardous wastes that must be managed include sludge generated in the 

wastewater treatment process and ash generated in the process of incinerating wastes 

such as paper and food wastes. Sediments removed from settling ponds, ditches, and 

basins may also be placed into the TDF. All these materials are placed into the TDF 

under a waste management permit issued by the Alaska Department of Environmental 

Conservation (ADEC). Hazardous wastes are collected and shipped off site to an 

approved facility. 

2.4.4 Water Management 

All water coming in contact with mine-related activities must be controlled and 

discharged under the mine’s APDES permit (see Section 1.8.3.4). The flow of water is 

controlled using a series of ditches located around all the facilities. Collection ditches 

gather water that has come in contact with mining operations and direct it to ponds or 

sumps where it can be pumped to the appropriate locations for treatment. Diversion 

ditches around the outside of facilities and disturbances are used to divert clean water 

away from facilities to minimize the amount of “contact” water. Water from the 

diversion ditches is directed into the adjacent landscape. Collection and diversion ditches 

are included as components of all alternatives. 

Wastewater treatment is currently accomplished in one of two wastewater treatment 

plants (WWTPs) located on the site. The WWTP at the mill treats water used in the 

milling process, mine water, and contact water collected in the immediate vicinity of the 

mill. Water discharged from this treatment plant can be directed back to the mill for reuse or to Pond 7, which collects water from the TDF. A second WWTP located at Pond 7 

treats all runoff from the TDF and any other water directed to Pond 7; the plant 

discharges to Outfall 002 located in the marine waters of Hawk Inlet. 

The APDES permit establishes a series of conditions that apply to both storm water and 

mine water at defined outfalls, including Outfall 002. Storm water outfalls are located at 

a number of locations throughout the facility. Collected process wastewaters are treated 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-24 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

at the Pond 7 WWTP to meet effluent limits identified in the APDES permit prior to 

discharge through a diffuser outfall located in Hawk Inlet. The Pond 7 process 

wastewater includes runoff and seepage from the TDF and runoff from mine facility 

areas. These waters are collected by a series of wastewater management ponds. Seepage 

through the TDF flows to the TDF underdrain collection system and is collected by a 

series of wells at the base of the TDF. A conceptual drawing of the TDF and contact 

water collection system is provided in Figure 2.4-1 in Section 2.4.9.3. 

At permanent cessation of mining operations, seepage from the TDF would continue to 

be treated and an APDES discharge permit would be required for at least 100 years after 

closure and perhaps in perpetuity. After mining is completed, it is expected that seepage 

from the TDF will not meet Alaska Water Quality Standards (WQS) and therefore water 

treatment will be needed in order to meet WQS. However, surface water runoff from the 

engineered final cover would not require treatment and the collection ponds would be 

reclaimed and runoff would be allowed to go to natural drainages. A more detailed 

discussion of the APDES permitting requirements and treatment needs is provided in 

Section 3.5. 

The wastewater discharge outfall location and permit requirements would be the same for 

all of the alternatives. The location of ponds, ditches, and storm water outfalls would 

change over time and could occur in different locations under each of the alternatives. 

The WWTP at the existing TDF may need to be relocated at some point in the future 

depending on the alternative. 

Storm water controls include diversion ditches, culverts, storm water detention basins, 

and storm water collection ponds. Runoff from undisturbed areas is and would continue 

to be routed around disturbed areas through ditches and culverts. The Forest Service 

recently issued National Core BMPs (USFS 2012). HGCMC will be responsible for 

applying the most up-to-date BMP guidance in their operations. 

2.4.5 Rock Quarries 

Approximately 20,000 to 30,000 cubic yards of 

rock material are required annually for the 

internal roads at the TDF. Several bedrock areas 

associated with each of the proposed TDF 

expansion areas have been identified as possible 

rock quarries (see figures 2.3-2, 2.3-4a, 2.3-5a, 

and 2.3-5c). These quarries would serve as rock 

sources for the internal TDF roads. Given the 

potential for acid generation, none of this rock 

material would be used external to the TDF. 

Spur roads, constructed of imported, non-acid 

forming material, would connect the rock 

quarries to the A Road, B Road, or West Road 

(see Section 2.4-8 and Figure 2.3-2 for West 

Road information) depending on alternative and 

stage of development. 

Rock Quarries – Rock is quarried on 

site to develop internal roads within 

the TDF. Local quarry rock may 

contain pyrite, which can weather to 

produce acid rock drainage (ARD). 

Given the potential for acid 

generation, none of this rock material 

would be used external to the TDF, 

unless the on-island rock source is 

determined to have a geochemically 

stable matrix and is found to be nonacid generating. External roads 

connecting facilities are generally built 

with imported rock. 
2.4 Project Component Details 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-25 

Materials for the clean roads are generally imported to the site from off-site quarries. 

These materials are tested for leachability and acid-generating capacity according to 

HGCMC’s Production Rock Environmental Characterization Standard Operating 

Procedures prior to their placement. The volume of clean materials imported to the site is 

approximately 16,000 cubic yards on an annual basis. 

HGCMC will be responsible for developing and applying measures consistent with 

recently issued National Core BMPs (USFS 2012) to avoid, minimize or mitigate adverse 

effects to soil, water quality and riparian resources when developing or using mineral 

materials resource sites (rock quarries). 

2.4.6 Reclamation Materials Stockpiles 

Biologically active topsoil, organic material, and other materials suitable as growth media 

would be removed prior to preparing foundations for the TDF(s) and any support 

facilities and stockpiled for later use in reclamation. Growth media would be stored 

separately from other vegetative slash or soil and rock materials; it would be protected 

from wind and water erosion, unnecessary compaction and contaminants. In order to 

reduce the potential for fugitive dust, erosion and spread of noxious weeds, the stockpiles 

would be hydroseeded once all material was deposited in the pile. Measures for 

controlling spread of noxious weeds are included in Table 2.6-1 in Section 2.6.2.1. 

Growth media stockpiles would be eliminated during the final reclamation process when 

the materials would be spread across disturbed areas as detailed in the reclamation plan 

(also see Section 2.4.9, Reclamation and Closure).

2.4.7 Truck Wheel Wash Facility 

All vehicles that travel on the TDF are and would continue to be required to pass through 

a truck wheel wash facility prior to exiting the TDF. The truck wheel wash facility 

reduces tracking of tailings material onto the clean roads.

2.4.8 Support and Service Roads 

Under all alternatives, the existing B Road would 

be maintained and continue to be the connection 

from the 920 portal (mine and mill) to the marine 

terminal area at Hawk Inlet. This road would 

continue to serve as the route for the transport of 

tailings and waste rock material from the mill and 

mine respectively to the TDF. A small portion of 

the B Road immediately east of the tailings 

expansion would be relocated to accommodate 

tailings placement under alternatives B and D. 

Under the proposed action, the West Road would be 

constructed on the west side of the TDF and would 

serve as access to future rock quarries, reclamation 

material storage areas, water management ponds, 

and the existing and future water treatment plant 

New Roads and Upgrades – 

Alternative B requires relocating 

the existing B Road to 

accommodate the TDF 

expansion. A new West Road 

would be built to access future 

TDF facilities.

Similar roads and upgrades 

would be needed for 

alternatives C and D; additionally 

the A Road would be upgraded 

up to the new TDF.
Chapter 2. Description of Proposed Action and Other Alternatives 

2-26 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

(see Figure 2.3-2). This external road would connect to the Hawk Inlet marine terminal 

facility and would be used primarily for light vehicle traffic and for trucks hauling 

reclamation storage material or internal quarry rock. The West Road would be of similar 

design as the existing B Road. This road would be about 1.5 miles long and would cross 

two fish bearing streams (Tributary and Cannery creeks). In addition, perimeter service 

roads would be maintained and installed at the toe of the expanded TDF. These roads 

would be the same as currently exist, that is, single-lane (minimum top width of 19 feet) 

all-weather roads, constructed on prepared foundations and surfaced with crushed rock 

and or gravel obtained from suitable (i.e., non-reactive) sources. Similar roads would be 

built under alternatives C and D surrounding the expanded existing TDF as well as the 

new TDF to the north. External roads connecting facilities are generally built with 

imported rock, though local (on-island) rock may be used if it is determined to have a 

geochemically stable matrix and is found to be non-acid generating. 

Safety berms or barriers (guard rails) would be added as appropriate to all roads to 

comply with the safety requirements of the Mine Safety and Health Administration 

(MSHA). 

Roads on the TDFs themselves (dirty roads) would be constructed internal to the TDF as 

discussed in Section 2.4.3.1, Tailings. These roads would be constructed of waste rock, 

quarry rock, or off-island rock. 

Under alternatives C and D, the A Road would be upgraded from its junction with the B 

Road to the new TDF site, approximately 3 miles. Upgrades to the A Road would be 

needed to accommodate TDF construction activities and use by haul trucks as well as the 

installation of a wastewater pipeline from the facility back to the existing WWTP. Under 

Alternative C, a short segment of new road would also be needed to access the new rock 

quarry near the north TDF. These new and upgraded roads are shown in figures 2.3-4a, 

2.3-4b, and 2.3-4c and figures 2.3-5a, 2.3-5b, and 2.3-5c. Additionally, Alternative D 

includes a new road that would be constructed from a new quarry just north of the 

existing TDF to the Hawk Inlet marine terminal (Figure 2.3-5c). This is similar to the 

West Road under the proposed action; however it is shorter in length and would not go 

around the expanded TDF under Alternative D. 

Currently tailings are transported from the mill to the TDF in 45-ton capacity covered 

tractor/trailer trucks. Approximately 20 to 40 round trips (15.6 miles for each round trip) 

from the mill to the TDF are made daily, delivering an average of 1,000 tons to the TDF. 

Round trip travel time for each truck is approximately one hour. Tailings transport is 

usually conducted during the day shift with two to four trucks in use at any given time. 

HGCMC will be responsible for developing and applying measures consistent with 

recently issued National Core BMPs (USFS 2012) to avoid, minimize or mitigate adverse 

effects to soil, water quality and riparian resources that may result from road management 

activities, including design, construction, operation, maintenance and reconstruction. 

Other road related activities include stream and waterbody crossings, snow removal, 

parking areas and equipment refueling and servicing areas. 

 
2.4 Project Component Details 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-27 

2.4.9 Reclamation and Closure 

Reclamation and closure techniques would be the same 

for all the alternatives. This section describes interim and 

final reclamation and closure planned for the TDF and 

TDF expansion. Reclamation growth medium material 

(consisting of soil and peat) would be removed from the 

areas disturbed by enlargement or construction of any of 

the TDF structures and placed into stockpiles. This 

material would be used for reclamation and site closure. 

Stockpiles would be protected from erosion; the existing 

mitigation measures to prevent erosion of the TDF and 

stockpiles include hydroseeding, the installation of wind breaks, surface water diversions, 

and armoring of slopes with rip-rap when necessary. 

The current land use at and surrounding the existing TDF is primarily for fish and 

wildlife habitat. The overall purpose of reclamation is to stabilize disturbed areas and 

return them to vegetated conditions to ensure long-term protection of land and water 

resources in the area and to obtain near-natural conditions. 

HGCMC’s current reclamation objectives include the following: 

 Reclaim disturbed areas as soon as practical after disturbance; 

 Minimize disturbance by maintaining a small footprint; 

 Complete final reclamation upon permanent cessation of operations; 

 Return the disturbed areas to near-natural conditions to the extent practical; 

 Ensure long-term stability; 

 Protect water quality; 

 Protect employee and public health and safety; 

 Minimize or eliminate the need for long-term active management; 

 Reclaim for land uses consistent with Monument resources and the Forest Plan; and 

 Ensure reclamation is consistent with the approvals and permits from the Forest 

Service, ADEC, Alaska Department of Natural Resources (ADNR), Alaska 

Department of Fish and Game (ADF&G), U.S. Army Corps of Engineers (USACE), 

and other regulatory agencies. 

Reclamation practices and technology are ever evolving and improving. Although 

HGCMC already has an approved reclamation and closure plan, HGCMC will be 

required to regularly update the reclamation plan to take advantage of future 

improvements in reclamation technologies and implement improved reclamation 

measures. All updates will be consistent with Forest Service National Core BMPs (USFS 

2012) to avoid, minimize or mitigate long-term adverse effects to soil, water quality and 

riparian resources. 

In GPO Appendix 14, Reclamation Plan (included in part as Appendix F here), HGCMC 

identified the following four stages of reclamation that are applicable to the tailings 

facility expansion:

 Interim reclamation; 

 Temporary cessation; 

Reclamation and Closure – 

The overall goal of 

reclamation is to stabilize 

disturbed areas and return 

the site to vegetated 

conditions for long-term 

protection of surrounding 

land and water resources.
Chapter 2. Description of Proposed Action and Other Alternatives 

2-28 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

 Concurrent and final reclamation; and 

 Post-closure care and maintenance. 

HGCMC is in the process of updating its current reclamation plan. After an alternative 

has been selected for implementation and a ROD or decision is issued by the applicable 

agencies, HGCMC will be required to revise its reclamation plan and financial assurance 

cost estimate based on the selected alternative and submit these revisions to the agencies. 

Agency staff will review the revised reclamation plan and cost estimate to ensure that the 

reclamation and closure requirements of each agency are met. The Forest Service 

requires submittal of a bond for reclaiming disturbances before approval of a plan of 

operations and implementation of the action. See Appendix C for additional information. 

2.4.9.1 Interim Reclamation 

Interim reclamation includes actions taken to stabilize areas that have been disturbed by 

mine operations. The objectives of interim reclamation include: 

1. Reduce erosion and sedimentation of waterways; 

2. Protect water quality; 

3. Maintain geotechnical stability; and 

4. Reduce fugitive dust. 

Interim reclamation at the site currently includes placement of growth medium, 

hydroseeding, as well as the construction of berms, slope drains, slope armoring, rock 

check dams, silt fences, jute mats, detention basins, and water management ponds. Under 

all alternatives, interim reclamation of the TDF(s) would continue to occur throughout 

their operational life prior to final reclamation which would be initiated upon permanent 

cessation of tailings disposal. 

Facility-wide interim reclamation measures are reported annually to the agencies. For 

example, potentially reactive berm material (pyritic rock) associated with an inactive 

waste site was removed and replaced with clean fill in 2010 and waste rock relocation to 

contained facilities is ongoing. Additional opportunities for interim reclamation are 

identified on an ongoing basis. 

2.4.9.2 Final Reclamation 

HGCMC conducts “concurrent” on disturbances and facilities that will not be disturbed 

again during the life of operation. Concurrent reclamation involves the same objectives 

and procedures as “final” reclamation although on a more limited scale. At the time of 

permanent cessation of project activities, HGCMC would implement final reclamation on 

the TDF(s) and associated infrastructure that would involve a number of steps: 

 Decommissioning and removal of unnecessary structures and facilities (water 

treatment facilities and electric power utility lines would remain); 

 Establishing surface contours conducive to natural revegetation or consistent with an 

alternate post-mining land use(s); 

 Reclamation within the Monument will be to as near a natural condition as 

practicable. This would include restoring original surface drainage, removal of all 

structures, and re-contouring where possible; 

 Placement of an engineered soil cover over TDF(s); 
2.4 Project Component Details 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-29 

 Implementation, maintenance and monitoring of reclamation; 

 Revegetation of all disturbed areas; and 

 Maintaining wastewater management and treatment as required by permits. 

The TDF final contours may be formed to establish natural drainage patterns, with the 

objective of long-term stability and environmental performance of the covers. Reclaimed 

facilities would be maintained in a free-draining condition, allowing water to shed from 

the facility without ponding or causing erosion, to the extent practical.

At permanent cessation of mining operations, seepage from the TDF would continue to 

be treated and an APDES discharge permit would be required for at least 100 years after 

closure and perhaps in perpetuity; as long as the TDF seepage does not meet Alaska 

WQS. During permit review and reissuance cycles, depending on the actual effluent 

quality, tailings seepage would continue to be treated and discharged to Hawk Inlet 

(where it would need to meet marine WQS) or to a surface water stream (where it would 

need to meet fresh WQS). 

HGCMC has submitted revisions to its approved reclamation and closure plan to the 

Forest Service and the State of Alaska. HGCMC assumes that a substantial amount of 

site-specific reclamation experience and performance data would be available at final 

closure. Prior to implementing final reclamation, HGCMC will submit a detailed 

reclamation plan to the Forest Service and State of Alaska that would incorporate decades 

of monitoring results and the most up to date site-specific information. The Forest 

Service and the State or Alaska will decide whether to approve the reclamation and 

closure plan revisions. It is expected that additional revisions will be made to the 

reclamation and closure plan in the future to take into account performance data based on 

interim site-specific reclamation experience and to take into account future advances in 

reclamation and closure technology. The current reclamation and closure plan is 

included in Appendix F. 

As stated above, HGCMC will be required to update its reclamation plan and associated 

financial assurances to reflect the alternative selected based on this EIS.

2.4.9.3 Engineered Tailings Soil Cover 

As required by the 2003 ROD, HGCMC would place an 

engineered four-layer soil cover over the TDF to 

minimize the amount of air and water that might enter 

the tailings after permanent closure. Minimizing the 

amount of water and air entering the tailings would 

control the rate at which acid rock drainage (ARD) can 

form within the tailings (discussed in sections 3.4 and 

3.5). This cover design would be the same for all 

alternatives. The performance of the engineered fourlayer soil test cover at Site 23 (waste rock disposal site 

near the 920 portal) has been monitored since 2000 and 

data from the program will be incorporated into the final cover design at mine closure. 

The components and characteristics of the proposed engineered four-layer soil cover over 

the tailings are as follows: 

Tailings Cover – Upon 

closure of the mine, the 

tailings pile will be covered 

with an engineered four-layer 

soil cover, to minimize air and 

water exposure to the tailings 

and reduce the potential for 

acid drainage.
Chapter 2. Description of Proposed Action and Other Alternatives 

2-30 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Lower Capillary Break: The first layer directly on top of the tailings material would 

consist of drain rock. Capillary breaks are created by layers of rock through which water 

can drain from the layers above. The small gaps between the rocks also keep water 

within the tailings from wicking up through the cover by capillary action. This layer 

would function as a lower capillary break to drain seepage from above layers and to 

remove water that might wick up through the tailings. The rock used for this layer would 

be mine waste rock, quarry rock, or rock imported to the site from an off-island source. 

Compacted (Barrier) Layer: The second layer would be composed of a clay soil. This 

layer would be a compacted, low permeability barrier layer that would minimize water 

and oxygen infiltration into the tailings pile. This layer is designed to stay 85 percent 

saturated to minimize air and water infiltration. 

Upper Capillary Break: The third layer would consist of another layer of drain rock. 

The layer would function as an upper capillary break in a similar fashion as the lower 

capillary break and drain seepage from the growth layer. 

Growth Layer: The fourth or top layer would be composed of reclamation growth 

material. This material would support vegetation, as well as provide a small amount of 

recharge water to the underlying compacted (barrier) layer to maintain saturation. This 

material would support the forest vegetation, such as western hemlock and Sitka spruce 

that would be allowed to naturally regenerate on the reclaimed tailings. According to 

HGCMC’s Proposed TDF Expansion Stage 3 (Hecla 2011), the plant growth layer would 

be between 24 and 36 inches. Figure 2.4-1 shows the engineered soil cover. 

Figure 2.4-1. Conceptual Drawing of TDF at Closure with Typical 4 Layer Engineered 

Cover for Reclamation Placed on a 3:1 Slope. 
2.5 Alternatives Considered but 

Not Carried Forward 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-31 

Runoff and drainage water from the upper capillary break layer from the surface cap 

would not be a regulated discharge since these waters would not be allowed to comingle 

with the tailings contact waters. Once the vegetation on the surface cap matures, these 

waters would be allowed to flow to surface water or infiltrate to groundwater. A detailed 

discussion of the management of tailings contact water and non-contact waters after 

closure is provided in Section 3.5.3.1. 

2.4.9.4 Site Revegetation 

Disturbed areas would be reclaimed to one of three vegetation types including upland 

meadows, upland forest, or wetlands. Specific seed mixtures, woody seedling density, 

and maps showing each vegetation type would be part of a detailed reclamation plan 

submitted to the Forest Service prior to closure. Measures to reduce or prevent the spread 

of noxious weeds would be included in the detailed reclamation plan. 

Acknowledging that the Greens Creek Mine is located in the temperate coastal rain 

forests of southeast Alaska, where forest vegetation regenerates quickly and profusely, 

HGCMC plans to allow natural regeneration to be the primary method of forest revegetation (GPO Appendix 14, Reclamation Plan). 

2.5 Alternatives Considered but 

Not Carried Forward _________________________ 

Expansion of the capacity to dispose of tailings and waste rock are the focus of this EIS. 

Since the Greens Creek Mine is already in operation, a number of aspects of the mining 

process, including mining methods, processing technologies, production levels, and 

power supply were not addressed as they are already authorized and currently in place. 

Alternatives suggested in comments on the Draft EIS included removing pyrite from the 

tailings and flow augmentation as a method to “treat” water. Pyrite removal would not 

address the pyrite already present within the TDF and after being assessed in the 2003 

EIS and again for this action, has been deemed impracticable (see Appendix D, 

Alternatives Development). While water quality was identified as a significant issue, the 

Greens Creek Mine discharges treated wastewater under a permit issued by the U.S. 

Environmental Protection Agency (USEPA) and certified by ADEC. That permit is 

currently under reissuance by ADEC in an action independent from the tailings disposal 

expansion. “Off-inlet treatment” similar to technology used at the Pogo Mine was 

suggested in the Draft EIS comments. This method, known as flow augmentation, is not 

a treatment technology but rather a method that could be used to dilute the effluent prior 

to discharge. The Forest Service has no authority over the permit reissuance process and 

cannot compel the USEPA or ADEC to require particular treatment technologies or 

dilution methods. Since the discharge is and will continue to be permitted by agencies 

with authority for Clean Water Act (CWA) compliance, the Forest Service considers the 

discharge to be protective of water quality for purposes of this analysis (36 CFR 

228.8(h)). As such, this EIS does not consider alternative treatment or discharge 

scenarios. 

However, in developing the alternatives evaluated in detail, a number of other 

alternatives were considered but ultimately not selected to be carried forward. The 

following subsection describes the rationale for developing these alternatives along with 

the reasoning for not carrying them forward. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-32 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.5.1 Alternative Facility Locations 

Alternative locations for tailings disposal were suggested directly (ship tailings off 

Admiralty Island) and indirectly (concerns about tailings in the Monument) in scoping 

comments. Shipping tailings off site would involve moving the tailings to the existing 

load-out facility, loading them onto a ship, transporting them to a different location, offloading them, and then placing them in a facility with a similar design to the existing 

TDF. This approach would not eliminate environmental impact since the existing tailings 

would remain in place and would create similar impacts in another location. The process 

would also increase the potential for spills to the marine environment as a result of the 

additional handling that would be necessary for transportation. These factors would 

present a challenge to developing an off-site disposal location but ultimately, the cost of 

shipping tailings would make such an alternative prohibitively expensive. The current 

cost to dispose of tailings is approximately $4.50/ton. If tailings were to be shipped 

offsite, the costs of site preparation, trucking, stacking and grading the tailings would 

remain. In addition, the operator would need to pay shipping and handling costs. 

HGCMC uses a cost of $68/ton to project costs for shipping and handling concentrate. 

Since tailings are of a similar consistency to concentrates, it is reasonable to assume 

shipping costs would be of a similar magnitude. If the costs to ship tailings to a facility 

were 25 percent of the cost of shipping concentrate overseas, the costs of shipping and 

dry-stacking tailings would be approximately $17/metric ton. Because shipping the 

tailings would increase costs for tailings disposal roughly four-fold, an off-site alternative 

was not considered practicable and not carried forward for consideration in detail. 

Alternative on-site facility locations were the focus of an interagency meeting in Juneau 

shortly after the close of the scoping process. In this case, the Forest Service hosted a 

meeting of the cooperating agencies to discuss alternative locations for a TDF that would 

be located outside the Monument. Locations within the Monument were eliminated from 

consideration because of the significant issues (minimize effects to Monument 

resources). Screening criteria were developed to provide an initial focus on other 

potential locations for tailings disposal and included slope steepness, presence of 

wetlands, and drainages supporting anadromous streams. Hillsides having a slope greater 

than 30 percent were eliminated from consideration for a tailings facility because of 

geotechnical stability concerns. The CWA requires that impacts to wetlands and other 

waters of the United States be avoided or minimized. Further, wetlands and drainages 

supporting anadromous fish were identified as significant issues in the scoping process, 

providing additional reason for avoidance or minimization. 

The Forest Service and cooperating agency team, including biologists, engineers, and 

regulators, used a map that highlighted these areas in an effort to identify suitable 

alternative locations. The topography of the area presented particular challenges in 

identifying suitable sites since most areas that did not exceed the maximum slope 

restrictions were wetlands. During the alternative development process, no suitable 

alternative locations were found that completely avoided wetlands or fish bearing 

streams. 

The interagency working group eliminated a number of sites from further consideration 

because of their location within the Fowler Creek drainage. Fowler Creek is a substantial 

watershed that feeds into Young Bay and supports a large anadromous fish population. 
2.5 Alternatives Considered but 

Not Carried Forward 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-33 

One location was eliminated because of the difficulties in managing storm water running 

onto the site since the site straddled the Fowler Creek drainage as well as a number of 

small, unnamed drainages that eventually discharge to Hawk Inlet. The facility location 

identified for alternatives C and D reflects a compromise where (1) the portion of 

drainage within the Fowler Creek drainage could be redirected to the unnamed stream 

draining to the head of Hawk Inlet (minimizing potential long-term effects on an 

anadromous stream); and (2) the facility could be constructed maximizing the amount of 

upland use for the design while minimizing impacts to wetlands and anadromous streams. 

2.5.2 Alternative Facility Designs 

Disposal of tailings in a slurry form within a tailings impoundment was evaluated in the 

original EIS finalized in 1989. The technology exists for this approach to tailings 

disposal although placement opportunities for an impoundment are limited. In addition, a 

tailings impoundment would result in greater land disturbance and higher volumes of 

water to be managed in comparison to dry-stack technology. Therefore, construction of a 

tailings impoundment was not carried forward for detailed analysis. 

Alternate TDF designs were also considered. Placement of a narrowed and elongated 

TDF expansion west of the design described under the proposed action could potentially 

reduce the extent of wetland impacts to Tributary Creek wetlands. This type of design 

was put forth in the early phases of alternative development. In order to sufficiently shift 

the TDF to the west out of emergent and scrub-shrub wetlands, a buttress would need to 

be constructed to ensure stability of the western slope of the tailings pile. While 

technically feasible, the design would involve the placement of substantial volumes of 

clean fill (approximately 3.6 million cubic yards) to form a buttress along the slope that 

leads to Hawk Inlet. Because of the reactive chemical behavior of most of the rock on 

Admiralty Island, this fill would have to be shipped to the site by barge. Construction of 

such a buttress would represent substantial costs to the operation. Contributing to the 

cost factor would be the necessity to construct a new water treatment plant in the 

immediate future since the staging of this design would require placing tailings into the 

area currently occupied by the water treatment plant in the immediate (less than 10 years) 

future, well before its planned service life. In order to develop this design cost 

effectively, growth material stockpiles would have needed to be placed into wetlands 

similarly to the proposed action. Ultimately, the costs and logistical complexity of this 

approach, combined with the wetlands impacts within the Tributary Creek drainage and 

its presence within the Monument resulted in this alternative being eliminated from 

further consideration. 

2.5.3 Reduction of the Pyrite Concentration in the 

Tailings 

The 2003 EIS identified the reduction of pyrite concentrations within the tailings as an 

alternative considered but not carried forward. The potential for changes in technology 

since that time warranted a reevaluation of the 2003 conclusion for this analysis. 

The alternative would consist of employing an additional flotation circuit to remove most 

of the pyrite from the tailings. Pyrite separated from the tailings would require special 

handling prior to disposal in either specially prepared cells within the TDF or being 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-34 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

backfilled into the mine. Existing flotation circuits in the mill could not be used for 

pyrite flotation without reducing the production rates of lead and zinc concentrates. For 

this reason, a separate pyrite plant would need to be constructed adjoining the existing 

mill at the 920 mine site. The pyrite concentration process uses sulfuric acid which 

would require an additional sulfuric acid storage area. A pyrite concentrate storage 

facility would also need to be built in order to coordinate disposal to either surface or 

underground operations. 

The 2003 EIS estimated that the pyrite plant would require approximately 1 acre. That 

analysis also estimated a sulfuric acid storage and handling facility could require an 

additional 0.5 acres and a concentrate handling and temporary storage facility could 

occupy an additional acre. All three facilities would need to be located in the mill site 

which is a highly congested area with steep topography. The feasibility of locating these 

facilities in this area is low. 

The storage of sulfuric acid would greatly add to the inventory of hazardous materials at 

the mine, and would require a high level of spill prevention and pollution controls. There 

would also be increased risk of hazardous material spills during shipping, both by barge 

to the mine and by truck to the mill. Spills could directly and severely impact water 

quality, aquatic life, and Monument resources. 

The pyrite concentrate would be highly reactive with the potential for spontaneous 

combustion. The 2003 EIS estimated that the pyrite concentrate would have the potential 

to oxidize within one year. Like the sulfuric acid storage facility, a pyrite storage facility 

would require a high level of spill prevention, special material handling, and pollution 

controls. 

This alternative was eliminated from further consideration for the following reasons: 

 The difficult logistics and operational constraints of placing the required facilities at 

the current mill site; and 

 The potential for effects to water quality, aquatic life, and Monument resources as 

well as human health that would be associated with the shipping and storage of 

sulfuric acid, and the handling of pyrite concentrate because of its potential reactivity. 

2.6 Mitigation and Monitoring 

The descriptions of baseline conditions and impact assessments presented in Chapter 3 

identify a number of mitigation measures to address potential impacts and adaptive 

management and monitoring for areas where there are uncertainties. The following 

measures have also been included to address mitigation of potential effects. 

2.6.1 Contemporaneous Reclamation 

Contemporaneous reclamation (also termed concurrent reclamation) would involve 

placing the final cover on portions of the TDF that have achieved their ultimate height 

and slope. As currently described, the design of the proposed action and Alternatives C 

and D would support the placement of the cover in some portions of the TDF without the 

need to wait until the final stages of tailings placement. In addition to the benefits noted 

above, contemporaneous reclamation could serve as a test facility in which to monitor 
2.6 Mitigation and Monitoring 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-35 

vegetation establishment and succession, soil building processes and the performance and 

overall effectiveness of the cover itself.

2.6.2 Mitigation and Monitoring 

The severity of impacts associated with any particular alternative depends to some extent 

on the mitigation that would be implemented. Monitoring can be used to evaluate the 

effectiveness of a particular mitigation measure or to assess whether impacts may be 

occurring to a particular resource. Changes in monitoring results outside an expected 

range can guide adjustments to, or changes in, specific mitigation measures (see 

Section 2.6.3, Adaptive Management). All of the mitigation measures that require 

monitoring are expected to have an adaptive management component, whereby the 

results of monitoring will be used to evaluate the effectiveness of the mitigation measures 

and make improvements as needed. 

2.6.2.1 Mitigation 

Table 2.6-1 presents a summary of mitigation measures that were identified for each of 

the resource areas. The Responsibility column describes which entity would be 

responsible for overseeing or requiring that the measure was actually implemented. To 

the extent possible, the cooperating agencies have worked together to incorporate 

mitigation measures into their permitting requirements. Other measures may be beyond 

regulatory authority but could be put in place by HGCMC. Table 2.6-1 also includes 

mitigation measures that are either ongoing or have been implemented according to the 

GPO (Kennecott 2004), standard operating procedures, or the 2010 Annual Report. 

Table 2.6-1. Required Mitigation Measures by Resource. 

Resource Measure 

Section in 

the EIS Site Responsibility

Air Ongoing dust abatement and monitoring. 

Conduct operations in such a manner as to avoid 

or minimize the production and transport of 

fugitive dust from the site (MIN-3, Forest Service 

2012). 

3.2 TDF HGCMC 

 *Investigate the source(s) and extent of fugitive 

dust-related metals contaminants observed in 

the Forest Service’s lichen monitoring program. 

As necessary, develop mitigation measures to 

reduce fugitive dust emissions. 

3.2 TDF / 

Mill Site / 

Roads 

HGCMC 

Air and Water 

Quality 

Inspect trailers hauling tailings/ waste rock; 

ensure covers are in place and secure and 

tailgate latched and secured against spillage. 

3.2, 3.5 TDF, mill 

area, and 

roads 

HGCMC 

 Spray roads with water if notable dust observed. 3.2 Roads HGCMC 

 Vehicles must have the wheels cleaned prior to 

leaving the TDF using clean water from existing 

permitted water source. 

3.5 TDF HGCMC 

 Implement additional fugitive dust control 

measures. 

3.2.3 TDF HGCMC 

*New requirement. Requirements not marked by an asterisk are required by previous decisions or existing 

permits or plans and made part of this decision. 

 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-36 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 2.6-1. Required Mitigation Measures by Resource (continued). 

Resource Measure 

Section in 

the EIS Site Responsibility 

Geotechnical 

Stability 

Tailings pile must be constructed with 

compacted outside side slopes that are no 

steeper than 3H:1V; slopes during operation may 

be steeper than 3:1 if future operation or slope 

work is planned or approval is obtained. 

3.3, 3.5 TDF HGCMC per 

ADEC Waste 

Management 

Permit 

 Locate ore stockpiles and waste facilities on 

stable, level sites (Min-6, Forest Service 2012). 

3.3 Site-wide HGCMC 

Geochemistry Implement standard operating procedures to 

evaluate risk of acid rock drainage (ARD) and 

other geochemical concerns prior to developing 

quarries. 

N/A Quarries HGCMC 

 Continue characterization of waste rock and 

tailings using accepted protocols to identify 

materials that have the potential to release 

acidity or other contaminants when exposed 

during mining (Min-6, Forest Service 2012). 

3.3, 3.5 TDF HGCMC 

Water 

Resources / 

Water Quality 

Maintain culverts and ditches; inspect facilities 

twice each year to maintain functionality. Clean 

culverts when more than 4” of sediment 

accumulates (6” in ditches). 

3.5 Roads HGCMC 

 *Install storm water detention structures, 

detention ponds or other structures at the 

confluence of surface water runoff diversions 

and natural channels in a manner that will 

maintain geomorphologic integrity of the natural 

channel. 

3.5 TDF HGCMC 

 Water management detention basins and ponds 

would continue to be operated with low storage 

volumes to maintain adequate contact water 

capacity in the pond systems; the maintenance 

of adequate contact water capacity is required by 

ADEC. 

3.5 TDF HGCMC 

 Collect and route direct runoff from tailings 

facility. 

3.5 TDF HGCMC 

 Collect and route direct runoff from mill area 

tailings and storage and transfer facilities. 

3.5 Mill area HGCMC 

 Prevent contact water runoff into surface water 

bodies. 

3.5 TDF HGCMC 

Vehicles exiting the TDF(s) must have the 

wheels cleaned. 

3.5 TDF HGCMC 

 Vehicles exiting the mill building concentrate 

room must have the wheels cleaned; runoff 

water from the truck wash collects in the sump 

and is pumped to the bulk thickener; no runoff 

water from the concentrate loading area leaves 

the building. 

3.5 Mill area HGCMC 

*New requirement. Requirements not marked by an asterisk are required by previous decisions or existing 

permits or plans and made part of this decision. 
2.6 Mitigation and Monitoring 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-37 

Table 2.6-1. Required Mitigation Measures by Resource (continued). 

Resource Measure 

Section in 

the EIS Site Responsibility

Water 

Resources / 

Water Quality 

(continued) 

Spill response and reporting procedure. Detailed 

Contingency Plan outlines spill response and 

reporting procedures in the event of a spill of a 

hazardous substance. 

3.5 Site-wide HGCMC 

 Establish vegetative cover and moderate slopes 

to manage surface water flows. Most slopes will 

be constructed with a 3H:1V slope; use erosion 

control measures (e.g., silt fences, swales, and 

weed-free jute matting) to slow the water and 

reduce erosion while vegetation becomes 

established. 

3.5 TDF HGCMC 

 Stabilize channels and channel banks. 

Hydroseeding used on channel banks to aid in 

stabilization; channels may be stabilized with 

degradable fiber mat to establish vegetation; 

riprap used to stabilize the constructed channels 

in areas that are subject to highly erosive stream 

flows. 

3.5 Site-wide HGCMC 

 Hydroseed slopes for stability. Monitor road cuts 

for exposed soils and use hydroseeding as 

appropriate. 

3.5 TDF HGCMC 

During operations, drainage channels designed 

to handle flows from a 24 hour/25-year storm 

event. Applies to all drainage channels and 

diversion structures during reclamation.

3.5 Site-wide HGCMC 

 Ensure that clean water remains clean. Surface 

runoff is intercepted and diverted around the mill 

area. 

3.5 Mill area HGCMC 

 Minimize tailings contact with groundwater by 

installing liners and under drains beneath the 

tailings; install slurry walls surrounding the facility 

(Min-6, Forest Service 2012). 

3.6 TDF HGCMC 

 Maintain or increase water management 

infrastructure to contain and treat tailings contact 

water and manage industrial storm water. 

3.5 Site-wide HGCMC per 

the current 

APDES Permit 

 Provide for water treatment in perpetuity to avoid 

or minimize the development and release of 

acidic or other contaminants (Min-6, Forest 

Service 2012). 

3.5 TDF HGCMC 

 Install impermeable caps, liners and surface 

water diversions (Min-6, Forest Service 2012). 

3.5 TDF HGCMC 

Aquatic 

Resources 

Repair and maintain, in perpetuity, the existing 

fish passage facility on Greens Creek. 

3.7 TDF HGCMC per 

previous NEPA 

documents and 

ADF&G 

mitigation 

requirements 

 Observe timing windows for instream activities 

as stipulated by ADF&G for the protection of fish 

species. 

3.7 Roads, 

fish 

passage 

HGCMC 

*New requirement. Requirements not marked by an asterisk are required by previous decisions or existing 

permits or plans and made part of this decision. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-38 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 2.6-1. Required Mitigation Measures by Resource (continued). 

Resource Measure 

Section in 

the EIS Site Responsibility 

Soils Salvage topsoil in stockpile (Min-8, Forest 

Service 2012). 

3.9.4 TDF HGCMC per 

GPO 

Establish test plots to study the optimum depth 

of the plant growth layer. 

3.9.4 Site 23 

Test 

Cover 

HGCMC 

Vegetation Establish test plots to verify that vegetative roots 

would not extend into the barrier layer, and 

develop an appropriate seed or planting mix. 

3.10.3.1 Site 23 

Test 

Cover 

HGCMC 

 Survey of HGCMC mine activity areas and roads 

for weeds to determine existing condition. 

3.10.3.1 TDF Forest Service 

 Assure that all vehicles and heavy equipment 

transported to the project area are free of 

invasive plant propagules and contaminated soil.

3.10.3.1 Site-wide HGCMC 

 Use of erosion control materials that are weed 

seed free. Avoid use of hay or straw bales. 

3.10.3.1 Site-wide HGCMC 

 Avoid or remove existing invasive plant 

populations in order to reduce the risk of spread. 

3.10.3.1 Site-wide HGCMC 

 Eradicate control of any newly introduced high 

priority invasive plant populations in the project 

area for the life of the project. 

3.10.3.1 Site-wide HGCMC 

 Perform triennial monitoring surveys of mine 

activity areas and roads for high priority invasive 

plant introductions for the life of the project, and 

for at least 3 years following mine site closures. 

3.10.3.1 Site-wide HGCMC 

 Annually monitor high priority invasive plant 

treatment sites. 

3.10.3.1 Site-wide HGCMC 

Wetlands Mitigation for wetlands will be determined by the 

Section 404 permit. 

3.8.4 TDF HGCMC; 

USACE 

Cultural 

Resources 

Implement Cultural Resources Management 

Procedure for ongoing operations around known 

sites and for managing previously unidentified 

resources. Survey all areas in advance of 

ground disturbing activity. 

3.17 Site-wide HGCMC 

 Document history of customary, traditional, and 

contemporary uses of the Cannery and adjacent 

areas of Hawk Inlet. The first step in the process 

will be for Greens Creek Mine to submit a study 

plan to the Forest Service for approval. 

3.17 TDF HGCMC 

Wildlife and 

Subsistence 

HGCMC employees prohibited from hunting. 3.11, 3.16 Site-wide HGCMC 

 To reduce the potential for impacts to nesting 

migratory birds, ground disturbing activities and 

tree clearing should be conducted outside the 

nesting season in the region (late May through 

early July). 

3.11.4 TDF HGCMC 

*New requirement. Requirements not marked by an asterisk are required by previous decisions or existing 

permits or plans and made part of this decision. 
2.6 Mitigation and Monitoring 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-39 

Table 2.6-1. Required Mitigation Measures by Resource (continued). 

Resource Measure 

Section in 

the EIS Site Responsibility

Air, Water, 

Soil and 

Aquatics 

Review current practices and update as 

necessary to be consistent with Forest Service 

National Core BMPs (Forest Service 2012) to 

avoid, minimize or mitigate adverse effects to 

soil, water quality and riparian resources that 

may result from mining and milling activities. 

Update GPO accordingly. 

3.2, 3.3, 3.4, 

3.5, 3.6, 3.7, 

3.8, 3.9 

Site-wide HGCMC 

*New requirement. Requirements not marked by an asterisk are required by previous decisions or existing 

permits or plans and made part of this decision. 

2.6.2.2 Monitoring 

Monitoring programs currently in place provide a means to assess the effectiveness of 

mitigation measures. Monitoring requirements are established in the GPO, permits, and 

approvals. Table 2.6-2 summarizes relevant monitoring requirements and authority. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-40 Greens Creek Mine Tailings Disposal Table 2.6-2. Monitoring Requirements and Authority. 

Resource / 

Item to be 

Monitored Method of Measurement Frequency of Measurement Threshold of Variability Action to be Taken A

Air Quality Visual observation of 

fugitive dust 

Ongoing Notable dust levels Watering the roads GP

Geotechnical Stability 

Visual inspections compaction testing, water level measured 

Daily visual inspections and recording of volumes by tailings pile operators; visual inspections every two years and following an earthquake, major storms, or over flow for structure by qualified engineer; monthly visual inspection of seepage from the pile and of leachate collection and surface water diversion systems 

Structural change or damage to a facility such that environmental damage is likely to occur or any violation of a permit condition is observed 

Stop water inflow from all managed sources, notify Forest Service, ADNR, create map of inundation 

GP

 Inspection of cover during 

reclamation 

Years 1,2,3, and 5, and then once every 5 years 

Identification of instability (structural change in cover) 

Operator must notify agencies, conduct an investigation, and develop a corrective action plan 

GP

Geochemistry pH, leachate (drainage) 

testing 

Monthly As stated in the GPO GP

InteEnMoPro

 Net neutralization potential 

paste pH of placed tailings 

Monthly tailing composites Every 5 years 

As stated in the GPO An expert in ARD will 

review the info, and develop a management plan if necessary. Notify Forest Service and ADEC 

 Net neutralization potential 

from mill tailings loadout 

Monthly 

 Net neutralization potential 

paste pH, and metals analysis from mill tailings 

Annually 

 Water in contact with 

tailings sampled for chemistry, water level measured 

Quarterly No specific compliance 

levels – looking at trends 

Trends reported to Forest Service, ADEC, and ADNR 
2.6 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 2.6-2. Monitoring Requirements and Authority. 

Resource / 

Item to be 

Monitored Method of Measurement Frequency of Measurement Threshold of Variability Action to be Taken A

Water Resources – Surface Water 

Freshwater sampled at various sites for chemistry 

Monthly and Quarterly to conduct statistical trend analysis 

Compliance with Alaska WQS, APDES permit, and storm water permit 

Compare to up-gradient reference sites, notify Forest Service, ADEC, conduct confirmation sampling, prepare monitoring plan to Forest Service and ADEC 

GP

 Marine water sampled for 

chemistry 

Quarterly Compliance with WQS 

and APDES Permit 

Water Resources – Groundwater 

Chemistry Twice a year Compliance with Alaska 

WQS 

Compare to up-gradient reference sites, notify Forest Service, ADEC, conduct confirmation sampling, prepare monitoring plan to Forest Service and ADEC 

GP

Aquatic Resources 

Juvenile fish sampled for abundance and distribution; subsamples analyzed for chemistry; periphyton samples collected for estimates on biomass. Invertebrates sampled for abundance and community structure. 

Annually for 5 years, then review 

Significant change as compared to baseline or reference site 

Increase the number of parameters analyzed in water samples; the source of the affected changes will be explored and, when found, corrective actions taken to reduce or eliminate the effects. 

GP

 Inspection of fish ladder to 

determine it is clear and passable 

Quarterly inspection Determined not passable Clear of debris and follow 

maintenance program 

 Marine sediment and biota 

for chemistry 

Semi-annually Detect changes in 

background levels 

None, monitoring and reporting only 

AD
Chapter 2. Description of Proposed Action and Other Alternatives 

2-42 Greens Creek Mine Tailings Disposal Table 2.6-2. Monitoring Requirements and Authority. 

Resource / 

Item to be 

Monitored Method of Measurement Frequency of Measurement Threshold of Variability Action to be Taken A

Soils Roads monitored for ruts 

and accumulations of fines; landslides or washouts 

Ongoing High levels of sediment 

production 

Additional mitigation measures such as carrying lighter loads, reduced air pressure in tires, or enhanced sediment removal and sediment control devises used 

GP

Vegetation Visual inspection of mine 

activity areas and roads for high priority invasive plant species 

Triennial Existing Re-survey GP

(to inc

 Monitor high priority 

invasive plant treatment sites 

Annual Still present Removal 

Reclamation/ Post Closure 

Visual inspection for subsidence and movement 

Annually Per Waste Management 

Permit 

Per Waste Management Permit 

GP

 Visual inspection of 

infiltration / barrier, root zone layers and establishment of growth and vegetation 

Semi-annual for 5 years 

 Groundwater monitoring, 

surface water seeps and leachate water monitoring, biological monitoring 

Semi-annual 

 Net neutralization potential 

and paste pH 

Every 5 years 

 Marine water sampling Per National Pollutant 

Discharge Elimination System (NPDES), if tailings underdrain water is discharged through marine outfall 
2.6 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 2.6-2. Monitoring Requirements and Authority. 

Resource / 

Item to be 

Monitored Method of Measurement Frequency of Measurement Threshold of Variability Action to be Taken A

Overall Management 

Conduct facility wide environmental audit 

5 years Observed environmental 

harm or operations not in compliance with the GPO or permit conditions 

Require corrective actions 

GPMaPe

 Conduct regular site 

inspections and BMP monitoring 

Variable (several per year) 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-44 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

2.6.3 Adaptive Management 

Adaptive management provides a mechanism for agencies to determine if and when it is 

necessary or advisable to require adjustment of operating procedures, mitigation 

measures, and/or monitoring in response to concerns identified through monitoring. 

Adaptive management approaches are effective in ensuring that permit and authorization 

requirements are met while providing sufficient flexibility to take preventative or 

remedial action if environmental concerns arise. 

Adaptive management starts with review and oversight of ongoing activities and evolves 

as needs or concerns are identified. On a daily basis, HGCMC staff visually observes 

and responds accordingly to conditions at the TDF, including erosion control measures. 

Several times a year, Forest Service, State or Alaska, or other agencies inspect the site for 

compliance with the GPO or permit conditions. The oversight provides frequent 

opportunity to confirm compliance or identify and respond to concerns. 

HGCMC would implement the mitigation measures listed in Table 2.6-1 and monitoring 

actions and programs listed in Table 2.6-2. If unanticipated adverse conditions are 

discovered, the Forest Service or another agency would require additional investigations 

and corrective actions, as appropriate. The ADEC Waste Management Permit includes 

notification and response requirements should monitoring indicate environmental damage 

has or is likely to occur. For example, if a statistically significant change in water quality 

is detected or a water quality standard is exceeded at any surface water point of 

compliance or down-gradient groundwater monitoring well, the Waste Management 

Permit requires prompt notification, investigation, and development of an action plan. 

HGCMC is required to report the results of its monitoring annually and present the 

findings at an annual meeting which is open to the public. This provides an opportunity 

for the agencies and public to review monitoring results, identify issues, and consider 

corrective actions, including modification of management requirements. 

The Waste Management Permit requires that an independent auditor complete a facilitywide environmental audit every 5 years. The purpose of the audit is to determine if both 

the facility management and regulatory controls and oversight of the facility provide 

reasonable assurances that the facility and controls are functioning as intended. This 

audit is an objective, systematic, documented review of the conditions, operations, and 

practices at the mine. The audit evaluates regulatory compliance, HGCMC’s compliance 

with its own environmental practices, reliability of facility reporting, adequacy of agency 

oversight, bond adequacy, and other components. The results of this audit assist the 

agencies in updating plans, procedures, and permit requirements; determining compliance 

with the GPO and Waste Management Permit; and determining adequacy of the 

reclamation bond. 

If alternatives B, C, or D are selected as a result of this analysis, the Forest Service will 

require detailed construction plans from the operator for the first phase of development, 

not to exceed 10 years of development. For future phases, the Forest Service will prepare 

supplemental information reports to evaluate received phased construction plans in light 

of existing conditions and information known at the time. Supplemental review may also 

be required if changing conditions or new information indicates that such a review is 

necessary. 
2.7 Comparison of Alternatives 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 2-45 

2.7 Comparison of Alternatives 

2.7.1 Exposure to Risk 

Each alternative relies on engineered systems to contain the waste within the TDF and 

manage contact water in perpetuity. A key component of the successful closure of the 

mine is the post closure contact water management and treatment. This system is 

essential because, as discussed throughout Section 3, contact water draining from the 

TDF may not meet WQS for hundreds of years, perhaps in perpetuity. As such, all 

contact water draining from the TDF is required to be captured and treated until such 

time that WQS can be met. The contact water management and control system includes 

the engineered cover, the facility liner, the system of underdrains and sumps, water 

collection ponds, the treatment facility, the marine discharge, and the pipe connecting 

these systems. These systems will require regular monitoring and maintenance in order 

to continue functioning properly. Pumps and treatment facilities will require power. 

Failure of one or more components, or the power required to operate a component, may 

be inevitable over the course of several hundred years and beyond. It is not possible to 

predict how a failure would occur or what the consequences would be. Possible 

scenarios include discovering a contact water seep down gradient of the facility, a pump 

failing causing a contact water collection pond to overflow and pollute adjacent streams, 

a contact water conveyance pipe rupture, human error, a natural event such as an 

earthquake, or any number of other situations. The environmental impact of such an 

event would depend on the nature, timing, and location of the failure and the time 

required to detect, define, and mitigate the situation. 

While all alternatives have been designed to be geotechnically stable and meet WQS with 

treatment, it is possible to compare the alternatives in terms relative exposure to risk and 

what would be at risk in terms of where a failure could occur. Alternatives A, B, and 

Mitigated B are similar in location and complexity, although the larger TDF in 

Alternatives B and Mitigated B would necessitate more contact water containment and 

conveyance systems when compared to Alternative A. Failures could occur in the 

Tributary or Cannery Creek watersheds, also potentially affecting Zinc Creek and Hawk 

Inlet downstream. Under Alternatives C and D, a new TDF would be developed about 3 

miles north of the existing TDF, adding additional pumps and about 3 miles of contact 

water conveyance pipe from the new TDF to the treatment plant adjacent to the existing 

TDF. Thus, the risk of failure would be extended into new watersheds, adding tributaries 

to Hawk Inlet, Fowler Creek, and Young Bay downstream. The risk of failure within the 

Tributary Creek, Cannery Creek and Zinc Creek watersheds would be similar between all 

alternatives. Alternatives A, B, and Mitigated B would rely on a simpler system with 

fewer pipes and pumps than alternatives C and D, and would expose fewer watersheds to 

the risk of potential future failures and associated environmental impacts. 

2.7.2 Summary of Alternatives 

Table 2.7-1 provides a brief comparison of all the alternatives. The table illustrates the 

similarities and differences among alternatives for each resource. 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-46 Greens Creek Mine Tailings Disposal 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource. 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Duration of Mine Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 

Air Quality Uncontrolled: PM10-2.5

tons per year (tpy) 

142 171 164 233 

 PM2.5 tpy 17 22 21 30  Controlled: PM10-2.5

tpy 

77 90 87 123 

 PM2.5 tpy 9 12 11 16  Greenhouse gas 

emissions (tons CO2 

emissions per year) 

707 707 707 946 

Water Resources–Surface Water 

Percent of watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 20 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 11 

Tributary Creek: 15 Cannery Creek: 3 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 3 South Hawk Inlet: 11 

Tributary Creek: 3 Cannery Creek: 2 Fowler Creek: 2 North Hawk Inlet: 11 Middle Hawk Inlet: 1 South Hawk Inlet: 2 

 Total acres of 

watersheds affected by new disturbance 

Tributary Creek: 0 Cannery Creek: 0 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 0 

Tributary Creek: 81 Cannery Creek: 19 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 28 

Tributary Creek: 62 Cannery Creek: 23 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 12 South Hawk Inlet: 29 

Tributary Creek: 12 Cannery Creek: 15 Fowler Creek: 107 North Hawk Inlet 28 Middle Hawk Inlet: 6 South Hawk Inlet: 6 

 Reduction in stream 

flow 

Minor reduction of flow in two creeks (Tributary and Cannery) 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A. Impacts to Tributary Creek slightly less than Alternative B. 

Minor reduction in flow in three creeks (Tributary, Canneryand Fowler) 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
2.7 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Duration of Mine Life Through 2019 30–50 More Years 30–50 More Years 30–50 More Years 

Water Resources–Surface Water (continued) 

Additional water management infrastructure such as diversions, groundwater slurry walls, and water management ponds 

Yes as TDF expands to currently approved size 

Yes; more water management infrastructure required than Alternative A 

Yes; more water management infrastructure required than Alternative B; additional water management infrastructure required, including construction and maintenance of pipeline and pump stations. 

Yes; more total infrastructure requirthan Alternative B aAlternative Mitigated B; additional water management infrastructure requirfor new TDF, including constructioand maintenance of pipeline and pump stations 

 Need for long-term 

water treatment 

Yes Yes Yes Yes 

Water Resources–Groundwater 

Change in flow or quality 

Minimal effect on local hydrogeology; no impacts to groundwater quality 

Similar to Alternative A Similar to Alternative A Similar to Alternative 

A but new TDF located in additionagroundwater area 

Aquatic Resources 

Habitat permanently lost (feet) 

Class I Tributary: 0 

Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 1,646 Fowler: 0 

Tributary: 0 Fowler: 0 

Class II Tributary: 0 

Fowler: 0 

Tributary: 2,400 Fowler: 0 

Tributary: 1,169 Fowler: 0 

Tributary: 0 Fowler: 1,044 

Risk of chemical or mining product spill 

Low, due to BMPs and Spill Prevention, Control, and Countermeasure Plan requirements 

Similar to Alternative A, although risk would continue over 30 to 50 years due to extended operations 

Similar to Alternative B Similar to Alternative 

B except the area opotential spills would expand to include Fowler Creek drainage 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Chapter 2. Description of Proposed Action and Other Alternatives 

2-48 Greens Creek Mine Tailings Disposal 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Geochemistry Likelihood of TDF 

ARD developing (uncontrolled) 

Low due to very low permeability, low availability of oxygen and closure and reclamation of TDF 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Geotechnical Stability 

Likelihood of TDF failure 

Very low probability of TDF failure due to design measures 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Soils New loss in soil 

productivity (measured in acres disturbed) 

0 128a 126a 174a 

Vegetation Acres of new 

disturbance 

0 POG: 73 acres 

Unproductive forest: 55 acres 

POG: 64 acres Unproductive forest: 62 acres 

POG: 114 acres Unproductive forest60 acres 

Off-site effects Elevated metals levels in 

lichens may continue through life of operations; duration of effects would depend on the effectiveness of control measures 

Similar to Alternative A; however, off-site effects may continue longer due to longer mine life 

Similar to Alternative B Similar to 

Alternative B 

Wetlands Acres and types of 

new disturbance 

0 Bog/Bog Woodland: 20 

Forested: 36 Sedge Fen/Fen: 28 Marsh: 1 Total: 85 

Bog/Bog Woodland: 12Forested: 35 Sedge Fen/Fen: 27 Marsh: 3 Total: 77 

Bog/Bog WoodlandForested: 78 Sedge Fen/Fen: 25 Marsh: 1 Total: 112 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
2.7 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Wildlife New decrease in 

brown bear buffers (acres) 

None 30 29 6 

New removal of POG habitat (acres) within brown bear buffers 

None 35 27 5 

Duration of activities that could disturb wildlife and marine mammals 

Through 2019 Additional 30–50 years Additional 30–50 years Additional 

30-50 years 

New temporary reduction in deer winter range habitat (acres) 

None 128 125 174 

Result in “take” of Endangered Species Act (ESA)-listed speciesb

No No No No 

Number of goshawk nests potentially affected 

0 0 0 1 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis pro

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS o
Chapter 2. Description of Proposed Action and Other Alternatives 

2-50 Greens Creek Mine Tailings Disposal 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Threatened (FT) and endangered (FE) species / Forest Service Sensitive Species (FSS)/Forest Service Rare (FSR) 

Humpback whale (FE)b Not likely to adversely effect 

Steller sea lions (FE)b Not likely to adversely effect Yellow-billed loon (candidate and FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, 

federal listing 

Chinook salmon; coho salmon; sockeye salmon; steelhead (FT or FE, depending on the run) 

No effect 

Green Sturgeon (FT) No effect Pacific Herring (candidate and FSS 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Queen Charlotte goshawk (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Black oystercatcher (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Mountain lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Large yellow lady’s 

slipper (FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Alaska rein orchid 

(FSS) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

 Bog adder's-mouth 

orchid (FSR) 

May adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nfederal listing 

Land Use Meet management 

prescriptions 

Yes Yes Yes Yes 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
2.7 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Recreation Duration of operations 

(when public may be excluded from areas) 

Through 2019 plus reclamation period 

Additional 30–50 years plus reclamation period 

Additional 30–50 years plus reclamation period

Same duration as Alternative B; disturbance at new TDF initiated in approximately 3-5 years 

Scenic Resources 

Compliance with applicable scenic integrity objective (SIO) 

Yes Yes Yes Yes 

 Duration of visual 

effects 

Around 2019 plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Additional 30–50 years plus reclamation establishment period 

Reclamation at existing TDF to begin approximately 3-5 years; reclamatiof new TDF at end omining activity (30-50 years); reclamation establishment perioapplies to both facilities 

 Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion acurrent location and new site to the north 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-52 Greens Creek Mine Tailings Disposal 

Table 2.7-1. Summary of Potential Impacts of Each Alternative by Resource (continued). 

Resource Impact Alternative A Alternative B Alternative B Mitigated Alternative C 

Subsistence Duration of mine life Through 2019 30–50 more years 30–50 more years 30–50 more years  New temporary 

reduction in deer winter range habitat (acres) during operations and until forested canopy develops post reclamation 

None 128 125 174 

 Location of TDF Current location Expanded at current 

location 

Expanded at current location 

Minimal expansion acurrent location and new site to the north 

Cultural Resources 

Effects on historic properties 

Historic properties not adversely affected; Hawk Inlet identified as a sacred place by Angoon affected over the long term 

Same as Alternative A Same as Alternative A Same as Alternative 

Socioeconomics Duration of annual economic and 

employment benefit from operations 

Through 2019 30–50 more years 30–50 more years 30–50 more years 

Monument Resources 

New disturbance within Monument (acres) 

0 104 83 18 

 Post-mining condition Near-natural condition 

following reclamation 

Similar to Alternative A Similar to Alternative A Similar to 

Alternative A 

Environmental Justice 

Disproportionately affect minority or low income populations 

No No No No 

a. Soil productivity would begin to be re-established following closure and continue to return to pre-mining conditions as soil genesis proce

established. 

b. A “may affect” determination was made for Humpback whales and Stellar sea lions (Tetra Tech 2013) with concurrence from NMFS on 
2.7 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 
Chapter 2. Description of Proposed Action and Other Alternatives 

2-54 Greens Creek Mine Tailings Disposal 
3.1 Introduction 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-1 

CHAPTER 3. AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 

3.1 Introduction ________________________________ 

Environmental impact statements (EISs) often separate the discussions of the affected 

environment (baseline conditions) and environmental consequences into separate 

chapters. This EIS combines these two chapters because the affected environment has 

already experienced environmental consequences from previous mining activities. 

Chapter 3 describes each resource, beginning with an overview of that resource, a brief 

summary of pre-mining conditions (based on the 1983 EIS), a description of the current 

conditions, and finally, a description of the environmental consequences that would result 

from each tailings disposal facility (TDF) alternative. Current conditions, including 

effects that have already occurred as a result of mine-related activities, will serve as the 

baseline conditions against which environmental impacts from the alternatives will be 

compared. Where applicable, the environmental consequences sections describe effects 

that are common to all alternatives followed by descriptions of effects that are unique to 

each alternative. The discussions include descriptions of measures that could be 

implemented to avoid, minimize, or mitigate impacts. 

Analyses conducted under the National Environmental Policy Act (NEPA) focus on 

assessing effects (positive and adverse) to a suite of resources and consider the frequency, 

duration, and spatial distribution of those effects. One objective is to identify 

“significant” effects in an attempt to avoid or minimize them to the extent possible. The 

Council on Environmental Quality (CEQ) in its NEPA regulations (40 CFR 1508.27) 

defines significance in terms of both context and intensity. Context refers to the setting 

of the project and how individual resources may be affected to a local or regional extent. 

Intensity refers to the severity of the impact and includes considerations of the 

uniqueness of the resource, whether affects are positive or adverse, whether federal, state 

or local laws may be violated, and the degree of risk or uncertainty involved. A project 

could exhibit extreme intensity to particular individuals (e.g., mortality) while having a 

low intensity level when considered on the basis of a local population; the significance of 

an effect would be different if an endangered species was involved compared to a species 

that occurs commonly. The impact analysis for each resource, therefore, considers the 

magnitude of the impacts, their frequency, likelihood, extent, duration, and intensity. 

The EIS also considers cumulative effects of the proposed action and alternatives when 

combined with other past, present and reasonably foreseeable activities. The cumulative 

effects discussion is provided in Section 3.22. 

For this project, the project area is defined as a one-half-mile buffer around the proposed 

TDF expansion areas and the portions of the A and B Roads extending from the existing 

lease boundary north to the TDF expansion under alternatives C and D (Figure 3.1-1). 

The study area for each resource may vary from the project area and in some cases may 

be much larger. The study area for each resource is described in Table 3.1-1. In some 

cases, study areas for cumulative effects may extend beyond the study area for direct and 

indirect effects; these are described in selection criteria identified in Table 3.22-2 in the 

cumulative effects discussion. 
Chapter 3. Affected Environment and Environmental Consequences

3-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.1-1. Project and Study Areas. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-3 

Table 3.1-1. Study Areas for Direct and Indirect Effects. 

Resource Study area for direct and indirect effects 

Air Quality Combined watershed area in Figure 3.1-1 

Geotechnical Stability Direct footprint of the TDF(s) 

Geochemistry Direct footprint of the TDF(s) 

Water Resources Combined watershed area in Figure 3.1-1 

Aquatic Resources Combined watershed area in Figure 3.1-1 and Hawk Inlet 

Soils Project area 

Vegetation Project area 

Wetlands Combined watershed area in 3.1-1 

Threatened and Endangered Species Project area 

Land Use Project area 

Scenic Resources Viewshed from Hawk Inlet (Figure 3.14-4) 

Recreation Project area and Hawk Inlet 

Subsistence Project area and Hawk Inlet 

Cultural Resources Project area 

Socioeconomics City and Borough of Juneau (CBJ) 

Monument Resources Admiralty Island National Monument 

Environmental Justice CBJ and Hoonah-Angoon Census Area 

3.2 Air Quality _________________________________ 

Air quality and permitting for industrial air emission 

sources is regulated under the federal Clean Air Act. 

Industrial air emission sources include stationary 

(point) sources, fugitive sources and mobile sources. 

The U.S. Environmental Protection Agency (USEPA) 

has approved the Alaska Department of 

Environmental Conservation (ADEC) Title 1 and Title 

5 State Implementation Plan programs. The ADEC 

administers the air permit program for industrial 

emission sources in Alaska. To obtain an air permit 

from ADEC the industrial source must identify all air 

emissions associated with the operation and 

demonstrate compliance with ambient air quality 

standards. National Ambient Air Quality Standards 

(NAAQS) and Alaska Ambient Air Quality Standards 

which the Greens Creek Mine must comply are listed 

in Table 3.2-1. 

Air quality was not identified as 

a significant issue during the 

scoping process. Comments 

received during the scoping 

process regarding air quality 

related to dust generated by 

mining activities are addressed 

in this section. Measures of air 

quality include fugitive dust 

levels in the project area and 

metal concentrations in 

established lichen monitoring 

plots.
Chapter 3. Affected Environment and Environmental Consequences

3-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.2-1. National and Alaska Ambient Air Quality Standards. 

Pollutant 

Primary Standards Secondary Standards 

Level Averaging Time Level Averaging Time 

Carbon Monoxide 9 ppm 

(10 mg/m3

) 

8- hour None 

35 ppm 

(40 mg/m3

) 

1-hour 

Lead 0.15 μg/m3 Rolling 3-month 

average 

Same as Primary 

Nitrogen Dioxide 53 ppb Annual 

(Arithmetic Average) 

Same as Primary 

100 ppb 1-hour None 

Particulate Matter (PM10) 150 μg/m3 24-hour Same as Primary 

Particulate Matter (PM2.5) 15.0 μg/m3 Annual 

(Arithmetic Average) 

Same as Primary 

35 μg/m3 24- hour 

Ozone 0.075 ppm 8-hour Same as Primary 

Sulfur Dioxide 0.03 ppm Annual 

(Arithmetic Average) 

0.5 ppm 3-hour 

0.14 ppm 24-hour 

75 ppb 1-hour None 

The NAAQS, developed by USEPA and adopted by the State of Alaska, are implemented 

to protect public human health and welfare. Primary standards are intended to protect 

public health. Secondary standards are in place to protect public welfare. NAAQS and 

Alaska Ambient Air Quality Standards have been established for six criteria pollutants 

which include; sulfur dioxide (SO2), carbon monoxide (CO), lead, ozone, nitrogen 

dioxide (NO2) and particulate matter with a diameter less than 10 microns in size (PM10) 

and less than 2.5 microns in size (PM2.5). For areas that attain the NAAQS, the USEPA 

has developed Prevention of Significant Deterioration (PSD) regulations. Within the 

PSD regulations, the PSD increment is defined as the amount of pollution a source is 

allowed to emit and is based on the specific baseline (ambient) concentration at the time 

that the first complete PSD permit application affecting the area was submitted. The key 

purpose of PSD regulations is to protect air quality and keep attainment areas in 

compliance with the NAAQS. Greens Creek Mine is located in an area classified as PSD 

Class II, which allows for moderate industrial growth in the area; Greens Creek Mine is 

considered a major source under PSD regulations, because it has the potential to emit 

more than 205 tons per year (tpy) of NOx. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-5 

3.2.1 Air Quality – Pre-mining Environment 

Before mining, air pollutant concentrations in the vicinity of the Greens Creek Mine are 

expected to have been well below the NAAQS. Prior to mine development, 

concentrations of criteria pollutants were not directly measured. Levels of pollutants 

were expected to be lower than observed in Juneau and similar to levels of surrounding 

remote areas. 

The climate at the Greens Creek Mine is a coastal marine environment. Topography 

largely influences wind patterns in the area. The terrain at the project site channels the 

wind, producing a flow from the north-northeast. Based on site data collected between 

2000 and 2010, the wind at the project site was from the north-northeast about 39 percent 

of the time and from the south about 12 percent of the time. The highest wind speed 

recorded near the project site between 2000 and 2010 was 72.6 miles per hour (mph). 

The average wind speed was 6.6 mph. Figure 3.2-1 graphically depicts the percentage of 

time the wind blows from a particular direction and includes a speed component. The 

data was collected in knots near the project site from January 1, 2000 through December 

31, 2010 (1 knot is equal to 1.15 miles per hour). 

Figure 3.2-1. Annual Prevailing Wind Speed and Direction. 
Chapter 3. Affected Environment and Environmental Consequences

3-6 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The potential for dispersion of airborne pollutants at the mine site is dependent on several 

environmental factors: wind speed, precipitation and the depth of the atmospheric mixing 

zone. High winds can dilute pollutants in the atmosphere as well as lead to higher 

fugitive dust emissions. Low wind speeds reduce pollutant dispersion and can increase 

localized ambient concentrations of pollutants. 

3.2.2 Air Quality – Baseline Conditions 

Ambient air quality monitoring has been conducted for PM10 at the mine site and 

measurements are below NAAQS standards. Concentrations of other commonly 

monitored air pollutants including nitrogen dioxide, carbon monoxide, and sulfur dioxide 

have not been directly measured at the mine site. 

PM10 ambient air quality monitoring was conducted at the Greens Creek Mine from April 

20, 1995, to March 30, 1996. Two co-located PM10 monitors were installed on the slope 

behind the mill. Concentrations of PM10 were well below the ADEC established standard 

of 150 μg/m3. However, the mine was not in operation during this period. Therefore 

concentrations of PM10 were representative of ambient air conditions. No onsite PM10

monitoring has been conducted while the mine has been in production. 

The ADEC has issued air permits that serve as a framework for the operation of the mine 

site. Active permits are currently in place to regulate air emissions at the mine site (Title 

V Operation Permit No. AQ0302TVP02 (Rev.1), Owner Request Limit No. 

AQ0853ORL02 and Minor Permit No. AQ0302MSS01). Operational guidelines and 

restrictions are identified in the active permits to ensure air quality standards are 

maintained at the Greens Creek Mine property boundary during ongoing mining 

activities. The regulations and restrictions put in place by the ADEC are monitored 

through ongoing reporting requirements and inspections by ADEC personnel 

(Table 3.2-2). A summary of emissions units currently permitted at the Greens Creek 

Mine is listed in Table 3.2-3. 

Table 3.2-2. Alaska Department of Environmental Conservation Air Quality Site 

Inspections. 

Inspection Date Summary of Inspection Findings 

May 22, 2001  Clean Air Act Notice of Violation 

 Failure to obtain a permit for a generator installed in 1998 

December 31, 2007  Facility found to be in compliance with all air quality permits 

April 29, 2010  Request air quality monitoring for particulate at the western and 

southwestern portions of the TDF 

 Follow-up with ADEC Air Quality Monitoring group to develop this 

program is recommended 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-7 

Table 3.2-3. Summary of Emission Units Currently Permitted at the Greens Creek Mine. 

Emission Units (EU) 

Description 

Allowable Tons of Pollutants Emitted Per Year a

NOx CO PM10 SO2 

Volatile Organic 

Compounds 

Ruston Diesel Engine 535.7 b 100.0 2.4 7.6 9.1 

Ruston Diesel Engine 

Ruston Diesel Engine 

CAT 3516B Diesel Engine 7.8 .5 40.0 b 7.6 

CAT 3516B Diesel Engine 

Diesel Solar Taurus Turbine 1.7 0.8 8.6 

Sullair Air Compressor 36.1 7.8 2.6 2.9 

Volcano Oil Boiler 1.6 0.4 0.1 0.02 

Sag Mill (crusher) 0.0 0.0 0.0044 0.0 0.0 

Ball Mill (crusher) 0.0 0.0 0.0044 0.0 0.0 

Conveyor Drop Points 0.0 0.0 0.042 0.0 0.0 

Cleaver-Brooks Boiler 2.81 0.7 0.04 3.18 0.14 

Insignificant Emission Units 0.31 0.08 0.063 1.09 0.0039 

All Units (Total) 576.5 126.3 11.8 67.1 54.2 

Notes: 

a. This table includes potential emissions from the significant emission units as listed in the current 

Operating Permit No. AQ0302TVP02 Revision 1 issued on March 3, 2011; emission units as described 

in off-permit changes; and insignificant emission units that are not required to be in the permit as set 

out in 18 ACC 50.326(d). 

b. Potential emissions based on allowable limits under the current operating permit. 

Fugitive Dust and Deposition 

Based on observation, dust is lost from the TDF during dry and windy conditions. These 

conditions typically occur between mid-December and late February when high pressure 

systems commonly create strong northern winds and dry, cold conditions. Since 2007, 

snow samples have been collected prior to spring melt. The samples collected were 

analyzed to quantify the amount of tailings dust accumulated in the surrounding snow 

pack. Lead loading was observable up to 1,695 feet from the TDF. Loading 

concentrations have decreased since initial sampling in 2007; dust mitigation measures 

put in place by Hecla Greens Creek Mining Company (HGCMC) have likely contributed 

to the decrease (KGCMC 2009). 

The Tongass National Forest and the Alaska Regional Soil, Water, and Air Program of 

the Forest Service, U.S. Department of Agriculture (Forest Service) initiated the use of 

lichens as biomonitors of air pollution in the Tongass National Forest (Geiser et al. 1994). 

Lichens are strongly affected by atmospheric conditions such as precipitation, gases, and 

particulate matter (Nash and Gries 1991; Herzig et al. 1989). Air pollution is directly tied 

to forest health and deposition of pollutants can produce effects including altering soil 

pH, which may in turn damage roots and harm productivity of vegetation (CARB 1989). 

The airborne deposition of metals or other contaminants can also produce ecosystem 
Chapter 3. Affected Environment and Environmental Consequences

3-8 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

changes over time. Lichens’ sensitivity to air quality facilitates their use as biomonitors, 

to evaluate air quality changes in a geographic region over time (Richardson 1988; Garty 

1988). 

The Tongass National Forest and the Alaska Regional Soil, Water, and Air Program of 

the Forest Service employ a lichens biomonitoring program for air pollution in the 

Tongass National Forest (Geiser et al. 1994). Lichen sampling at the Greens Creek Mine 

was initiated in 2005. Lichen samples were collected from plots at the mine portal and 

TDF that are exposed to road dust, vehicle emissions and other airborne particulates 

related to mining activities. 

Lichens collected at the Greens Creek Mine portal contained more elements above 

established baseline levels than any other monitoring site in the Tongass National Forest. 

Lichens collected from Plot 511a had 12 elements above threshold values, while lichens 

collected from Plot 511b, 250 feet away from the portal, had 7 elements above threshold 

values. From Plot 512 near the TDF, 19 elements were above threshold including sulfur, 

nitrogen, aluminum, barium, cadmium, copper, iron, lead, silicon, titanium, vanadium, 

zinc, cobalt, lithium, and nickel. The presence of these high concentrations of elements is 

suspected to be from fugitive dust from mining and road activity. 

Dust Control Improvement Methods 

Under the current Title V Permit No. AQ0302TVP02 (Rev. 1), HGCMC must take 

reasonable precautions to prevent fugitive dust while materials are handled, transported, 

stored or engaged in industrial activity or construction. In an effort to reduce dust loss 

from the TDF, HGCMC has employed a variety of voluntary abatement measures. 

Interim slopes not being used are covered with rock, outer slopes of the TDF are 

hydroseeded and snow fences and concrete blocks were installed on the crest of the TDF 

to serve as a wind break. 

3.2.3 Air Quality – Environmental Consequences 

This section addresses the expected changes in air quality and emissions associated with 

the alternatives and the relative differences among alternatives in terms of air emissions. 

The stationary sources of air emissions included in the proposed action are compared to 

potential sources of air emissions associated with each alternative. Stationary source 

emission units will remain virtually the same for all activities associated with mining and 

mineral processing with only a difference in duration at various sites. Fugitive dust 

emissions for activities associated with the TDF operations and development will vary by 

alternative. 

3.2.3.1 Effects Common to All Alternatives 

The baseline conditions described previously are the current conditions of the mining 

operation. Under all identified alternatives, air emissions would continue from mining 

and support activities already underway. Air emission sources associated with the mine 

include non-combustion sources such as fuel tanks, fugitive dust-generating sources; 

other miscellaneous sources; and combustion sources such as mining equipment, heaters, 

diesel generators and boilers. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-9 

Compliance with all ADEC air quality permits would continue. As noted in Section 

3.2.2, elevated concentrations of metals have been observed in lichens adjacent to the 

TDF. These elevated metals levels are likely to continue into the immediate future under 

all alternatives and would decrease following closure of the TDF. To the extent that 

emissions (or deposition) are from TDF operations, the duration of future effects would 

depend on the effectiveness and implementation schedules of control measures that could 

be put in place. 

Each alternative has the potential for increased fugitive dust emissions due to wind 

erosion of the TDF and truck hauling on unpaved roads. Emissions generated by wind 

erosion are dependent upon the frequency and size of disturbances of the erodible 

surface; each time the surface is disturbed, fresh surface material is exposed to wind. 

Stationary source emission units (i.e., generators, boilers, etc.) would not measurably 

change under all action alternatives. Mobile emissions and greenhouse gas (GHG) 

emissions from vehicle miles traveled and number of vehicles will change by alternative. 

Fugitive Dust Emissions 

Estimations for the maximum annual uncontrolled and controlled PM10 and PM2.5 fugitive 

dust emissions for alternatives A–D are listed in Table 3.2-4. Total maximum emissions 

incorporate fugitive dust from travel on unpaved roads and wind erosion on the TDF. 

Fugitive emissions due to travel on unpaved roads were estimated using methods outlined 

in the Western Regional Air Partnership’s fugitive dust handbook. Fugitive emissions 

due to wind erosion of the surface area of the TDF were estimated using standard 

methods (Air and Waste Management Association). 

Table 3.2-4. Estimated Maximum Fugitive Dust Emissions. 

Alternative 

Maximum 

Emissions 

PM2.5 (tpy) 

Maximum 

Emissions 

PM10 (tpy) 

Max Tailings 

Footprint 

(acres)* 

Unpaved 

Roundtrip Road 

Length (miles) 

A 17 159 49 16 

B 22 193 54 16 

Mitigated B 21 186 44 16 

C 30 263 102 21 

D 32 274 103 21 

* This number represents the footprint of the tailings only. 

Unpaved Roads: Fugitive PM10 and PM2.5 emissions for alternatives A–D from travel on 

unpaved haul roads are summarized in figures 3.2-2 and 3.2-3. Fugitive PM10 dust 

emissions from unpaved roads were estimated given the number of dry working days per 

year, length of unpaved road to TDF from the mine, silt content of the road material and 

average vehicle weight. Control efficiencies (44 percent) are based on existing 

limitations on traffic speeds on haul roads of 25 mph (MRI 2006). 
Chapter 3. Affected Environment and Environmental Consequences

3-10 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.2-2. Maximum Controlled and Uncontrolled PM10 Emissions for TDF and Roads. 

Figure 3.2-3. Maximum Controlled and Uncontrolled PM2.5 Emissions for TDF and Roads. 

Wind Erosion: Fugitive PM10 and PM2.5 emissions from wind erosion at the TDFs were 

calculated by establishing an erosion potential of the TDF based on an average peak wind 

speed observed near the TDF during the period between January 1, 2000 and November 

30, 2008. Other variables used to establish the PM10 and PM2.5 emissions from wind 

erosion include working dry days per year and the maximum height and surface area of 

the TDF. The disturbed portion of the TDF was estimated as 50 percent of the total 

footprint acreage based on existing dust management procedures including re-seeding 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-11 

unused portions of the TDF. Control efficiencies (55 percent) are based on existing dust 

management procedures, which include watering the TDF as needed. Western Regional 

Air Partnership guidance indicates a watering frequency of twice per day to obtain this 

efficiency; however, it was assumed due to the wet conditions of the area that this 

efficiency is still accurate. The Hawk Inlet Meteorological Station at the Greens Creek 

Mine indicates an average of 219 wet days per year based on daily precipitation data 

from 2000 to 2010. Figures 3.2-2 and 3.2-3 summarize the maximum uncontrolled and 

controlled emissions from the TDF as a result of wind erosion for alternatives A–D. 

Greenhouse Gas Emissions 

Mobile source GHG emissions were calculated for all action alternatives. Mobile source 

GHG emissions at the Greens Creek Mine for Alternative B and Mitigated Alternative B 

would add 707 tons CO2 emissions per year or 0.16 percent to Juneau’s total GHG 

emissions; Alternative C would add 946 tons CO2 emissions per year or 0.21 percent of 

Juneau’s total GHG emissions and Alternative D would add 910 tons CO2 emissions per 

year or 0.21 percent of Juneau’s total GHG emissions (Table 3.2-5). Stationary sources 

would remain the same under all action alternatives for the life of the mine. 

Table 3.2-5. Mobile Greenhouse Gas Emissions. 

 

Light 

Weight 

Vehicle 

(kg/day) 

Heavy 

Duty 

Truck 

(kg/day) 

Light 

Duty 

Truck 

(kg/day) 

Total 

(kg/day) 

Total 

(kg/day) 

Total 

(tons CO2 

emissions 

per year) 

Alternative A 

CO2 171.8 1,470.3 113.1 1,755.2 706.19 

N2O 0.0059 0.0049 0.0001 0.0108 0.0044 707.62 

CH4 0.0041 0.00517 8.6E-05 0.00935 0.00376 

Alternative B 

CO2 171.8 1,470.3 113.1 1,755.2 706.19 

N2O 0.0059 0.0049 0.0001 0.0108 0.0044 707.62 

CH4 0.0041 0.0052 9E-05 0.0094 0.0038 

Mitigated 

Alternative B 

CO2 171.8 1,470.3 113.1 1,755.2 706.19 

N2O 0.0059 0.0049 0.0001 0.0108 0.0044 707.62 

CH4 0.0041 0.0052 9E-05 0.0094 0.0038 

Alternative C 

CO2 229.8 1,966 151.3 2,347 944.5 

N2O 0.008 0.007 2E-04 0.015 0.006 946.40 

CH4 0.005 0.007 1E-04 0.013 0.005 

Alternative D 

CO2 221.1 1,893 145.6 2,259 909 

N2O 0.008 0.006 2E-04 0.014 0.006 910.84 

CH4 0.0053 0.0067 0.0001 0.012 0.0048 
Chapter 3. Affected Environment and Environmental Consequences

3-12 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Mobile source emissions were calculated based on road trips required daily by lightweight pickups and heavy-duty haul trucks from the mine portal to the TDF. The 

distance from the mine portal to the TDF for alternatives A and B is 15.6 miles round 

trip; the distance from the mine portal to the north TDF under alternatives C and D is 

21.2 miles roundtrip. Alternatives C and D would produce 0.05 percent more GHG 

emissions than alternatives A and B yearly while the north TDF is under construction and 

operation. In comparison Juneau’s yearly highway transportation GHG emissions equals 

29 percent of the borough’s total GHG emission output (Juneau Climate Action & 

Implementation Plan 2011). 

Mitigation and Monitoring 

Currently, the existing mitigation measures to prevent wind erosion of the TDF include 

hydroseeding on disturbed areas of the TDF, installation of wind breaks and covering 

slopes with rock. Additional dust control measures taken for controlling emission 

sources other than wind erosion are discussed in Section 3.2.3.1 as part of existing 

conditions. 

Sampling has indicated elevated levels of metals in snow and lichen adjacent to the TDF. 

For this reason the Forest Service is requiring additional sampling for fugitive dust in the 

air using federal reference methods for dust monitoring devices. The extent and source 

of elevated concentrations of lead, zinc and other metals are being characterized through 

a formal monitoring program implemented by HGCMC with continued snow sampling 

and atmospheric depositional pail passive air samplers that were installed at locations 

around the TDF in 2010. 

If monitoring indicates that fugitive dust emissions related to TDF activities are the 

source of elevated concentrations of lead, zinc and other metals, a mitigation plan will be 

developed to identify control measures. An adaptive management approach would allow 

improvements to trigger more or less future control measures. 

Additional control measures included in the mitigation plan should be considered by 

evaluating the significance of the impact and control. Acceptable and effective 

mitigation measures can be found within local and state regulatory standards in dry 

regions of the continental U.S. and include those as noted in the Western Regional Air 

Partnership’s Fugitive Dust Handbook and are summarized in Table 3.2-6. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-13 

Table 3.2-6. Regulatory Formats to Control Fugitive Dust on Unpaved Roads and Open 

Areas. 

Control Measure Goal Threshold Agency 

Wind Erosion of Open Sources 

Watering, fencing, paving, 

graveling, dust suppressant, 

vegetative cover, restrict vehicular 

access 

Maintain soil moisture 

content min 12%; or 

70% min of optimum 

soil moisture content; 

reduce windblown 

emissions 

Construction sites; fences 

3 feet – 5 feet, adjacent to 

roadways/urban areas 

Arizona, 

Maricopa County 

Rule 310 

04/07/2004 

Cease ops (wind speed 

>25 mph); applying dust 

suppressant two times per hour; 

watering and fencing (as above)

Reduce amt of 

windblown dust leaving 

site; maintain soil 

moisture content 12%

Wind speed must be 

>25 mph for 60 minute 

average; fencing must be 

3 feet – 5 feet with <50% 

porosity; watering 

increase to four times per 

day during wind event

Arizona, 

Maricopa County 

Rule 310 

04/07/2004

Control dust on all disturbed soil 

to maintain in damp condition: soil 

crusted over by watering or other, 

or graveling or treated with dust 

suppressant

Prevent visible fugitive 

dust from exceeding 

20% opacity, and 

prevent dust plume 

from extending more 

than 100 yards

NA Nevada, Clark 

County Section 

94 Air Quality 

Regulation 

06/22/2000

Application of water or chemical 

stabilizers prior to wind event 

three times per day (possible 

increase to four times per day if 

evidence of wind driven dust), or 

establish a vegetative cover 

within 21 days after active 

operations have ceased to 

maintain a stabilized surface for 

six months 

NA For operations that remain 

inactive for not more than 

four consecutive days

California, 

SCAQMD Rule 

403 12/11/1998

Unpaved Roads 

Requires annual treatment of 

unpaved public roads by 

implementing one of the following:

‒ Paving at least 1 mile with 

roadway material;

‒ Applying chemical stabilizers 

to at least 2 miles; and

‒ Installing signage at 

0.25-mile intervals limiting 

speed to 15 mph.

NA Set applicability standard: 

‒ unpaved road with 

more than 20 vehicle 

trips per day

California, 

SCAQMD 

Rule 1186 

9/10/1999 

Pave, apply dust palliative, or 

other

Complies with 

stabilization standard: 

limit visible dust 

emissions to 20% 

opacity, limit silt loading 

to 0.33 ounce per 

square foot, and limit 

silt content to 6% 

All unpaved roads with 

vehicular traffic 150 

vehicles or more per day 

Nevada, Clark 

County 

Hydrographic 

Basins 212, 216, 

217 Section 91 

Air Quality 

Regulation 

06/22/2000 
Chapter 3. Affected Environment and Environmental Consequences

3-14 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Year-round monitoring would be implemented to better characterize potential fugitive 

dust issues and determine the source (i.e., activities at the TDF, mining operations, 

vehicle emissions, or other). Monitoring programs are put in place to ensure efforts are 

being made to mitigate fugitive dust onsite. These efforts include record keeping of soil 

stabilization methods; dates and frequencies of hydroseeding tailings piles; times and 

date of watering; and establishment/maintenance of wind breaks. Site inspections and 

monitoring of the crust strength and erodibility should be documented and scheduled 

regularly as well. The TDF crust strength can be determined using drop ball tests, as well 

as observations of operational dust suppressant systems, and inspections of heights and 

porosities of wind breaks. 

3.2.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceased, 

disturbed sites were reclaimed, and human activity in the area reduced. The TDF would 

be built to the maximum footprint and height evaluated in the 2003 EIS (Forest Service 

2003). After the TDF is fully constructed in 2019, reclamation would begin as proposed 

under the currently approved reclamation plan. 

The average annual emissions for each decade following the implementation of 

Alternative A were assessed. The values presented in figures 3.2-4 and 3.2-5 reflect the 

assumption of full site stabilization (e.g., hydroseeding) of the TDF by 2020. This 

conservative assumption predicts zero fugitive dust emissions six years after reclamation 

begins in 2019. 

Figure 3.2-4. Alternative A Average Annual PM10 Emissions, Years 1–10. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-15 

Figure 3.2-5. Alternative A Average Annual PM2.5 Emissions, Years 1–10. 

3.2.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. The expanded TDF 

and associated infrastructure would add to fugitive and mobile emission sources during 

development beyond the impacts of Alternative A. The extended life of the mine would 

additionally increase the amount of fugitive dust from the TDF, emissions from 

stationary source emission units would remain the same under this alternative. 

Expansion of the TDF could also potentially result in localized impacts on visibility, 

vegetation, and soils in the immediate area as a result of fugitive dust. These effects 

would range from short term (visibility) to long term (soils). 

The average annual emissions for each decade following the implementation of 

Alternative B were assessed. The values summarized in figures 3.2-6 and 3.2-7 reflect 

the conservative assumption that the exposed surface area of the TDF would increase 

linearly with time over the projected 50-year extended life of the mine. 
Chapter 3. Affected Environment and Environmental Consequences

3-16 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.2-6. Alternative B Average Annual PM10 Emissions, Years 1–50. 

Figure 3.2-7. Alternative B Average Annual PM2.5 Emissions, Years 1–50. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-17 

3.2.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Admiralty Island National Monument (Monument). The result would be a new 

reclamation material storage area located near the junction of the A and B roads; moving 

the quarry out of the Monument would require deepening the quarry at the north end of 

the existing TDF. Enlarging the quarry rather than developing a new one south of the 

existing TDF would reduce the areal extent of fugitive dust sources although the 

activities conducted in the quarry(ies) including blasting, sorting and loading would result 

in similar overall levels of fugitive dust. Overall, impacts resulting from Mitigated 

Alternative B would be similar to Alternative B although with a slight reduction in the 

potential for deposition within the Monument. 

The average annual emissions for each decade following the implementation of Mitigated 

Alternative B were assessed. The values summarized in figures 3.2-8 and 3.2-9 reflect 

the assumption that the exposed surface area of the TDF would increase linearly with 

time over the projected 50-year extended life of the mine. 

Figure 3.2-8. Mitigated Alternative B Average Annual PM10 Emissions, Years 1–50. 
Chapter 3. Affected Environment and Environmental Consequences

3-18 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.2-9. Mitigated Alternative B Average Annual PM2.5 Emissions, Years 1–50. 

3.2.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve a 3-year expansion of the existing TDF, construction and 

operation of a new TDF and upgrading the A Road to handle haul truck traffic to the new 

TDF. Alternative C would extend the operating period of the mine by 30–50 years. 

Effects to ambient air quality would be more widely spread than in alternatives A and B 

due to the development of a new TDF. Development of new facilities would increase 

mobile, fugitive and construction-related air emissions. A quarry would be developed for 

the construction of the new TDF and road upgrades would add to fugitive and mobile air 

emissions. An increase in mobile, fugitive and construction produced air emissions 

would be expected for the duration of the construction of the new TDF, emissions from 

stationary source units would remain the same. Mobile source emissions would increase 

0.07 percent during operations. 

The average annual emissions for each decade following the implementation of 

Alternative C were assessed. The values summarized in figures 3.2-10 and 3.2-11 reflect 

the assumption that the exposed surface area of the TDF would increase linearly with 

time over the projected 50-year extended life of the mine. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-19 

Figure 3.2-10. Alternative C Average Annual PM10 Emissions, Years 1–50. 

Figure 3.2-11. Alternative C Average Annual PM2.5 Emissions, Years 1–50. 
Chapter 3. Affected Environment and Environmental Consequences

3-20 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.2.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve the expansion of the existing TDF and the construction of a 

new TDF. Like alternatives B and C, Alternative D would extend the operating period of 

the mine by 30–50 years. The expansion of the existing TDF would be substantially 

smaller than under Alternative B and larger than under Alternative C. Effects to ambient 

air quality would be similar to Alternative C. The air quality impacts of this alternative 

would be more widespread than alternatives A and B due to development of a new TDF. 

A quarry would be developed for the construction of the new TDF and road upgrade 

adding to dust and mobile air emissions. An increase in mobile, fugitive and 

construction-related air emissions are expected for the duration of the construction of the 

new TDF, emissions from stationary source units would remain the same under this 

alternative. Mobile source emissions would increase 0.07 percent during operations. 

The average annual emissions for each decade following the implementation of 

Alternative D were assessed. The values presented in figures 3.2-12 and 3.2-13 reflect 

the conservative assumption that the exposed surface area of the TDF will increase 

linearly with time over the projected 50-year extended life of the mine. 

Figure 3.2-12. Alternative D Average Annual PM10 Emissions, Years 1–50. 
3.2 Air Quality 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-21 

Figure 3.2-13. Alternative D Average Annual PM2.5 Emissions Years, 1–50. 

3.2.4 Air Quality – Summary 

Under all alternatives, air emissions would continue from mining and support operations 

until reclamation had been completed. Air emission sources associated with the mine 

include combustion related emission sources including mobile equipment like trucks and 

other heavy equipment and non-combustion sources including fugitive dust generated by 

road traffic and wind. Under Alternative A fugitive dust emissions and mobile source 

emissions would be minimized after closure in 2019. Using minimal control techniques, 

the total uncontrolled PM10 emissions under Alternative A from fugitive emissions due to 

the TDF expansion and haul road extensions could reach 159 tpy by 2019 while the 

uncontrolled PM2.5 emissions could reach 17 tpy. Using existing control efforts, the 

controlled PM10 and PM2.5 emissions would be 86 and 9 tpy respectively. 

Under Alternative B, fugitive dust and mobile emissions would increase over the 

extended life of the mine. The expanded TDF and associated infrastructure would add to 

fugitive and mobile emission sources during development beyond the impacts of 

Alternative A. Using minimal control techniques, the total uncontrolled PM10 emissions 

under Alternative B from fugitive emissions due to the TDF expansion and haul road 

extensions could reach 193 tpy by 2062 while the uncontrolled PM2.5 emissions could 

reach 22 tpy. Using existing control efforts, the controlled PM10 and PM2.5 emissions 

would be 102 and 12 tpy respectively. 

Under Mitigated Alternative B, fugitive dust and mobile emissions would increase over 

the extended life of the mine. The expanded TDF and associated infrastructure would 

add to fugitive and mobile emission sources during development beyond the impacts of 

Alternative A. Using minimal control techniques, the total uncontrolled PM10 emissions 

under Alternative B from fugitive emissions due to the TDF expansion and haul road 

extensions could reach 186 tpy by 2062 while the uncontrolled PM2.5 emissions could 
Chapter 3. Affected Environment and Environmental Consequences

3-22 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

reach 21 tpy. Using existing control efforts, the controlled PM10 and PM2.5 emissions 

would be 98 and 11 tpy respectively. 

Under Alternative C, effects to ambient air quality would be more widespread than in 

alternatives A and B due to the development of a new TDF to the north. Development of 

new facilities would increase mobile, fugitive and construction-related air emissions. A 

quarry would be developed for the construction of the new TDF adding to fugitive and 

mobile air emissions. Using minimal control techniques, the total uncontrolled PM10

emissions under Alternative C from fugitive emissions due to the TDF expansion and 

haul road extensions could reach 263 tpy by 2062 while the uncontrolled PM2.5 emissions 

could reach 30 tpy. Using existing control efforts, the controlled PM10 and PM2.5 

emissions would be 138 and 16 tpy respectively. 

Under Alternative D effects to ambient air quality would be similar to Alternative C in 

that both alternates would create more widespread impacts to air quality as a direct result 

of the development of the new TDF. The air quality impacts of this alternative would be 

more widespread than alternatives A and B due to development of a new TDF. Using 

minimal control techniques, the total uncontrolled PM10 emissions under Alternative D 

from fugitive emissions due to the TDF expansion and haul road extensions could reach 

274 tpy by 2062 while the uncontrolled PM2.5 emissions could reach 32 tpy. Using 

existing control efforts, the controlled PM10 and PM2.5 emissions would be 143 and 16 tpy 

respectively. 

Limited monitoring of snow and lichens has shown metals deposition adjacent and at 

distance from the TDF. Additional monitoring and development of a mitigation plan will 

be required to better characterize the source, extent, and nature of the contamination and 

determine the need for additional mitigation measures. Mitigation measures are listed in 

Section 3.2.3.1.

3.3 Geotechnical Stability ________________________ 

3.3.1 Geotechnical Stability – Pre-mining Environment 

This section briefly describes the local stratigraphy 

and seismicity at the mine site to establish a baseline 

for the geotechnical conditions that may affect 

stability of the TDF alternatives. The local 

stratigraphy generally consists of peat followed by 

various thicknesses and combinations of gravel, 

sand, silt, and clay. These sediments were deposited 

as a result of marine, fluvial, and glacial processes. 

Till and other sedimentary materials are underlain by 

metamorphic bedrock, typically schist, phyllite, 

and/or argillite. The depth to bedrock varies greatly 

in the area. In some places, bedrock is present at or 

near the ground surface, but in other areas may be covered by more than 100 feet of peat, 

sand, silt, and till. Depth to bedrock is generally assumed to be quite shallow on steep 

slopes. 

The resource analysis of 

geotechnical stability does not 

have any issues directly tied to 

significant issues. There are no 

specific measures to address the 

significant issues; the analysis in 

this section addresses the longterm geotechnical stability of the 

TDF. 
3.3 Geotechnical Stability 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-23 

Greens Creek Mine is located in a region of moderate to high seismicity, and is within 

regional proximity to the active Fairweather-Queen Charlotte Fault, potentially active 

portions of the Denali Fault, and the Chatham Strait Fault, which is generally not 

considered active. A site-specific hazard analysis was performed in 1998 by Klohn 

Crippen. Based on regional active faults and other potential sources zones, this study 

recommended a maximum design earthquake peak ground acceleration of 0.3 g 

(gravitational force) and a design basis earthquake peak ground acceleration of 0.15 g for 

the site to ensure an adequate level of geotechnical stability. 

3.3.2 Geotechnical Stability – Baseline Conditions 

Overall stability of the TDF was addressed by Klohn Crippen in 2004 and 2005. These 

analyses were conducted for five critical locations, and addressed the potential for failure 

in the tailings, foundation soils, and along the liner. Klohn Crippen design criteria 

required a minimum factor of safety against slope instability of 1.5 for static long-term 

conditions, and a minimum factor of safety of 1.3 for static short-term conditions. 

Stability modeling included the results of Klohn Crippen’s 2004/2005 field investigation 

and laboratory testing program, and re-analyzed laboratory data from previous 

investigations. In addition, Klohn Crippen’s laboratory testing program included 

interface strength testing on the geosynthetics used for the liner materials. Peak and 

residual strengths for the liner materials were used in the models, as well as water levels 

established according to piezometer readings from within the tailings and beneath the 

underdrainage system. 

In general, stability analyses through the foundation materials indicated the pile was 

stable under normal operating conditions. However, the stability analyses performed 

using residual liner strengths resulted in a minimum factor of safety below 1.5, and 

inclusion of a small toe berm at the base of the tailings was recommended by Klohn 

Crippen. A safety factor above 1 is an indication of geotechnical stability and below 1 

indicates a potential for instability under certain conditions. Engineers attempt to design 

facilities with safety factors well above 1 to assure geotechnically stable conditions. 

Pseudo-static seismic deformation predictions were also shown to be substantially 

improved by emplacement of a berm at the toe of the pile. 

Klohn Crippen performed a sensitivity analysis to determine if higher groundwater levels 

or a higher phreatic surface (water pressures) would cause instability in the TDF. They 

determined that the phreatic surface would need to be much higher than the current 

groundwater levels to reduce the factor of safety from 1.3 to 1.1 or to potentially affect 

TDF stability. 

Ground response analyses conducted by Klohn Crippen Berger, and summarized in their 

2007 draft report, indicated liquefaction is not a concern at the facility. 
Chapter 3. Affected Environment and Environmental Consequences

3-24 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.3.3 Geotechnical Stability – Environmental 

Consequences 

3.3.3.1 Effects Common to All Alternatives 

TDF Stability 

Stability analyses of the TDF for all alternatives were conducted using the Slope/W 

component of GeoStudio 2007. Slope/W was used to conduct limiting equilibrium 

analyses using the general limit equilibrium method, which satisfies both force and 

moment equilibrium. The Slope/W program incorporates a search routine to locate those 

failure surfaces with the least factor of safety within user-defined search limits. Trial 

failure surfaces were defined with “entry and exit” parameters, resulting in a range of 

possible locations within which the most critical (lowest factor of safety) potential failure 

surface may be found. 

Preliminary stability analyses for the alternatives were modeled using the material 

properties and design criteria established by Klohn Crippen in their 2004/2005 reports. 

These initial analyses indicate that the tailings and foundation materials are likely to be 

stable, assuming conditions are similar for all alternatives. However, the potential exists 

for instability on natural slopes of 40 percent (2.5 horizontal units to 1 vertical unit) or 

steeper, and tailings placed adjacent to these slopes may be impacted by minor quantities 

of sloughing materials. These stability analyses did not include a study of consolidation 

in peat layers or soft clays that may be present in the alternative locations, nor did they 

include pseudo-static analyses. 

Stability of TDF Engineered Cover 

Maintaining the physical integrity of the barrier layer is the key to maintaining the critical 

hydrologic functions of the engineered closure cover (OSU 2010). The stability of the 

engineered cover was modeled independently of the main TDF, also using Slope/W. The 

hydraulic conductivity and relative saturation design criteria for the barrier layer may not 

be met if inadequate compaction of the barrier layer, slope failure, or tree wind throw 

were to lead to differential settling, slumping, erosion or exposure of the barrier layer to 

freeze/thaw or wetting/drying cycles. If fractures develop in the barrier layer, roots could 

penetrate through the resulting fracture planes. This could lead to increased flux of 

precipitation and oxygen through the engineered closure cover and into the TDF. The 

effects of increased flux of water and oxygen in the stability of the TDF would not be 

sufficient to result in geotechnical concerns; however, the implications of breaching the 

cover in terms of geochemistry are discussed in Section 3.4.3. 

Four scenarios were modeled to evaluate the geotechnical stability of the engineered 

closure cover under different seismic loading conditions and saturation levels. The TDF 

would be under the jurisdiction of the ADEC regulations for solid waste management 

(18 AAC 60, dated April 8, 2012). However, these regulations do not require specific 

factors of safety. In the absence of specific safety factor guidelines applicable to the 

construction of dry tailings disposal facilities in Alaska, values typical for similar 

facilities (e.g., Nevada Division of Water Resources recommendations for heap leach 

facilities) were adopted for the TDF (Table 3.3-1). 
3.3 Geotechnical Stability 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-25 

Table 3.3-1. Minimum Safety Factors for Slope Stability Analyses. 

Design Condition Minimum Factor of Safety 

End of Construction; Static Loading (normal conditions) 1.3 

End of Construction; Pseudo-Static Loading (earthquake) 1.05 

It should be noted that, as it relates to slope stability, the safety factor is a ratio 

representing the relationship between forces that will drive slope movement, versus 

forces that will resist slope movement. These forces depend on several site-specific 

factors including, but not limited to, design geometry, material properties and pore-water 

pressure conditions. The factor of safety itself, however, is calculated in the same 

manner regardless of location. Location can impact the selection of a minimum factor of 

safety for regulatory purposes, as this becomes a question of acceptable risk for a specific 

site. However, as stated previously, the ADEC regulations do not provide safety factor 

guidelines that may be applied to the TDF; the typical values provided in Table 3.3-1 are 

therefore considered to be appropriate as a screening tool for the proposed alternatives. 

These design criteria were used to evaluate the following slope stability scenarios: 

1. Static Conditions, Average Pore Pressure Conditions; 

2. Pseudo-Static Conditions, Average Pore Pressure Conditions; 

3. Static Conditions, Storm Event Pore Pressure Conditions; and 

4. Static Conditions, Storm Event, Forced Failure Surface at Cover and Tailings 

Interface. 

The results of the analyses indicate that the cover is stable under the design conditions, 

and exceeds the minimum factors of safety provided in Table 3.3-1. These results 

indicate that for the conditions modeled the engineered cover is stable as designed. 

Table 3.3-2 shown the results of the analyses compared to the minimum State of Nevada 

factor of safety. Under all alternatives, a stable dry stack (or stacks) can be built using 

standard engineering practices. Under these conditions, slope failures are not anticipated. 

Table 3.3-2. Summary of Factors of Safety for TDF Cover Stability. 

Seismic Loading 

Condition 

Pore Water Pressure 

Conditions 

Minimum 

Factor of 

Safety 

Factor of 

Safety 

Static Average Climate Year 1.3 3.2 

Pseudo-Static Average Climate Year 1.05 1.7 

Static Storm Event 1.3 3.2 

Static Storm Event 1.3 22.1* 

* Failure Surface Forced at Cover and Tailings Interface. 
Chapter 3. Affected Environment and Environmental Consequences

3-26 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Monitoring and Mitigation 

Changes in predicted water levels and pore pressures within the TDF(s) may change 

stability parameters over the life of the project. Therefore, the Forest Service and ADEC 

will require monitoring of the TDF(s) under all alternatives over the life of the project so 

that any changes to the anticipated conditions within the facilities can be addressed by 

design modifications necessary to maintain the target factor of safety. 

3.3.3.2 Effects of Alternative A, No Action 

Under Alternative A, the TDF is stable under current conditions. As discussed in Section 

3.3.2, a rise in the phreatic surface within the TDF could result in an unstable condition. 

Assuming the phreatic levels remain the same, the pile is expected to remain stable. 

Higher levels are not expected to develop in the future. 

3.3.3.3 Effects of Alternative B, Proposed Action 

Analyses performed for the proposed action indicate the required factors of safety would 

continue to be met (Klohn Crippen Berger 2011). However, as discussed in Section 

3.3.3.1, natural slopes greater than 2.5 horizontal units to 1 vertical unit may experience 

some sloughing, and tailings placed adjacent to these slopes may be slightly impacted. 

3.3.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Analyses 

performed for Alternative B apply to Mitigated Alternative B and indicate the required 

factors of safety would continue to be met (Klohn Crippen Berger 2011). However, as 

discussed in Section 3.3.3.1, natural slopes greater than 2.5 horizontal units to 1 vertical 

unit may experience some sloughing, and tailings placed adjacent to these slopes may be 

slightly impacted. 

3.3.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Two sections through the maximum TDF height were analyzed for the new TDF under 

Alternative C, one from the northwest to the southeast, and one perpendicular to the slope 

along the north-northeast edge of the alternative pile, oriented northeast-southwest. The 

analyses assumed a lined pile and similar geology and pore pressure conditions to the 

existing TDF. The results indicated that Alternative C can be expected to behave 

similarly to the existing TDF. As with the slopes to the east of the existing TDF, the 

upper natural slopes to the north-northeast of the site have the potential for minor 

sloughing. Room to accommodate some sloughed materials between the slope and the 

TDF is included in the layout, though further analyses would be required at later design 

stages. If native materials from the upper slopes do accumulate on the TDF edge, some 

clean up and maintenance may be necessary. However, this potential accumulation is not 

expected to cause major damage to the TDF or final cover. 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-27 

3.3.3.6 Effects of Alternative D, Modified Proposed Action 

Analyses performed for Alternative D indicate the required factors of safety would 

continue to be met at both facilities. 

3.3.4 Geotechnical Stability – Summary 

Slope stability is not expected to pose a credible risk to the current expansion 

alternatives. While consolidation of peat and/or clay, earthquake induced accelerations, 

pile pore pressures, and proximity to potentially unstable native slopes are aspects of the 

expansion that require due consideration and design, they are not insurmountable or 

substantially different for the alternatives discussed, based on the current analyses. 

However, it should be noted that these results are conceptual-level designs (as opposed to 

construction drawings) and based on several simplifying assumptions. 

3.4 Geochemistry ______________________________ 

3.4.1 Geochemistry – Pre-Mining Environment 

Surface geochemistry is largely the result of the bedrock geology in an area. The 

fundamental geology associated with the pre-mining environment is described in detail in 

the 2003 EIS. The pre-mining environment did not include any appreciable occurrences 

of sulfide minerals such as pyrite (FeS2), sphalerite (ZnS), or galena (PbS) that are 

associated with the Greens Creek ore deposit and tailings as they are unstable at surface 

conditions and degrade if exposed. Other minerals associated with the deposit may have 

been present, as they are relatively stable. These minerals would include dolomite and 

calcite (carbonates) and a host of generally unreactive silicate minerals. 

The inferred relative absence of sulfide minerals present at the surface in the pre-mining 

environment is supported by negligible chemical loading to surface or groundwater. The 

chemical quality of water in the pre-mining environment would have been controlled 

more by precipitation interacting with organic material on the forest floor and limited 

interaction with relatively unreactive bedrock minerals. 

3.4.2 Geochemistry – Existing Conditions 

Since the 2003 EIS, tailings have been added to the TDF. The overall footprint has 

increased, as has the total mass of tailings. 

The driving geochemical consideration at the Greens Creek Mine is the water quality 

associated with tailings. Some of this water is process water entrained in tailings when 

they leave the mill and some is affected by the result of weathering reactions that occur 

after placement. Water discharged from the TDF can be described as contact water, 

which is the result of combining process waters and meteoric precipitation with the 

products of weathering reactions. 

Since the 2003 EIS for the Greens Creek Mine, mineral processing has remained 

essentially unchanged, the geochemical characteristics of tailings to the present are, 

therefore, expected to be essentially unchanged. The geochemical characteristics of 

Greens Creek Mine tailings are thoroughly presented in the 2003 EIS, and are 

summarized here with more recent information. 
Chapter 3. Affected Environment and Environmental Consequences

3-28 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The Greens Creek Mine tailings are silt-sized and 

composed primarily of pyrite, dolomite, quartz, and 

barite. Tailings composition was reported by Lindsay 

and Blowes (2011) for an average of 12 samples. Ten 

of these samples were taken from several depths (0.5–

2.5 meters) within test cells studied by Lindsay (2009) 

and are estimated to have been produced in the 2000s. 

Two of the remaining four samples were from the 

mid-1990s and two were fresh from the mill in 2004. 

The field samples were collected from four boreholes 

located along a west to east transect and one 

additional location at the southwest corner of the 

tailings facility. The mineral composition of the 

tailings by percent weight reported by Lindsay (2009) 

is listed in Table 3.4-1. The standard deviation for 

each mineral is relatively small. Within this 

assortment of minerals the ratio between pyrite and dolomite drive the overall leachate 

geochemistry and the potential to generate acidic drainage and release chemical 

constituents of concern. 

Table 3.4-1. Tailings Mineral Composition by Weight. 

Mineral Type Chemical Formula Percent by Weight (%) Standard Deviation 

pyrite FeS2 34.3 4.3 

dolomite CaMg(CO3)2 27.2 3.0 

quartz SiO2 12.1 3.6 

barite BaSO4 12.3 3.8 

muscovite KAl2AlSi3O10(OH)2 3.8 2.5 

calcite CaCO3 3.4 0.8 

sphalerite Zn,FeS 2.5 1.0 

cymrite BaAl2Si2(O,OH)8·H2O 2.1 0.6 

K-feldspar KAlSi3O8 1.5 0.6 

chlorite (Mg,Fe)5Al(Si3Al)O10(OH)8 1.5 0.4 

hydroxylapatite Ca5(PO4)3(OH) 1.2 0.3 

galena PbS 0.7 0.2 

 

The tailings associated with the Greens Creek Mine have a net capacity to produce acidic 

drainage known as acid rock drainage (ARD). That is, the capacity to generate acidity 

through the oxidation of pyrite exceeds the capacity to neutralize it. ARD is an acidic 

(low pH) iron sulfate solution containing various trace metals that is produced by the 

geochemical weathering (oxidation) of sulfide minerals, primarily pyrite. If carbonate 

minerals (e.g., calcite, dolomite) are present with pyrite, the acidity associated with ARD 

can be neutralized, and iron, trace metal and sulfate concentrations lowered. But even 

with neutralization, chemical contaminants can still be released, but at far lower 

concentrations than those associated with ARD. 

The resource analysis of 

geochemistry is related to 

Issue 1, water quality and longterm geochemical stability of 

tailings. Measurements of 

geochemical impacts include 

the ability to meet Alaska 

Water Quality Standards 

(WQS) by designing the TDF to 

reduce the rate of geochemical 

reactions within the tailings 

pile. 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-29 

Figure 3.4-1 (amended version of Lindsay and Blowes 2011, Figure 5.6) is a graph of the 

acid generating potential of tailings versus the acid neutralizing potential of tailings. The 

top graph in Figure 3.4-1 shows acid-base accounting data from 1990-2004 and data 

initially measured by Lindsay and Blowes (2011; labeled as Current Study) and the lower 

graph in Figure 3.4-1 shows the data of Lindsay and Blowes (2011) shown in (a) as well 

as their recalculated data from 2002–2004 that more accurately represent the acid 

potential. The dashed box in (b) corresponds to the range of data in (a) for the years 

1990-2004 and data presented in the figure span ages from 1990 to 2008 and provide a 

representation of the variability of the acid-base balance in Greens Creek tailings. The 

acid-base accounting data from 1994 (Condon 1995) was obtained from 15 borings 

within the tailings, distributed to cover the entire pile. Acid-base accounting samples 

were prepared by compositing over the length of the core obtained, which penetrated the 

thickness for the pile. The 2008 (Lindsay and Blowes 2011; labeled as Current Study) 

data were produced from samples taken from four borings transecting the pile east-west 

and one boring at the southern margin of the pile. Together, these samples should be 

considered representative of the acid-base accounting characteristics of tailings. 

Although variable, there is no apparent trend in composition over time. Any points that 

plot above the sloping line that represents an equal balance of acid generating potential 

and acid neutralizing potential are interpreted as having a net capacity to generate ARD, 

as acid generating potential exceeds acid neutralizing potential for these data points. All 

samples that have been taken of Greens Creek Mine tailings are net acid generating. 

The co-disposal of waste rock with tailings in the TDF could affect the overall acid-base 

balance of the pile. This is because waste rock has only 75 percent of the acid 

neutralizing capacity of tailings. However, the relatively large size of waste rock relative 

to tailings will mitigate any broad changes in expected acid-base accounting generation 

because large particles react more slowly than the small tailings particles. Because codisposed waste rock will be placed within the tailings, where oxygen is restricted, the 

overall effects on acid-base chemistry of the tailings facility can be anticipated to be 

negligible. 

Although tailings are shown to have a net capacity to generate ARD, the rates at which 

geochemical weathering reactions occur control eventual water quality of tailings pore 

water and tailings drainage. Pyrite will be oxidized at rates dictated by site conditions. 

This oxidation will only occur at locations that provide ample water and oxygen. In the 

pile, only tailings that are located near the outer surface are exposed to abundant oxygen 

and it is only at these locations that pyrite oxidation is supported. At depth, the tightly 

packed small tailings grains retard availability of oxygen. Thus, pyrite oxidation can be 

anticipated to be only a localized occurrence and not widespread throughout the entire 

pile at any given time. The resulting localized acidity will be neutralized until carbonate 

minerals are consumed. At that point, acid neutralization is consumed and ARD may 

form in these localized areas. The key to this sequence is the rate of pyrite oxidation. 

The rate at which pyrite oxidizes is related to its grain size (reactive surface area), 

available oxygen, water, and temperature. Grain size remains essentially constant for 

Greens Creek Mine tailings and water is present in excess of that required by the 

oxidation reaction. Pyrite oxidation generates heat. Because there is limited observed 

pyrite oxidation in the TDF, the internal temperature is expected to stay cool and 

approximately the annual average temperature of the project site. 
Chapter 3. Affected Environment and Environmental Consequences

3-30 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Source: Lindsay and Blowes 2011. 

Figure 3.4-1. Acid-base Accounting of Greens Creek Tailings. 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-31 

Ultimately, the rate of oxidation of Greens Creek Mine tailings has been and will 

continue to be driven by the rate at which oxygen can be supplied to tailings in the pile. 

Information is available to predict the oxidation of pyrite in Greens Creek Mine tailings 

from several sources, all with varying degrees of oxygen availability. 

The oxidation of Greens Creek Mine tailings: 

 has been measured using bench scale laboratory tests; 

 has been measured in field test plots; 

 calculated using empirically determined rate equations; and 

 can be estimated for post-closure scenarios. 

Laboratory testing of Greens Creek Mine tailings has been conducted using humidity cell 

testing. This style of testing is conducted in a column where the tailings are exposed to 

moist oxygenated air for three days, followed by exposure to dry oxygenated air for three 

days, concluding with a full rinse on the seventh day. The test is then repeated for as 

many weeks as desired to observe changes in the release of soluble constituents over 

time. The rate of oxidation is expressed as milligrams (mg) of sulfate (product of pyrite 

oxidation) released per kilogram (kg) of tailings per week. The humidity cell testing 

protocol supplies excess water and oxygen to enable the most rapid reaction rates. Other 

than the pyrite oxidation component, which is well understood within the Greens Creek 

Mine setting (see below), the specific rate of reaction may be variable, depending upon 

the geochemical reactions occurring in the test apparatus. 

The rate of sulfate release for Greens Creek Mine tailings, for a single sample taken in 

1990 (Vos 1990), through an 18-month study changed from a high of 374 mg/kg/week 

for the first 6 months to 37 mg/kg/week for the next six months, decreasing to 25 

mg/kg/week the final six months (Vos 1990). In the 2003 EIS, the diminishing rate was 

attributed to a combination of sulfate release caused by the dissolution of gypsum which 

formed from previous oxidation reactions; and because oxidation of pyrite particles forms 

a shrinking core over time. A shrinking core can be described as a progressively 

shrinking unoxidized sulfide mineral core that is surrounded by an ever-growing oxidized 

rind (layer) that restricts or reduces pyrite oxidation in the center. A second sample of 

tailings was submitted for humidity cell testing work in 2009. Although it differed in the 

beginning and the ultimate measured concentrations, the trend of the sulfate release rate 

for this sample was similar to that observed for the 1990 sample (see Table 3.4-2). 

Table 3.4-2. Pyrite Oxidation Estimates for Greens Creek Tailings. 

Source 

Early Rate 

mg/kg/week 

Long-Term Rate 

mg/kg/week 

1990 Greens Creek HCT (Vos 1990) 374 25 

2009 Greens Creek HCT 529 233 

2010 Sulfate Reduction Monitoring Program No data 9.6 

Laboratory Rate 200 200 

Note: HCT= humidity cell test. 
Chapter 3. Affected Environment and Environmental Consequences

3-32 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The rate of pyrite oxidation of tailings in field test plots has also been measured (Lindsay 

and Blowes 2011). These measurements were made as part of a study to assess the 

effects of amending tailings with organic material to support biological sulfate reduction 

as a mechanism to attenuate chemical constituents of concern in tailings pore water. For 

these field test plots, the pyrite oxidation rate was estimated using measurements of easily 

leachable iron, which is one product from the oxidation of pyrite. As presented in Petros 

(2011), easily leachable iron was present at concentrations of approximately 1,500 

mg/kg. This mass was accumulated over a four-year time span and correlates to a pyrite 

oxidation rate of 9.6 mg/kg/week. 

Laboratory rate equations have also been established for oxidation of pyrite (Williamson 

and Rimstidt 1994) and these rate equations have been used to estimate rates of Greens 

Creek tailings. These equations incorporate grain size, oxygen dissolved in contact 

water, and pH and yield an anticipated rate of pyrite oxidation of 200 mg/kg/week. This 

calculation (assuming general conditions of water saturated with dissolved oxygen, a pH 

of 7, with an average grain size for Greens Creek tailings and a temperature of 25 degrees 

centigrade) provides a simple gauge of measured lab rates from humidity cell tests and 

indicates that the rates observed are consistent with theoretical expectations. Measured 

rates are slightly higher than the calculated rate and are attributed to variability in grain 

size as well as the documented variation of sulfide content in tailings. The difference 

between lab/theoretical estimates of rate and those determined in field test plots is related 

to limited availability of oxygen at depth in tailings. 

The summary of the results of estimates of pyrite oxidation for Greens Creek Mine 

tailings is presented in Table 3.4-2. The rate of oxidation in humidity cell tests and for 

the laboratory rate equations, where oxygen is not limited, are comparable, although the 

1990 long-term rate is much slower than the 2009 results. This difference may be due to 

differences in sulfide sulfur content. However, the most significant finding is that the 

oxidation rate measured in the field test plots is appreciably lower. This is because the 

ingress of oxygen is limited at depth within the tailings (see Table 3.4-2). 

Humidity cell testing in 1993 and 1994 (reported in 2003 EIS) concluded, “Static testing 

of tailings from the Greens Creek deposit (Figure 3-15) indicates that they have the 

potential to become acidic. However, owing to the abundance of calcium carbonate and 

dolomite in the samples (generally ranging from 10 to 60 percent), a long period of 

weathering, estimated at more than 10 to 33 years in lab tests conducted on siliceous 

waste rock samples, would have to occur prior to development of acidic conditions.” 

Products of pyrite oxidation have been observed in limited and restricted acidic seeps 

associated with the tailings immediately before and since the 2003 EIS. This observation 

is consistent with the projected delay time of 10 to 33 years for the potential onset of 

ARD in areas where unlimited water and oxygen were available for a substantial period 

of time. 

3.4.2.1 Solutions Associated with Tailings 

The fine-grained, silt-sized nature of Greens Creek Mine tailings greatly restricts the 

infiltration of incident precipitation. Thus, the time required to replace a pore volume of 

water within the tailings is substantial. Petros (2011) reports an estimated time of 80 

years for an average pile thickness of 150 feet. Very slow movement of water in the TDF 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-33 

means that water quality will change very slowly. This time estimate is consistent with 

earlier estimates made during the 2003 EIS. 

Despite the relatively slow rate of infiltration, the tailings contain several aqueous 

solutions that are discharged ultimately to wet wells associated with the tailings facility 

(see Section 3.5.2.2). Solutions associated with the tailings include the following: 

 Near surface seeps; 

 Deeper seated unsaturated portions of the tailings; and 

 Saturated tailings. 

The near surface seeps are characteristic of water that results from the oxidation of pyrite 

that is neutralized by carbonate minerals (e.g., dolomite and calcium-magnesium 

carbonate) and has relatively elevated concentrations of several trace metals. The 

solution associated with the unsaturated portion of the tailings contains lower 

concentrations of metals than the surface seeps, but shows a similarity with near-surface 

solutions. The interpretation is that these neutralized solutions started near the surface 

and have percolated to lower depths within the pile. In moving deeper into the pile, they 

experienced attenuation of some constituents in response to the chemically reducing 

conditions that exist with increasing depth within the pile. The deepest portions of the 

tailings are saturated. The chemical composition of this zone is consistent with, although 

not identical to, the zones above it. This lack of interaction is reasonable, as the 

reactivity (oxidation) of pyrite and other sulfide minerals is negligible because saturated 

conditions exclude oxygen. A comparison of the chemical composition of solutions 

associated with the tailings impoundment in presented in Table 3.4-3 (Condon 2012). 

3.4.2.2 Sulfate Reduction Monitoring Program 

The 2003 Greens Creek EIS concluded that there was merit to conducting an 

investigation into the potential benefit of amending tailings with organic additives to 

facilitate microbially mediated sulfate reduction. This chemical reduction of sulfate 

results in the production of sulfide, which forms very low solubility compounds with 

metals such as zinc. Thus, from 2004 through 2010, Greens Creek conducted a study in 

conjunction with the University of Waterloo (Ontario, Canada) to prepare and monitor 

several test plots constructed in the field. Trials evaluated several organic amendments 

where the geochemical evolution of associated solutions (and solids) was monitored. 

As expected, the addition of organic amendments resulted in sulfate reduction, with the 

attendant decrease in sulfate concentrations as well as a decrease in sulfide mineral 

forming metals (e.g., zinc). These metals react with the sulfide produced by sulfate 

reduction to precipitate metal sulfide solids and remove the metal from solution. The 

decrease in zinc concentration in solution was appreciable, resulting in a representative 

concentration of 0.2 mg/L compared with 33.5 and 1.52 mg/L in near surface seep 

solutions and solutions associated with the unsaturated portion of the tailings, 

respectively (see Table 3.4-3). 
Chapter 3. Affected Environment and Environmental Consequences

3-34 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.4-3. Chemical Composition of Solutions Associated with Greens Creek Tailings. 

Constituent Unit 

Near Surface Seep Reduced Unsaturated Zone Saturated Zone 

Average 

Standard 

Deviation Average 

Standard 

Deviation Average 

Standard 

Deviation 

Alkalinity mg/l 209 13 403 68 287 46 

Field Conductivity μS/cm 3150 573 3833 423 4107 601 

Field pH su 6.9 0.17 7.3 0.2 7.9 0.4 

Total dissolved 

solids 

mg/l 2943 850 3258 360 3609 655 

SO4 mg/l 2067 371 2230 425 2419 531 

Ca mg/l 532 22 522 56 190 41 

Mg mg/l 241 108 185 62 424 96 

Hardness mg/l 2500 536 2062 299 2331 435 

Na mg/l 22 13 309 122 226 72 

K mg/l 17 12 19 4 45 12 

Cl mg/l 10 4 10 6 28 6 

Al mg/l 0.025 NA No measurements NA 0.10 0.14 

Ag mg/l 0.0001 NA 0.0008 0.0011 0.002 NA 

As mg/l 0.0542 0.0761 0.0800 0.0779 0.008 0.007 

Ba mg/l 0.0071 NA 0.0062 0.0002 0.0152 0.0061 

Cd mg/l 0.0066 0.0053 0.0015 0.0021 0.0001 NA 

Cu mg/l 0.0013 0.0005 0.0074 0.0054 0.0037 0.0018 

Cr IIII mg/l 0.0022 0.0025 0.0047 0.0060 0.0021 0.0021 

Fe mg/l 16.6 18.6 8.1 4.4 2.2 NA 

Hg mg/l 0.00020 NA 0.0000002 NA 0.0000002 NA 

Mn mg/l 5.5 4.5 0.21 0.06 0.25 0.19 

Mo mg/l 0.0028 NA 0.0086 0.0023 0.134 0.281 

Ni mg/l 0.4490 0.1870 0.0217 0.0041 0.0064 0.0027 

Pb mg/l 0.0100 0.0114 0.0027 0.0022 0.0006 0.0005 

Se mg/l 0.00827 NA 0.0053 0.0045 0.043 0.119 

Sb mg/l 0.0033 NA 0.0009 0.0005 0.031 0.039 

Zn mg/l 23.6 11.2 1.5 0.8 0.0100 0.0081 

Note: For each water type presented, several constituents were either always undetected, or had less than 

about 10 percent detectable concentrations. For constituents always undetected, the lowest reported 

detection limit value is shown in underlined italics. For constituents with few detections, the highest 

observed concentration is shown in italics. NA = not applicable; the constituent was undetected. 

However, the addition of organic amendments produced some adverse effects in terms of 

water quality. Samples collected from trials showed an increase in arsenic 

concentrations. The increase in arsenic concentrations was interpreted as being caused 

by the dissolution of arsenic-containing iron oxyhydroxides in the chemically reducing 

environment. The iron oxyhydroxides would have formed during the previous 

weathering of the waste rock. A chemically reducing environment is created when 

sulfate reducing bacteria consume the organic amendments. Under these conditions, the 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-35 

iron oxyhydroxides dissolve, releasing absorbed arsenic. For this reason, Lindsay and 

Blowes (2011) conclude that establishing sulfate reduction is not recommended for 

weathered tailings at the Greens Creek Mine. 

3.4.3 Geochemistry – Environmental Consequences 

Water quality changes within the tailings pile and in water seeping or discharging from 

the tailings pile are the most obvious manifestation of geochemical effects. Since 

preparation of the 2003 EIS for the Greens Creek Mine (Forest Service 2003), 

observations of water quality, water balance, and flow characteristics in the tailings pile 

have improved the understanding of the relationships among geochemistry, water quality, 

and fate (chemical changes) and transport in the Greens Creek TDF as discussed above. 

As a result, the proponent has created a new conceptual and numerical model, which is 

consistent with these observations and data (Petros 2011). The model estimates the 

weathering of placed tailings, geochemistry, and effluent quality that could be expected 

over time. This initial model was created with the intent of continuously updating it and 

recalibrating it using observed site data obtained in future years. A recommended 

mitigation measure is to regularly update and recalibrate the model so that predictions of 

effluent quality and TDF geochemical behavior can be refined and improved as time 

progresses. 

3.4.3.1 Effects Common to All Alternatives 

The closure plan for all the TDF alternatives at Greens Creek prescribes an engineered 

soil cover specifically designed to reduce available oxygen below the cover in the 

tailings. The cover is primarily designed to prevent diffusion of oxygen in a vapor state 

into the tailings. The water-saturated layer incorporated into the proposed cover design is 

intended to limit the flux of oxygen into tailings to that which can be dissolved in water 

and infiltrated. Ultimately, the rate of water flux through the cover at closure would 

determine the rate of oxygen ingress to tailings, which in turn would dictate the rate of 

pyrite oxidation. 

Petros (2011) used the designed flux rate of water through the engineered cover with a 

dissolved oxygen content of 12 mg/L to calculate the rate of pyrite oxidation and 

carbonate mineral depletion in the TDF. At the conditions of limited oxygen supply, 

approximately 1,000 years would be required to deliver enough oxygen to oxidize the 

pyrite contained in a 0.4-inch thick layer of tailings. Approximately 300 years would be 

required to consume the acid-neutralizing carbonate minerals in the same size layer. 

These calculated times are a minimum time, as they assume complete and rapid reaction 

of all oxygen that reports to tailings under the reclamation cover. In reality, the oxidation 

of pyrite is likely to be slower as the oxidation rate would slow as ferrous iron (Fe2+, 

released from the oxidation of pyrite) would likely also compete for oxygen to form ferric 

iron (Fe3+). Further, this ferric iron would precipitate at the neutral pH conditions 

maintained by the available carbonate minerals and coat existing pyrite. The ferric 

coating would be expected to further depress the rate of oxidation. Hence, timeframes 

required to oxidize pyrite, and subsequently consume acid-neutralizing carbonates, are 

expected to be very long. Because of the sluggish rate of pyrite oxidation, it is unlikely 

that ARD would form in the entire TDF at any given time. Rather, ARD products are 

anticipated to only be able to form in thin layers at any given time, depending on the 

extent of pyrite coating by iron precipitates. These reactive layers would slowly progress 
Chapter 3. Affected Environment and Environmental Consequences

3-36 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

deeper within the TDF but leave behind previously reacted acid neutral layers. In this 

manner only a small volume of the TDF could be producing ARD at any given time. In 

general, any ARD solutions produced in localized areas are anticipated to become 

neutralized or diluted by other pore waters as it percolates through the pile. 

Petros (2011) constructed a mixing model to calculate the potential water quality in this 

system associated with discharge from tailings under various discharge scenarios. Unlike 

the model used in the 2003 Greens Creek EIS, as discussed above, the 2011 model has 

the benefit of incorporating the geochemical characterization of solids and solutions 

based on observations conducted over the intervening years. Thus, the 2011 model is 

based upon actual site data and conditions, whereas the 2003 model required 

consideration of future effects on a theoretical basis. 

The model constructed by Petros (2011) assigned water quality compositions for 

solutions associated with the tailings as well as associated flows such as surface runoff 

and background groundwater. These flows were iteratively blended as a calibration 

exercise to determine the relative proportions required to replicate the existing water 

quality representative of discharge (wet well data) from the tailings facility. This 

calibration determined that water reporting to a monitoring wet well from the tailings 

themselves was comprised of approximately 2 percent shallow surface seep water, 31 

percent unsaturated zone solution, 10 percent saturated zone water and 57 percent 

groundwater. In areas of the TDF that were unlined, groundwater intermingles with 

tailings effluent in the underdrains of the TDF. These underdrains flow to the wet-wells 

where it is captured and treated. For comparative purposes, background groundwater 

quality is provided in Section 3.6.2.3. 

Petros (2011) offers a full description of the construction of the water quality model, in 

terms of characterization of various flows as well as estimates for water quality of tailings 

solutions post closure. Predictions are produced for the anticipated period of operation, 

as well as transition time to long-term performance and lastly, long-term estimates. The 

time domain for the calculations is 2,000 years into the future. Overall, the modeled 

estimates for future water quality discharging from the tailings impoundment are within 

an order of magnitude of the estimates made in 2003. The agreement between model 

results generated on a theoretical basis (2003) and an empirical, field data basis serves to 

reinforce confidence in the estimates produced by Petros (2011). 

The model results reported by Petros (2011) show very minor differences among 

alternatives. As shown in Figure 3.4-2 (taken from Petros 2011), numerical differences 

exist between concentrations of zinc for each alternative, but the differences are 

inconsequential for comparison purposes. The inherent uncertainty of model predictions 

for trace metals many years in the future is comparable to, or greater than, the anticipated 

precision of measurements. In other words, the inherent error of the points associated 

with each model line overlaps every other line. Thus, there is no statistically significant 

difference observed among the model results for the various alternatives. 

Although the specific time-dependent concentrations for sulfate differ from those of zinc, 

the fundamental conclusions are similar. No appreciable difference among alternatives 

appears to be present. The model results for sulfate are shown in Figure 3.4-3. 
3.4 Geochemistry 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-37 

Figure 3.4-2. Model Results for Zinc over Time, for each Alternative. 

Figure 3.4-3. Model Results for Sulfate over Time, for each Alternative. 
Chapter 3. Affected Environment and Environmental Consequences

3-38 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The inclusion of organic amendments to establish sulfate reduction results in lower zinc 

and sulfate concentrations in the relative near term, but does not represent a long-term 

solution. Although the effect of organic amendment is appreciable, the effect can only be 

maintained so long as organic material is continually added. Thus, in time, organic 

materials are consumed through microbial activity and the model results for sulfate 

reduction become identical to other alternatives. 

Chemical constituents other than zinc and sulfate illustrated previously show similar 

relative trends, with no appreciable difference among alternatives, save for the 

application of organic amendments. Results for all constituents are presented by Petros 

(2011). 

As a mitigation measure, the Forest Service will require HGCMC to update the predictive 

water quality mixing model incorporating updated water quality monitoring data 

associated with the TDF. HGCMC will be required to produce a revised report every five 

years that describes any changes to the mixing model, model assumptions, and results. 

The report will be developed prior to each five-year independent mine site environmental 

audit that is required as a part of the ADEC waste management permit. The independent 

audit will incorporate a review of the model and data. The results of this audit assist the 

agencies in updating plans, procedures, and permit requirements; determining compliance 

with the General Plan of Operations (GPO) and Waste Management Permit; and 

determining adequacy of the reclamation bond. These regular updates will also allow the 

Forest Service, ADEC, and HGCMC to plan potential changes to water management and 

control as well as support long-term planning regarding water treatment. 

3.4.4 Geochemistry – Summary 

Weathering (oxidation) is the primary geochemical reaction that would affect the tailings 

post closure and reclamation. The influx of oxygen and water would be governed by the 

ingress of oxygen and water through the compacted (barrier) layer of the engineered 

cover and movement through the tailings themselves. The rates of geochemical reactions 

would be the same under all TDF alternatives and the low permeability of the tailings 

would result in the “shrinking core” behavior of the pile, where complete oxidation 

would require thousands of years. The rate of reaction is unlikely to result in a buildup of 

ARD although water draining from the TDF under all alternatives would exceed WQS 

and therefore would require water treatment for at least 100 years after closure and 

perhaps in perpetuity. The geochemical behavior of the tailings among alternatives 

would be indistinguishable over the long term. Potential effects on water quality and 

treatment requirements are discussed in more detail in Section 3.5.3.1. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-39 

3.5 Water Resources – Surface Water _____________ 

Impacts associated with Waters of the United States are evaluated in Section 3.5, Water 

Resources – Surface Water; Section 3.7, Aquatic Resources; and Section 3.8, Wetlands. 

3.5.1 Water Resources – Surface Water – Pre-mining 

Environment 

3.5.1.1 Climate 

Between 1997 and 2000, the average annual precipitation at the site was 53.0 inches 

(Forest Service 2003). At the TDF, the average annual precipitation from January 2000 

through November 2008 was 60.4 inches. This precipitation amount is larger than the 

average from 1997 through 2000; however, it is consistent with other meteorological 

measurements in the project area. The meteorological station at Hawk Inlet had an 

average precipitation of 40.1 inches from 2000 through 2010. The Hawk Inlet station is 

located less than 1 mile north of the TDF and at approximately sea level. The 

meteorological station at the mill site had an average precipitation of 66.6 inches from 

2000 through 2010. The mill site station is located approximately 5.5 miles southeast of 

the tailings station and at an elevation of approximately 920 feet. In general, the site is 

the wettest during the fall and driest during the spring. Table 3.5-1 shows the monthly 

and annual precipitation for the 11-year period from 2000 through 2010. 

From 2000 through 2008, the average annual temperature at the TDF ranged between 

approximately 30 °F and 56 °F. From 2000 through 2010, the average annual 

temperature at the mill site ranged between approximately 28 °F and 54 °F. 

From 2000 through 2010, the average annual temperature at the Hawk Inlet site ranged 

between 31 °F and 55 °F. In general, the site is coldest during the winter and warmest 

during the summer and the close proximity to the marine environment has a moderating 

effect on temperature extremes. 

3.5.1.2 Surface Water 

Several drainage basins make up the Greens Creek 

Mine area. The major drainage basins are 

Cannery Creek, Fowler Creek, Tributary Creek, 

Zinc Creek, Greens Creek, and several small 

creeks that drain to Hawk Inlet (Figure 3.5-1). 

Fowler Creek drains much of the area east of the 

A Road. An additional small drainage basin north 

of the Fowler Creek watershed that drains north to 

Hawk Inlet is referred to as the “North Hawk Inlet 

watershed.” 

Water resources are directly 

connected to significant Issue 1. 

Water quality concerns raised 

during scoping are addressed in 

this section. Measures of water 

quality include the ability to 

discharge water that meets Alaska 

WQS as well as managing 

pathways of discharged surface 

water.
Chapter 3. Affected Environment and Environmental Consequences

3-40 Greens Creek Mine Tailings Disposal 

Table 3.5-1. Monthly and Annual Precipitation, 2000–2010. 

Month 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

Tailings Site Monthly Precipitation (inches) 

January 3.02 5.78 3.04 5.07 5.92 12.38 3.85 5.89 4.7 NA February 0.94 3.27 5.31 2.21 3.87 5.24 1.57 3.58 4.79 NA March 3.67 2.67 1.11 3.62 6.16 3.87 0.92 29.66 3.9 NA April 4.32 3.15 0.42 0.72 2.54 2.73 3.45 17.74 4.57 NA May 2.47 3.65 2.66 3.1 1.14 1.56 3.81 3.34 3.17 NA June 3.8 1.86 3.2 3.68 1.49 3.68 5.27 1.6 2.82 NA July 4.02 3.24 4.46 2.45 4.24 6.64 3.45 4.35 5.93 NA August 4.47 3.08 7.64 4.11 1.89 6.45 7.74 2.17 3.8 NA September 8.32 7.88 5.06 10.91 7.94 9.62 9.46 6.46 6.6 NA October 5.98 4.97 7.69 5.74 6.33 7.53 9.99 8.88 9.85 NA November 4.34 3.16 6.59 4.88 6.71 11.73 2.74 2.67 4.93 NA December 3.49 3.39 6.27 4.75 10.04 5 10.97 4.3 NA NA Total 48.84 46.10 53.45 51.24 58.27 76.43 63.22 90.64 55.06 NA 

Hawk Inlet Site Monthly Precipitation (inches) 

January 2.35 4.30 2.05 3.03 3.71 3.39 2.04 3.85 2.62 4.45 February 0.76 2.34 3.78 1.46 3.20 3.58 1.18 2.20 1.93 2.24 March 3.02 2.09 0.73 2.39 4.17 2.84 0.59 2.21 2.36 1.90 April 3.62 2.48 0.34 0.55 1.98 2.19 3.08 1.90 3.33 0.98 May 1.92 3.11 2.09 2.60 0.98 1.30 3.47 2.54 2.55 1.43 June 3.10 1.67 2.69 2.99 1.09 3.22 4.74 1.35 2.12 1.73 Note: NA = Data not recorded or unavailable. 
3.5 Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.5-1. Monthly and Annual Precipitation, 2000–2010. 

Month 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

Hawk Inlet Site Monthly Precipitation (inches) (continued) 

July 3.33 2.67 4.12 1.97 3.27 5.95 3.32 5.69 4.92 0.81 August 3.21 2.57 5.39 3.04 1.60 6.14 7.08 1.83 2.07 5.49 September 2.66 7.27 3.98 7.47 6.26 9.35 7.53 5.16 5.22 5.94 October 2.66 4.28 6.44 3.96 4.75 5.46 7.42 7.46 0.00 4.52 November 3.58 2.45 5.24 4.61 5.06 8.80 0.83 1.86 4.58 3.54 December 2.66 2.34 4.65 3.21 7.33 3.72 5.02 2.95 3.43 2.44 Total 32.87 37.57 41.50 37.28 43.40 55.94 46.30 39.00 35.13 35.47 

Mill Site Monthly Precipitation (inches) 

January 4.39 7.82 3.48 5.77 5.53 4.90 3.75 6.15 3.40 6.65 February 1.08 4.55 5.87 1.63 5.37 4.73 2.60 2.74 3.74 1.96 March 5.45 4.14 1.63 3.66 7.03 4.82 1.06 11.73 5.15 2.24 April 4.78 3.39 0.67 1.16 3.88 2.93 4.10 8.24 5.45 1.47 May 2.51 6.04 2.56 4.09 1.40 1.27 5.10 3.33 3.80 2.10 June 4.95 2.30 3.07 4.28 1.72 3.54 6.55 2.64 2.45 3.05 July 6.01 5.19 4.62 2.66 4.29 6.56 4.48 6.58 7.14 1.25 August 5.47 4.50 9.87 4.97 2.54 6.08 9.07 2.65 4.77 6.94 September 9.84 11.01 6.20 11.64 9.86 12.66 10.51 9.42 9.99 9.10 October 8.09 8.07 9.71 5.54 8.26 9.89 11.37 11.76 15.74 6.16 November 6.47 4.62 8.42 8.09 9.72 15.26 2.52 3.31 5.99 7.66 December 5.06 3.64 7.60 6.33 13.37 6.79 10.23 4.30 4.02 3.67 Total 64.10 65.27 63.70 59.82 72.97 79.43 71.34 72.85 71.64 52.25 Note: NA = Data not recorded or unavailable. 
Chapter 3. Affected Environment and Environmental Consequences

3-42 Greens Creek Mine Tailings Disposal Figure 3.5-1. Surface Water. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-43 

The Cannery Creek drainage basin is approximately 690 acres located on relatively steep 

terrain and primarily covered by timber. The creek is a perennial drainage whose upper 

reaches flow north and northwest and discharges to Hawk Inlet near the cannery 

buildings. Cannery Creek is also classified as a State Public Water System. The primary 

withdrawal point is located immediately east of the B Road crossing near the existing 

TDF site. An alternate permitted withdrawal point is near the Hawk Inlet Camp 

Building. 

Greens Creek would not be directly affected by the proposed TDF expansion; however, 

the watershed was included in the study area for surface water due to its proximity to 

ongoing activities and the potential for indirect effects. Like Cannery Creek, it is a 

classified as a Public Water System. The withdrawal point is located well upstream of 

and outside of the project area, upstream of the mill facilities and mine portal. 

Prior to mining, the Tributary Creek drainage basin was about 482 acres sloping south 

towards Zinc Creek and primarily consisting of muskeg vegetation interspersed with 

stands of timber. The headwaters of Tributary Creek were the slopes east of the TDF and 

part of the muskeg area where the current TDF is located. Tributary Creek flows to Zinc 

Creek, which flows into Hawk Inlet near the mouth of Greens Creek. 

The South Hawk Inlet drainage basin lies immediately west of the Tributary Creek basin. 

Several small ephemeral streams make up this basin, which originally drained 

approximately 76 acres. The drainage has a northern aspect and is primarily made up of 

muskeg that occurs on terraces and timber that occurs on steeper slopes. The streams are 

known as CC Creek, Proffett Creek, and Further Creek. CC Creek and Further Creek 

drain directly to Hawk Inlet. Proffett Creek flows for a few hundred feet but becomes 

intermittent and eventually sinks into the underlying strata. 

Another surface stream occurs about 100 feet down-gradient to where Proffett Creek 

disappears, and appears (based on similar water chemistry and physiographic position) to 

be the same water flow. This lower stream is known locally as Franklins Creek, which 

discharges directly to Hawk Inlet. Water flow in these streams fluctuates seasonally in 

response to rainfall and snowmelt events. However, all of these drainage features have 

very low flows, with average flows ranging between less than one gallon per minute 

(gpm) and approximately 10 gpm. One particular seep in this drainage is called Further 

Seep, an intermittent seep with a flow of approximately one gpm. 

The Fowler Creek drainage basin is approximately 5,090 acres located on flat to 

moderately steep terrain and primarily covered by timber and forested wetlands. Fowler 

Creek has a number of small tributaries and eventually drains to Young Bay. Many 

northern small tributaries contain beaver dams and drain muskeg and forested wetlands. 

The central and southern tributaries are relatively low gradient and also contain beaver 

dams and bog wetlands. 

The North Hawk Inlet watershed is approximately 260 acres. The drainage contains two 

primary unnamed streams that drain muskeg and forested wetlands to Hawk Inlet. 
Chapter 3. Affected Environment and Environmental Consequences

3-44 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.5.2 Water Resources – Surface Water - Baseline 

Conditions 

The TDF occupies a gently sloping terrace that straddles the drainage divide between the 

Tributary Creek drainage basin, the Cannery Creek drainage basin, and the South Hawk 

Inlet drainage area. A steep, timbered mountain slope rises to the east of the TDF, while 

to the west a muskeg area steepens as it approaches Hawk Inlet. On the northwest side of 

the TDF, a bedrock knob rises to nearly 300 feet above sea level.

In 1998, a stabilizing berm (known as the West Buttress) was constructed on a prepared 

foundation on the western edge of the existing TDF site to allow additional height and 

capacity to the TDF, without a major increase in site surface disturbance. From 2000 to 

late 2002, tailings were placed in an area known as the East Expansion, taking advantage 

of the additional room allotted by the construction of the West Buttress.

An additional surface water feature has resulted from mining activities. Duck Blind 

Drain is a human-induced spring that resulted from construction of the pipeline that 

discharges treated water into Hawk Inlet. Water that naturally collects within the pipeline 

trench alignment is allowed to discharge to the surface through a pipe at the location of a 

pipeline valve vault. This vault contains a flow meter that monitors flow through the 

pipeline; the discharge pipe is used to keep the vault from becoming flooded. The flow 

from this source is less than 5 gpm. The streams and seeps in the South Hawk Inlet 

catchment were sampled during baseline data collection efforts in 2001. Samples were 

collected in Proffett and Franklin creeks, CC Creek (two sites), Further Creek (four sites), 

Further Seep, and the Duck Blind Drain. 

Water quality and flow samples in area streams, creeks, and other water features have 

been collected and monitored since 1985. As mining has progressed, the Fresh Water 

Monitoring Program (FWMP) has expanded to provide monitoring of additional stations 

and creeks. Figure 3.5-1 depicts the area streams. Under the FWMP, an annual report is 

produced as a part of the operations plan. This report documents trends in water quality 

in all project drainage features and creeks. This annual FWMP report is sent to the Forest 

Service and ADEC for review. 

Water quality is usually evaluated in relation to Alaska WQS. Alaska WQS include use 

classifications, numeric and/or narrative water quality criteria, and an anti-degradation 

policy. The use classification system designates the beneficial uses that each water body 

within the State of Alaska (such as Tributary Creek, Greens Creek, and Cannery Creek) is 

expected to provide. The numeric and/or narrative water quality criteria are the criteria 

deemed necessary by the State of Alaska to support the beneficial use designation.

Beneficial uses for waters within the Greens Creek area are freshwater industrial water 

supply use, contact recreation, secondary recreation, water supply for drinking, culinary 

and food processing, and for the growth and propagation of fish, shellfish, other aquatic 

life, and wildlife. The most stringent water quality criteria across these designated uses 

applies to area streams. For most parameters and metals, the most stringent criteria are 

for the propagation of fish and aquatic life. However, the most stringent water quality 

criteria for manganese is for the human health consumption of water plus fish, and the 

most stringent criteria for arsenic and sulfate are for drinking water (ADEC 2009).
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-45 

Some of the fresh WQS for metals are hardness-based. Hardness is the measure of 

polyvalent cations (ions with a charge greater than +1) in water. Hardness generally 

represents the concentration of calcium (Ca2+) and magnesium (Mg2+) ions in solution, 

because these are the most common polyvalent cations. Other ions, such as iron (Fe2+) 

and manganese (Mn2+), may also contribute to the hardness of water, but are generally 

present in much lower concentrations. Hardness mitigates metals toxicity because 

polyvalent cations (Ca2+ and Mg2+) help keep fish and other aquatic organisms from 

absorbing metals such as cadmium, copper, and lead into their bloodstream through their 

gills. The greater the hardness of the water, the harder it is for toxic metals to be 

absorbed into the gills. For this reason, a higher measured hardness in the receiving 

water results in a higher (less stringent) WQS for hardness-based metals. A lower 

measured hardness results in more stringent WQS for hardness-based metals. In this 

manner, the metals WQS applied to area creeks are based on measured hardness of the 

receiving water on a sample-by-sample basis. Table 3.5-2 shows WQS for aquatic life 

(also see Figure 3.5-2). For this example, standards for the hardness based metals were 

calculated using the long-term average hardness of 46 mg/L measured as calcium 

carbonate (as CaCO3) in lower Tributary Creek. 

There are no streams listed as impaired under Section 303(d) of the Clean Water Act 

(CWA) at the Greens Creek project site. Table 3.5-3 shows cumulative results of the 

FWMP at major area streams near the TDF. These data show average and maximum 

concentrations of metals, pH, and other important parameters taken between 1989 when 

the program was first initiated, and 2010. In general, surface water in Greens Creek, 

Tributary Creek, and Cannery Creek have near-neutral pH with low levels of metals and 

sulfate. The water quality generally meets Alaska WQS for aquatic life. Some water 

quality samples with concentrations above the Alaska WQS for dissolved cadmium, and 

to a lesser extent copper, mercury and zinc were reported in Tributary Creek in the 1990s. 

Reported concentrations appear to be anomalous values that were not associated with 

parallel increases in sulfate, reduced pH, or elevations of non-trace metals, such as iron, 

calcium, or magnesium. Since 1990, these parameters have returned to low levels that 

meet the Alaska WQS for aquatic life. 

The water quality in the Further Creek, Further Seep, and Duck Blind Drain is generally 

of lower quality than that of Greens Creek, Tributary Creek, and Cannery Creek. In 

general these drainages and seeps have elevated sulfate, lower pH, and elevated dissolved 

zinc as well as some other metals; but are higher in hardness. As a result of these data, an 

action plan was designed by the operator in 2001 in consultation with the Forest Service 

and other agencies to conduct a rigorous study of surface water, seeps, and groundwater 

in the areas near the TDF. As a part of this action plan, an annual report that documents 

sampling and water quality trend analysis is submitted annually to ADEC and the Forest 

Service (HGCMC 2009). The action plan sets water quality triggers for these drainage 

features that require the proponent to notify ADEC and identify mitigation measures if 

the trigger is exceeded. Results from this action plan has shown that the lower pH and 

elevated sulfate and metals in these drainage features were not caused by contact with 

placed tailings but rather were from other pyritic sources such as waste rock that were 

outside the slurry walls of the TDF (EDE 2002a and KGCMC 2003). 

 
Chapter 3. Affected Environment and Environmental Consequences

3-46 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.5-2. Example of Water Quality Standards for Area Streams. 

Parameter (in μg/L unless noted otherwise) 

WQS 

Acute Chronic 

Aluminum, Total 750 87 

Arsenic 340 10 

Cadmium – Dissolved a 0.95 0.14 

Copper – Dissolved a 6.5 4.6 

Cyanide b 22 5.2 

Iron – Total – 1,000 

Lead – Dissolved a 27 1.07 

Manganese c – 50 

Mercury – Dissolved 1.4 0.012 

Nickel – Dissolved a 243 27 

Selenium – Total 20 5 

Silver – Dissolved a 0.91 – 

Zinc – Dissolved a 61 61 

Sulfate (mg/L) d – 250 

Total Dissolved Solids (mg/L) d – 500 

pH 6.5–8.5 

Notes: 

mg/L = milligrams per liter or parts per million; μ/L = micrograms per liter or 

parts per billion. 

The values listed for the chronic standard are for chronic aquatic life criteria or 

alternatively the most stringent standard based on other designated uses. 

a. assumes the long-term average hardness of 46 mg/L as CaCO3 in 

Tributary Creek. 

b. the cyanide standard is for free cyanide sampled as weak acid dissociable. 

c. based on the human health criteria for consumption of water and fish. 

d. based on the drinking water standard. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-47 

Figure 3.5-2. Surface Water Quality Monitoring Sites. 
Chapter 3. Affected Environment and Environmental Consequences

3-48 Greens Creek Mine Tailings Disposal Table 3.5-3. Summary of Surface Water Quality Monitoring Stations. 
3.5 Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 3.5-3. Summary of Surface Water Quality Monitoring Stations (continued). 
Chapter 3. Affected Environment and Environmental Consequences

3-50 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The elevated levels in Further Seep were found to be residual effects from an old access 

road constructed in 1988 that contained pyritic rock. The road was located along the 

perimeter of the West Buttress and removed during the slurry wall construction in 1996. 

As a result, the water quality in Further Seep has improved but remains slightly acidic 

(HGCM 2009). This seep will continue to be monitored under the action plan. Over time 

it is expected to become less acidic and show decreasing levels of sulfate (HGCM 2009). 

Elevated metals levels in the North Fork of Further Creek were reported to be caused by a 

thin veneer of tailings residue at the toe of the West Buttress that accumulated from the 

removal of the temporary tailings cover in 1999, and from residual tailings found in the 

Northwest Diversion Ditch. The Kennecott Greens Creek Mining Company (KGCMC) 

removed these tailings sources in 2002 which resulted in improved water quality. 

Elevation of metals was noted in Further Creek as a result of disturbances during the 

2007 and 2008 construction seasons. Subsequent monitoring has indicated that Further 

Creek is returning to pre-construction conditions (HGCMC 2009a). 

Slightly elevated metal concentrations in Duck Blind Drain were attributed to pyritic 

materials used in an access road and trench construction materials that were used for the 

permitted discharge pipeline. Water quality in this drain has improved since 2008 and 

continues to be monitored. 

In addition to monitoring these and other sites specified by other permits and through the 

GPO, HGCMC has initiated a study to better define and determine natural background 

water quality for both surface and groundwater in the area. This study will assist the 

Forest Service, ADEC and other agencies evaluate site conditions, potential impacts and 

mitigation success. 

3.5.2.1 Wastewater Management 

Freshwater intake diversions are located at Greens Creek near the mine portal and at 

Cannery Creek near the Hawk Inlet camp, shipping dock, and office facilities. These 

water sources provide water for milling operations, domestic use, equipment wash-down, 

underground mining activities, and fire suppression. 

Non-contact surface runoff from native areas is diverted from contacting disturbance 

areas or the TDF using upslope ditches. Depending on the location, these ditches direct 

the runoff to either Cannery Creek or Tributary Creek. The diversion ditches are 

designed to convey the flow that would occur from the 25-year, 24-hour precipitation 

event. 

Mining activities produce a variety of wastewaters. Wastewaters consist of spent 

domestic use water (grey water), sanitary wastewater, process water (water used in 

processing ore), equipment wash-down water, and contact waters, which consist of 

surface water or groundwater originating within or passing through mining disturbance or 

the TDF. Contact water includes precipitation and runoff that contacts rock quarries with 

the potential to develop ARD. Monitoring of these waters is addressed via programs 

established in the GPO’s stormwater monitoring program. 

The four primary wastewater management areas at the site are the Hawk Inlet camp/loadout facilities area, the waste rock disposal areas (Pond C, Pond D, and Site 23), the 920 

mine and mill area, and the tailings facility area, consisting of the TDF, water 

containment and storage, and the Pond 7 wastewater treatment plant (WWTP). The 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-51 

primary wastewater containment and treatment facilities are located in the southwest 

corner of the TDF. These facilities consist of Pond 7 and the Pond 7 WWTP. There are 

two sewage treatment plants located at the site, one at the Hawk Inlet facilities, and one at 

the mine and mill area. Wastewater discharges, including treated sewage effluent that 

originates from the Hawk Inlet facilities and the mine and mill area report to Pond 7 and 

are treated at the Pond 7 WWTP. The WWTP reduces the levels of metals in the 

wastewater by precipitation with calcium carbonate as well as other neutralizing bases. 

Sewage sludge is co-disposed in the TDF. A detailed description of these water 

management facilities is provided by EDE (2010). 

Extreme storm events in 2007 produced new information about the extent of mine contact 

water management necessary. In response to that information, the mine expanded its 

water collection, treatment, and discharge system. Upgrades included improvements to 

ponds C and D, increased pumping capacity to the WWTP, and modification of the 

diffuser at the outfall in Hawk Inlet. 

Collected wastewaters are treated at the Pond 7 WWTP to meet effluent limits identified 

in the National Pollutant Discharge Elimination System (NPDES) permit prior to 

discharge through a diffuser outfall located in Hawk Inlet. The current NPDES permit 

restricts the maximum allowable daily discharge to 3.6 million gallons per day (mgd) 

[2,490 gpm] and a monthly average discharge of 2.39 mgd (1,650 gpm). The permit 

limits assure compliance with all Alaska marine WQS. The permit also allows ten noncontact storm water discharge outfalls in Greens Creek, Zinc Creek, and Hawk Inlet. 

Surface contact water treated at the Pond 7 WWTP is primarily runoff generated from the 

TDF or from mine facility areas. Groundwater contact water is a combination of 

infiltration through the TDF (within containment boundaries) to the underdrain collection 

system and native groundwater. The majority of native groundwater at the site is 

intercepted or routed around the TDF by perimeter up-gradient groundwater diversions 

and barriers. This water does not require containment or treatment. 

3.5.2.2 Tailings Contact Water Management 

Contact surface runoff is captured via a series of perimeter toe ditches around the TDF. 

Four primary ditch segments make up the toe ditch network and are designated according 

to their location around the base of the TDF. The ditches are all designed to convey the 

runoff that would occur from the 25-year, 24-hour storm event. All runoff water 

collected by the ditches reports to Pond 7 and is treated by the Pond 7 WWTP. 

Tailings contact groundwater is captured via an underdrain network beneath the TDF. 

The underdrain network is composed of a combination of French drains, finger drains, 

high-density polyethylene liner placements, and wet wells. Different phases of the 

tailings placement expansion have different underdrain configurations based on the order 

of expansion and the underlying native materials. The wet wells collect water from the 

underdrain system as collection sumps that direct the water to Pond 7 for surge storage 

and redistribution for treatment. The TDF currently has three wet wells within the 

underdrain network. Underdrain discharges are directed to the toe ditches surrounding 

the tailings pile or directly to Pond 7, depending on their location under the TDF. 
Chapter 3. Affected Environment and Environmental Consequences

3-52 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.5.2.3 Hawk Inlet 

Hawk Inlet is a marine inlet formed during the late Holocene. The inlet extends seven 

miles north from Chatham Strait to a tidal mudflat estuary about 0.6 miles in diameter. 

The narrow channel connecting the Inlet to Chatham Strait, located between the top of 

the Greens Creek delta and the western shore of Hawk Inlet, has a minimum low tide 

depth of 35 feet. The mid-channel depth ranges from 35 feet to 250 feet. The Inlet has 

regular, twice-daily tides, with a maximum tidal variation of 25 feet. On the flood tide, 

the surface 35-foot layer contains the bulk of the water transport entering the Inlet and is 

then flushed out on the ebb tide. Flushing describes the rate and extent to which a body 

of water is replenished by tidal or other currents. Flushing rates are also indicative of the 

length of time that mining effluent may remain in a water body and become incorporated 

into the physical and biological ecosystem through ingestion, adsorption, or other means. 

In 1981, dispersion dye testing in Hawk Inlet determined that over each tidal cycle, an 

average of 13 billion gallons of water is flushed from the Inlet. At that rate, it is 

estimated that the Inlet will completely flush at least once every five tidal cycles. Based 

on the mine output up through 1995, the input of effluent from the mining operations 

over this flushing period represents approximately 0.009 percent of the total flushing 

volume (Ridgeway 2003). 

Prior to development of the Greens Creek Mine, baseline studies were conducted to 

document marine life and to characterize existing levels of heavy metals in sediments and 

marine biota in Hawk Inlet. Currently the NPDES permit requires monitoring for water 

quality, sediment quality, and bio-assays of mussels and worms. The primary objective 

of the monitoring program is to document the water quality, sediment quality, and metals 

levels in marine organisms that could be potentially impacted by mining operations. Sea 

water is sampled quarterly at three locations in Hawk Inlet, and sediment and invertebrate 

samples are taken at several locations each year in the spring and fall. Figure 3.5-3 

shows the location of the NPDES outfall and water quality monitoring stations in Hawk 

Inlet. Table 3.5-4 shows Alaska marine WQS for selected parameters and Table 3.5-5 

shows average marine water quality data for selected metals for 2005 through 2009 

(HGCMC 2009). The permit requires reporting of any identified impacts, reporting of 

incidents or spills and descriptions of corrective actions taken, if any were required. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-53 

Figure 3.5-3. Marine Water, Mussel, and Sediment Sampling Sites. 
Chapter 3. Affected Environment and Environmental Consequences

3-54 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.5-4. Alaska Marine Water Quality Standards (Adjusted to Total Values). 

Parameter Units WQS 

Total Cadmium μg/L 8.85 

Total Copper μg/L 3.73 

Total Lead μg/L 8.47 

Total Mercury μg/L 1.1 

Total Zinc μg/L 86 

pH s.u. 6.5–8.5 

Notes: 

s.u. = standard pH units. 

Table 3.5-5. Average Marine Water Quality in Hawk Inlet for 2005–2009. 

Site 

Dissolved 

Cadmium 

 Dissolved 

Copper 

 Dissolved 

Lead Total Mercury 

 Dissolved 

Zinc 

(μg/L) (μg/L) (μg/L) (μg/L) (μg/L) 

106, Background 

Location 

0.068 0.42 0.074 0.00056 0.58 

107, Near Ore 

Loading Dock 

0.074 0.55 0.13 0.00064 1.08 

108, Near 

Diffuser Outfall 

0.070 0.44 0.091 0.00063 0.86 

3.5.3 Surface Water – Environmental Consequences 

3.5.3.1 Effects Common to All Alternatives 

Fugitive Dust 

Each alternative has the potential for continued or increased fugitive dust emissions due 

to wind erosion of the TDF and truck hauling on unpaved roads. Emissions generated by 

wind erosion are dependent upon the frequency and size of disturbances of the erodible 

surface; each time the surface is disturbed, fresh surface material is exposed to wind and 

climatic conditions (e.g., wind, precipitation). The extended life of the mine would 

increase the amount of fugitive dust from the TDF. Fugitive dust could adversely affect 

water quality by either direct deposition on streams or accumulated dust on vegetation 

and soils being carried into stream in runoff. Best management practices (BMPs) are 

currently employed to minimize fugitive dust from blowing off the TDF. Additional 

BMPs may be added if monitoring indicates this is necessary. BMPs to reduce fugitive 

dust are included in Section 3.2.3. HGCMC would continue to implement its FWMP to 

identify effects to water quality, including effects potentially associated with fugitive 

dust. After successful reclamation fugitive dust would no longer occur. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-55 

Freshwater Sources 

Potential indirect impacts to fresh and drinking water sources in Greens Creek and 

Cannery Creek, respectively, could occur due to continued operation of mine operations. 

Direct short-term impacts to water quality in Cannery Creek could occur if the collection 

pond failed, or if discharges occurred through the emergency spillway. Water would 

discharge through the pond’s emergency spillway if the pond stormwater capacity was 

exceeded. The pond stormwater capacity is based on the 25-year, 24-hour storm event. 

Indirect impacts to water quality could occur from fugitive dust as well as from other 

non-specific operations. These potential impacts are monitored through the FWMP and 

trend analyses are conducted annually. 

NPDES Discharge 

Wastewater that comes into contact with the tailings (TDF runoff and seepage) and other 

industrial wastewater is treated in a WWTP and discharged into Hawk Inlet under the 

terms and conditions of the NPDES permit. The treated effluent is discharged through a 

diffuser outfall near monitoring location 108. All discharges are required to meet the 

effluent limits established in the NPDES permit. The current permit includes effluent 

limits for flow, cadmium, copper, lead, mercury, zinc, total suspended solids, and pH. 

The permit also requires monitoring of cyanide, temperature, biological oxygen demand, 

and fecal coliform bacteria. The effluent limits established by the NPDES permit are 

provided in Table 3.5-6. 

Table 3.5-6. NPDES Effluent Limits Established for the Hawk Inlet NPDES Outfall. 

Parameter Units 

Effluent Limit 

Daily Maximum Monthly Average 

Flow mgd 3.6 2.39 

Total Recoverable Cadmium μg/L 100 50 

Total Recoverable Copper μg/L 300 150 

Total Recoverable Lead μg/L 600 300 

Total Mercury μg/L 2 1 

Total Recoverable Zinc μg/L 1,000 500 

Total Suspended Solids mg/L 30 20 

pH s.u. 6.0–9.0 

Notes: 

mgd = million gallons per day 

μg/L = micrograms per liter or parts per billion 

mg/L = milligrams per liter or parts per million 

s.u. = standard pH units 

 

Under all alternatives, tailings contact water, or any other industrial contact water, would 

be captured, treated, and discharged under the current NPDES, or a future Alaska 

Pollutant Discharge Elimination System (APDES) discharge permit. Discharge permits 

are scheduled to be reissued on a five-year basis. When a permit is reissued, all water 

quality monitoring data and effluent quality data are reviewed, as is the need for a mixing 

zone. Changes are made as necessary under provisions established by the CWA and the 

State of Alaska. A discharge permit would be required as long as the effluent does not 

meet Alaska WQS. As discussed in the following section, drainage from the TDF is 
Chapter 3. Affected Environment and Environmental Consequences

3-56 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

expected to be of poor quality and exceed Alaska WQS for at least 100 years after closure 

and perhaps in perpetuity. Therefore, active water treatment and a permit to discharge 

will continue to be needed. Each time the permit is reissued, surface water and effluent 

monitoring data is reviewed to determine if permit conditions need to be revised to be 

protective of Alaska WQS. In addition, there could be changes to Alaska WQS in the 

future. For example, post-closure as TDF discharge volumes decrease, so might the size 

of the mixing zone, the outfall location, the treatment technology, etc. This EIS analysis 

can predict that the TDF discharge will exceed Alaska WQS and require a permit, but it 

cannot predict the requirements of a permit so far in the future. 

Water Quality of Tailings Effluent 

Since preparation of the 2003 EIS for the Greens Creek Mine (Forest Service 2003), 

observations of water quality, water balance, and flow characteristics in the TDF have 

improved the understanding of the relationships among geochemistry, water quality, and 

fate and transport in the Greens Creek TDF. As a result, the operator has created a new 

conceptual and numerical model, which is consistent with these observations and data 

(Petros 2011). This initial model was created with the intent of continuously updating it 

and recalibrating it using observed site data obtained in future years. In this manner 

predictions of effluent quality and TDF geochemical behavior can be refined and 

improved as time progresses. The model estimates the weathering of placed tailings, 

geochemistry, and effluent quality that could be expected over time. A description of the 

predicted geochemistry of placed tailings and the conceptual and predictive models is 

provided in detail in Section 3.4, Geochemistry. 

The conceptual and predictive models suggest three phases (or time periods) that affect 

the geochemistry and quality of wastewater from placed tailings: 

 An operational period where the tailings are being actively placed; 

 A transitional period after closure where oxidation products such as sulfate, calcium, 

and magnesium, as well as trace metals, such as, cadmium, nickel, manganese, and 

zinc are flushed through the TDF; and 

 A steady-state period. 

During the operational period, some oxidation occurs on the surface of the placed tailings 

because it is temporarily exposed to air. The oxidation of pyrite causes several products 

to form such as calcium sulfate (gypsum) and some metals to become elevated, such as 

cadmium, nickel, manganese, and zinc. Acid is also produced, but is neutralized by 

carbonates that are also present. After a permanent cover is placed on the TDF at closure, 

these oxidation products begin flushing through the system during the transitional period. 

Depending on the exact thickness of tailings, the observed hydrologic monitoring data in 

the existing TDF indicates that it would take between 60 and 140 years for a single pore 

volume to be replaced by infiltration and drainage. Petros (2011) estimated that the 

transitional phase would last 350 years, assuming an average tailings thickness of 150 

feet. After the oxidation products formed during the operational phase are flushed from 

the system, a steady-state period will exist with very slow levels of pyrite oxidation, 

neutralization, and drainage of effluent (Petros 2011). Pyrite oxidation is slow and 

limited where it occurs within the TDF because the ingress of oxygen is also limited. 

These processes are discussed in more detail in Section 3.4. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-57 

Contact water in the existing TDF comes from three sources, surface runoff, seepage 

through the TDF, and upwelling groundwater in areas of the TDF that overlay glacial 

marine deposits. The original permitting of the TDF did not require a liner in these areas. 

Upwelling groundwater does not directly contact the tailings; however, it mixes with 

tailings seepage in the underdrain system prior to collection in the wet wells. The 

management of contact waters was discussed in Section 3.5.2.2. 

Tables 3.5-7 through 3.5-10 show predicted water quality for selected parameters of 

concern for water reporting at the TDF boundary and at the wet wells. Data are provided 

for current or initial operation, immediately after closure, and 100 years following closure 

(Petros 2011). The applicable Alaska fresh WQS and Alaska marine WQS are also 

shown for comparative purposes. The predicted concentration at the “facility boundary” 

represents a relative mixture of runoff water and water collected from the underdrains in 

the wet wells. During operation and after closure, the volume of runoff water is much 

higher than the volume of seepage water. Data for the wet wells show predicted water 

quality in the underdrains only. 

Table 3.5-7. Average Predicted Water Quality for Tailings Wastewaters for Alternative A. 

Parameter a 

Alaska 

Chronic 

Fresh 

WQS b

Alaska 

Chronic 

Marine 

WQS 

Current 

Condition 

2011 

2019 

Condition at 

Closure 

50 Years After 

Closure (2064) 

100 Years After 

Closure (2164) 

Facility 

Boundary 

Wet 

Wells/

Drains

Facility 

Boundary

Wet 

Wells/

Drains 

Facility 

Boundary 

Wet 

Wells/

Drains

Facility 

Boundary

Cadmium μg/l 0.14 8.8 24.6 0.2 0.1 0.1 0.1 0.1 0.1 

Copper μg/l 4.6 3.1 9.0 3.0 2.0 3.0 2.0 3.0 2.0 

Iron μg/l 1,000 – 2,500 5,400 3,300 6,100 3,500 2,900 2,300 

Lead μg/l 1.1 8.1 52.2 1.1 0.7 1.2 0.7 1.2 0.7 

Manganese c μg/l 50 100 2,400 900 800 800 800 800 800 

Mercury μg/l 0.012 1.1 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

Nickel μg/l 27 8 140 10 10 10 10 10 10 

Selenium μg/l 5 71 3.8 2.8 1.4 3.1 1.5 3.0 1.4 

Zinc μg/l 61 81 8,180 570 220 470 180 470 180 

Sulfate d mg/L 250 – 1,455 772 298 810 312 810 312 

Total 

dissolved 

solids 

mg/l 500 – 2,164 1,256 517 1,294 531 1,241 511 

pH s.u. 6.5–8.5 6.5–8.5 7.5 7.3 6.4 7.2 6.4 7.2 6.4 

Notes: 

The water quality at the wet wells represent drainage collected in the underdrains only. 

The water quality at the Facility Boundary is a relative mixture of drainage from the underdrains and surface water 

runoff. 

a. All metals are expressed as totals. 

b. Assumes a long-term average hardness of 46 mg/L as CaCO3 in Tributary Creek would be applied. 

c. Fresh WQS for manganese is based on the human health consumption standard for water + fish; the marine WQS 

for manganese is based on the human health consumption standard for consumption of aquatic organisms only. 

d. Fresh WQS for sulfate and total dissolved solids are based on the drinking water standard. 
Chapter 3. Affected Environment and Environmental Consequences

3-58 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.5-8. Average Predicted Water Quality for Tailings Wastewaters for Alternative B. 

Parameter a 

Alaska 

Chronic 

Fresh 

WQS b

Alaska 

Chronic 

Marine 

WQS 

Current 

Condition 

2011 

Condition at Closure 

(2064) 

100 Years After 

Closure (2164) 

 Facility 

Boundary 

Wet 

Wells/

Drains 

Facility 

Boundary

Wet 

Wells/

Drains 

Facility 

Boundary 

Cadmium μg/l 0.14 8.8 24.6 0.2 0.1 0.1 0.1 

Copper μg/l 4.6 3.1 10 3.0 2.0 3.0 2.0 

Iron μg/l 1,000 - 2,500 3,800 2,600 2,900 2,300 

Lead μg/l 1.1 8.1 52.2 1.0 0.6 1.1 0.7 

Manganese c μg/l 50 100 2,400 1,000 900 900 800 

Mercury μg/l 0.012 1.1 0.01 0.01 0.01 0.01 0.01 

Nickel μg/l 27 8 140 10 10 10 10 

Selenium μg/l 5 71 3.8 2.7 1.3 2.9 1.4 

Zinc μg/l 61 81 8,180 550 210 450 170 

Sulfate d mg/L 250 - 1,455 785 303 824 317 

Total 

dissolved 

solids 

mg/l 500 - 2,164 1,239 510 1,251 515 

pH s.u. 6.5 – 8.5 6.5 – 8.5 7.5 7.2 6.4 7.1 6.4 

Notes: 

The water quality at the wet wells represents drainage collected in the underdrains only. 

The water quality at the Facility Boundary is a relative mixture of drainage from the underdrains and surface runoff. 

a. All metals are expressed as totals. 

b. Assumes a long-term average hardness of 46 mg/L as CaCO3 in Tributary Creek would be applied. 

c. Fresh WQS for manganese is based on the human health consumption standard for water + fish; the marine 

WQS for manganese is based on the human health consumption standard for consumption of aquatic organisms 

only. 

d. Fresh WQS for sulfate and total dissolved solids are based on the drinking water standard. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-59 

Table 3.5-9. Average Predicted Water Quality for Tailings Wastewaters for 

Alternative C – North Stack. 

Parameter a 

Alaska 

Chronic 

Fresh 

WQS b

Alaska 

Chronic 

Marine 

WQS 

Initial 

Condition 

2024 

Condition At Closure 

(2064) 

100 Years After 

Closure (2164) 

Facility 

Boundary 

Wet 

Wells/

Drains 

Facility 

Boundary 

Wet 

Wells/

Drains 

Facility 

Boundary 

Cadmium μg/l 0.14 8.8 24.6 0.2 0.1 0.1 0.1 

Copper μg/l 4.6 3.1 9 3.0 2.0 3.0 2.0 

Iron μg/l 1,000 - 700 2,100 2,000 2,700 2,200 

Lead μg/l 1.1 8.1 52.2 1.1 0.7 1.2 0.7 

Manganese c μg/l 50 100 2,500 900 800 800 800 

Mercury μg/l 0.012 1.1 0.01 0.01 0.01 0.01 0.01 

Nickel μg/l 27 8 140 10 10 10 10 

Selenium μg/l 5 71 3.9 2.9 1.4 3.2 1.5 

Zinc μg/l 61 81 8,160 540 210 450 170 

Sulfate d mg/L 250 - 1,482 799 308 837 322 

Total 

dissolved 

solids 

mg/l 500 - 2,163 1,236 509 1,274 523 

pH s.u. 6.5 – 8.5 6.5 – 8.5 7.5 7.3 6.4 7.3 6.4 

Notes: 

The water quality at the wet wells represents drainage collected in the underdrains only. 

The water quality at the Facility Boundary is a relative mixture of drainage from the underdrains and surface runoff. 

a. All metals are expressed as totals. 

b. Assumes a long-term average hardness of 46 mg/L as CaCO3 in Tributary Creek would be applied. 

c. Fresh WQS for manganese is based on the human health consumption standard for water + fish; the marine 

WQS for manganese is based on the human health consumption standard for consumption of aquatic organisms 

only. 

d. Fresh WQS for sulfate and total dissolved solids are based on the drinking water standard. 
Chapter 3. Affected Environment and Environmental Consequences

3-60 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.5-10. Average Predicted Water Quality for Tailings Wastewaters for 

Alternative D – North Stack. 

Parameter a 

Alaska 

Chronic 

Fresh 

WQS b

Alaska 

Chronic 

Marine 

WQS 

Initial 

Condition 

2034 

Condition at Closure 

(2064) 

100 Years After 

Closure (2164) 

Facility 

Boundary 

Wet 

Wells/

Drains 

Condition 

At Closure: 

Facility 

Boundary

Wet 

Wells/

Drains 

Facility 

Boundary 

Cadmium μg/l 0.14 8.8 24.6 0.2 0.1 0.1 0.1 

Copper μg/l 4.6 3.1 9 3.0 2.0 3.0 2.0 

Iron μg/l 1,000 - 700 2,000 1,900 2,600 2,200 

Lead μg/l 1.1 8.1 52.2 1.0 0.6 1.1 0.7 

Manganese c μg/l 50 100 2,500 1,100 900 1,000 900 

Mercury μg/l 0.012 1.1 0.01 0.01 0.01 0.01 0.01 

Nickel μg/l 27 8 140 10 10 10 10 

Selenium μg/l 5 71 3.9 3.1 1.5 3.4 1.6 

Zinc μg/l 61 81 8,160 520 200 420 160 

Sulfate d mg/L 250 - 1,482 832 320 870 335 

Total 

dissolved 

solids 

mg/l 500 - 2,163 1,270 522 1,308 536 

pH s.u. 6.5 – 8.5 6.5 – 8.5 7.5 7.3 6.4 7.2 6.4 

Notes: 

The water quality at the wet wells represents drainage collected in the underdrains only. 

The water quality at the Facility Boundary is a relative mixture of drainage from the underdrains and surface runoff. 

a. All metals are expressed as totals. 

b. Assumes a long-term average hardness of 46 mg/L as CaCO3 in Tributary Creek would be applied. 

c. Fresh WQS for manganese is based on the human health consumption standard for water + fish; the marine 

WQS for manganese is based on the human health consumption standard for consumption of aquatic organisms 

only. 

d. Fresh WQS for sulfate and total dissolved solids are based on the drinking water standard. 

A comparison of these data show there would only be small differences in water quality 

of the TDF runoff and drainage among all alternatives. For example, predicted zinc 

concentration at the facility boundary immediately after reclamation and closure ranges 

between 200 micrograms per liter (μg/L) for the TDF in Alternative D to 210 μg/L in 

Alternative B. Similarly, predicted sulfate concentration in the wet wells ranges between 

810 milligrams per liter (mg/L) for Alternative A and 870 mg/L for the TDF in 

Alternative D, 100 years after closure. Petros (2011) attributes these minor differences to 

build-out acreage, specific tailings depth, and the proportion of co-disposed waste-rock 

material in the alternatives. However, these differences do not result in an appreciable 

difference in predicted water quality effects between alternatives. 

Further evaluation of these data show that water quality at the facility boundary and in 

the wet wells would drastically improve after reclamation and final closure. For 

example, the predicted concentration of zinc at the facility boundary for Alternative A 

lowers from 8,180 μg/L during operation to 180 μg/L after closure (Table 3.5-7). Similar 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-61 

large reductions in concentration can be noted for other parameters and across all 

alternatives. This effect would be caused by placement of the final engineered cover. 

Runoff water mixing at the TDF boundary would no longer be in contact with tailings. 

Runoff would now be in contact with reclaimed forest soils and vegetation. The final 

engineered cover would also affect pH. The pH of the tailings contact water is relatively 

neutral (7.5 standard pH units [s.u.]). The natural pH of forest soils is acidic (6.4 s.u.), 

primarily caused by the decomposition of organic matter. Because runoff is the largest 

component of water at the facility boundary, the pH of the natural soils of the surface 

cover would dominate pH. 

A comparison of the predicted water quality of the tailings wastewater at the TDF 

boundary and in the wet wells with the Alaska fresh chronic WQS indicates that the 

Alaska fresh WQS would not be met for iron, manganese, zinc, sulfate, and total 

dissolved solids even several years after closure. It also indicates that the wastewater at 

the TDF boundary would not meet the Alaska marine WQS for manganese and zinc. 

Zinc would exceed the acute WQS for fresh and marine waters. These data indicate that 

water treatment would be required for at least 100 years after closure of the TDF(s), 

perhaps in perpetuity. As discussed above, treatment and a discharge permit will be 

required as long as the effluent does not meet Alaska WQS. If treatment is required after 

closure, the operator would separate the mixing of surface water runoff from the 

engineered cover and the seepage water discharging from the underdrains. Runoff from 

the surface cap would not be a regulated discharge if it is not allowed to comingle with 

the tailings contact waters in the underdrains. This would drastically reduce the volume 

of water requiring treatment and would allow clean runoff from the TDF to return to 

Tributary Creek, Cannery Creek, and other respective drainages in the Middle Hawk Inlet 

drainage or Further Creek.

3.5.3.2 Effects of Alternative A, No Action 

Since construction of the TDF (Figure 2.3-1), 

the headwaters of Tributary Creek have 

become small seeps and numerous small 

channels flowing through bog vegetation. 

Additionally, non-contact surface runoff from 

east of the TDF is captured and routed in 

diversions to Cannery Creek and Tributary 

Creek. The final build out under Alternative A 

with supporting infrastructure would reduce the 

total 409-acre watershed area for Tributary 

Creek an additional one percent over current 

conditions. The seeps and channels lying south 

of the TDF are fed from the shallow 

groundwater regime in the peat and sand 

substrate (Bosworth 2011). The series of slurry 

walls installed around the TDF essentially 

route clean groundwater back to Cannery 

Creek and Tributary Creek that would normally 

be stored as shallow groundwater in the bog 

wetland. As a result of the surface and 

Under Alternative A, the existing TDF 

would expand to its permitted footprint 

of 65 acres. The existing tailings 

contact water management and 

infrastructure would remain in place. 

Additional infrastructure would be 

required to divert non-contact surface 

runoff from undisturbed areas around 

the tailings facility. The series of toe 

drains used to collect and route 

surface runoff on the tailings facility 

would expand as necessary as the 

TDF expands. Additional liners, finger 

and blanket drains beneath the 

tailings and slurry walls constructed 

could also be required to divert 

groundwater around the TDF.
Chapter 3. Affected Environment and Environmental Consequences

3-62 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

groundwater diversions and only an additional four percent loss in the Tributary Creek 

drainage area, only minor impacts to both base and storm flows in Tributary Creek would 

be expected. However, because non-contact surface runoff would be routed directly in 

diversion channels, peak flow velocities could increase in the natural stream channel 

during large storm events. This could potentially cause erosion of channel substrates and 

impact channel geomorphology. These potential impacts would be mitigated by a Forest 

Service requirement to use a storm water detention structure or detention pond at the 

confluence of the diversions and the natural channels. While it is anticipated that a storm 

water detention structure would mitigate the effects of the increased flow velocities, the 

Forest Service will require HGCMC to conduct habitat and/or geomorphic surveys in 

Tributary Creek downstream of the TDF expansion area to ensure that unanticipated 

effects are not occurring. This program would be developed and incorporated into the 

GPO as it is updated to reflect the selected alternative. 

Under Alternative A, potential impacts to the water quality in Tributary Creek could 

occur if the liner is compromised or the runoff and groundwater collection systems fail. 

The duration of these impacts would be until the affected facility is repaired. 

Additionally, under an extreme storm event, water could discharge to Hawk Inlet through 

the Pond 7 emergency spillway. The pond’s storm water capacity and spillway are based 

on the 25-year, 24-hour storm event. 

3.5.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B (Figure 2.3-2), noncontact surface runoff from the east side of the 

TDF would continue to be diverted around the 

TDF to Tributary Creek. Groundwater flow 

would also continue to be diverted to 

Tributary Creek by the slurry walls and drain 

curtains. The expansion of the TDF footprint 

under this alternative would reduce the 409-

acre watershed by an additional 20 percent 

(Figure 3.5-4). While some minor impacts to 

the flow of Tributary Creek could be expected 

by the loss of drainage area, it is not 

anticipated that it would result in a 20 percent 

reduction of flow. This is because the primary 

area impacted by the expansion is principally 

wetland with intermittent braided channels. 

These types of wetlands principally act as 

storage during precipitation events. 

Additionally, most of the groundwater that 

previously fed the wetland would continue to 

be diverted back to Tributary Creek. 

Under Alternative B, the existing TDF 

would expand from its current footprint. 

The existing site industrial water and 

tailings contact water management and 

infrastructure would remain in place. 

Additional infrastructure will be 

required to continue to divert noncontact surface runoff from undisturbed 

areas around the tailings facility. The 

series of toe drains used to collect and 

route surface runoff on the tailings 

facility would expand as necessary as 

the TDF expands. Additional liners, 

finger and blanket drains beneath the 

tailings and slurry walls constructed 

could also be required to divert 

groundwater around the TDF. 

Infrastructure to manage water would 

be more than that required for the 

Alternative A footprint. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-63 

Figure 3.5-4. Impacts to Watersheds and Streams by Alternative (South). 

 
Chapter 3. Affected Environment and Environmental Consequences

3-64 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Similar to Alternative A, diverting non-contact runoff could increase peak flow velocities 

in the natural stream channel during large storm events. This could potentially cause 

erosion of channel substrates and impact channel geomorphology. While it is anticipated 

that a storm water detention structure would mitigate the effects of the increased flow 

velocities, the Forest Service would require HGCMC to conduct habitat and/or 

geomorphic surveys in Tributary Creek downstream of the TDF expansion area to ensure 

that unanticipated effects are not occurring. This program, including a monitoring plan, 

would be developed and incorporated into the GPO as it is updated to reflect the selected 

alternative. 

The current treatment capacity of the Pond 7 WWTP to the outfall in Hawk Inlet is 3.1 

mgd, although it is permitted to discharge a maximum daily discharge of 3.6 mgd. Under 

the full expansion of the TDF, the existing WWTP would be upgraded or a new WWTP 

would be constructed to provide additional treatment capacity. The additional capacity 

would be needed in order to accommodate the additional volume of tailings wastewater 

that would be collected. At full buildout under Alternative B, EDE (2010) estimated that 

a treatment capacity of 4.6 mgd would be required. To evaluate extreme storm events, 

EDE (2010) estimated that containment and treatment of two back-to-back 10-year, 24-

hour precipitation events would require containment and a treatment capacity of 2.76 

mgd over a 30-day period. 

Similar to Alternative A, potential impacts to the water quality in Tributary Creek could 

occur if the liner is compromised or the runoff and groundwater collection systems fail. 

The duration of these impacts would be until the affected facility is repaired. Water 

could additionally discharge to Hawk inlet through the Pond 7 emergency spillway under 

storm events exceeding the 25-year, 24-hour storm event. 

3.5.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Enlarging the 

quarry rather than developing a new one south of the existing TDF would reduce the 

footprint within the Monument; however, these new storage areas would require 

construction of additional water management infrastructure, collection and potential 

treatment. Mitigated Alternative B would reduce the acreage impact to the Tributary 

Creek watershed from 20 percent to 15 percent, when compared with HGCMC’s 

proposed action, Alternative B (Figure 3.5-4). The slight difference in wetlands impacted 

may produce a very minor improvement in flow attenuation and groundwater discharge 

to Tributary Creek compared to Alternative B. The relocated reclamation material 

storage area may have a similar minor adverse effect on flow in the unnamed watershed 

in its new location. 

Potential impacts to stream channel substrates and channel geomorphology would be the 

same as described for Alternative B. These potential impacts could be mitigated by using 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-65 

a storm water detention structure or detention pond at the confluence of the diversions 

and the natural channels. While it is anticipated that a storm water detention structure 

would mitigate the effects of the increased flow velocities, the Forest Service would 

require HGCMC to conduct habitat and/or geomorphic surveys in Tributary Creek 

downstream of the TDF expansion area to detect any unanticipated effects. This 

program, including a monitoring plan, would be developed and incorporated into the 

GPO as it is updated to reflect the selected alternative. 

This alternative would require the construction of additional infrastructure to collect 

wastewater from the TDF expansion in the northeast corner of the facility. The portion of 

the expansion that would be in the Cannery Creek watershed would require separate 

infrastructure for collection of surface runoff and TDF effluent collected in the floor 

drains. Separate collection ditches, a collection pond, and wet wells would be required at 

the northeast portion of the facility. Wastewater collected from this area would need to 

be pumped to the existing WWTP on the south of the TDF during operation and after 

closure. Management of this collection system and pumping of TDF effluent to the 

WWTP would be required as long as active treatment is required to meet Alaska WQS, 

perhaps in perpetuity. 

The northeast expansion under this alternative would dispose of tailings and develop 

infrastructure facilities near Cannery Creek. Cannery Creek is a drinking water source 

and a source of freshwater for HGCMC. The risk of impacts to water quality in Cannery 

Creek from fugitive dust would increase during tailings placement. Additionally, 

potential impacts to water quality in Cannery Creek could occur if the liner of the TDF 

was compromised or the collection pond failed. 

Like alternatives A and B, potential impacts to the water quality in Tributary Creek could 

occur if the liner is compromised, or the groundwater collection systems fail. The 

duration of these impacts would be until the affected facility is repaired. Water could 

additionally discharge to Hawk inlet through the Pond 7 emergency spillway under storm 

events exceeding the 25-year, 24-hour storm event. 

3.5.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Under Alternative C (see figures 2.3-3a, 2.3-3b, 

and 2.3-3c in Chapter 2), the existing TDF would 

be slightly larger than the currently permitted 

footprint. In addition to the expansion of the 

existing TDF, a new TDF would be constructed to 

the north of the Monument boundary (see Figure 

2.3-3a in Chapter 2). 

The expansion of the existing TDF under 

Alternative C would require construction of water 

management infrastructure similar to that described 

for alternatives A and B. At the new TDF, new 

runoff diversions would be required to divert noncontact surface water runoff from the TDF. New 

finger and blanket drains, and groundwater curtain 

and slurry walls would be required to divert 

groundwater flow around the TDF. Effluent 

The additional expansion of the 

existing TDF footprint to the south 

site would reduce the Tributary 

Creek watershed by an additional 

3 percent. Similar to Alternative 

B, some minor impacts to the flow 

of Tributary Creek could be 

expected by the loss of drainage 

area; however, it is not anticipated 

that it would result in a 3 percent 

reduction of flow. Most of the 

groundwater that previously fed 

the wetland is being diverted back 

to Tributary Creek.
Chapter 3. Affected Environment and Environmental Consequences

3-66 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

seepage and runoff from the TDF would be collected and pumped to the WWTP for 

treatment. The amount of water management infrastructure would expand as the new 

TDF expanded. 

The total footprint of the two TDFs would be larger than the total TDF footprint of 

Alternative B. The increased requirement for the amount of water management 

infrastructure required under this alternative would be proportional to the increased 

acreage and the increased amount of total perimeter of the two facilities. Effects to the 

mine site water balance should be similar to those presented for Alternative B. However, 

a larger water treatment capacity could be required because of increased volume of runoff 

from the two TDFs. 

An additional pond to contain surface runoff from the new TDF to the north would need 

to be designed and built. Additional pumps, pump stations, and a pipe system would be 

required to pump captured tailings contact water to the existing Pond 7 for treatment and 

discharge to the Hawk Inlet NPDES outfall. The pipe system would be approximately 

20,000 feet and would follow the existing road alignment. A break in this pipeline could 

result in spillage entering Hawk Inlet, Fowler Creek, other small streams, or wetlands, 

resulting in temporary water quality impacts. With procedures in place to reduce the 

magnitude of a potential spill and lack of proximity of the pipeline to major stream 

resources, effects from a pipeline break would likely be short term and not substantial. 

Additional storm water controls could also be necessary to control runoff from roads and 

other required facilities. At closure, captured TDF effluent from the northern TDF would 

be pumped to the WWTP plant located near the existing TDF. Pumping of TDF effluent 

to the WWTP would be required as long as active treatment is required to meet Alaska 

WQS, perhaps in perpetuity. 

A new truck wheel wash facility and associated water collection system would also be 

constructed at the new TDF to prevent tracking of tailings and waste materials away from 

the TDF. Establishing this truck wash would require HGCMC to obtain a water right to 

use water from Fowler Creek. The truck wash at the current truck facility requires on 

average 36 gpm. At this or a similar withdrawal rate, only minor impacts to the base 

flow of Fowler Creek would be expected. 

The new TDF footprint would reduce a portion of the Fowler Creek watershed by 

approximately 2 percent. The Tributary Creek watershed would be reduced by an 

additional 3 percent. Only minor impacts to both the base flow and storm flows of 

Fowler Creek and the other drainages would be expected, because groundwater and noncontact surface water would also be routed around the new TDF down gradient to Fowler 

Creek (figures 3.5-4 and 3.5-5). 

Potential impacts to stream channel substrates and channel geomorphology from noncontact diversions would be the same as described for alternatives A and B. While it is 

anticipated that a storm water detention structure would mitigate the effects of the 

increased flow velocities, the Forest Service would require HGCMC to conduct habitat 

and/or geomorphic surveys in Tributary Creek downstream of the TDF expansion area to 

detect any unanticipated effects. This program, including a monitoring plan, would be 

developed and incorporated into the GPO as it is updated to reflect the selected 

alternative. 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-67 

Figure 3.5-5. Impacts to Watersheds and Streams by Alternative (North). 

 
Chapter 3. Affected Environment and Environmental Consequences

3-68 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Establishing a new TDF would potentially allow fugitive dust to adversely affect water 

quality in new watersheds at Fowler and North Hawk Inlet. BMPs would be employed to 

minimize fugitive dust from blowing off the tailings stack. 

Like alternatives A and B, potential impacts to the water quality in Tributary Creek could 

occur if the liner is compromised or the runoff and groundwater collection systems fail at 

the south TDF. Similar short-term water quality impacts could occur to Fowler Creek 

should the liner or collection systems fail at the North TDF. The duration of these 

impacts would be until the affected facility is repaired. Water could additionally 

discharge to Hawk inlet through the Pond 7 emergency spillway and the water collection 

pond for the north TDF under storm events exceeding the 25-year, 24-hour storm event. 

3.5.3.6 Effects of Alternative D, Modified Proposed Action 

Under Alternative D, the existing TDF would be enlarged to a greater extent than under 

Alternative C but less than under Alternative B. In addition to the expansion of the 

existing TDF, a new TDF (see figures 2.3-3a, 2.3-3b, and 2.3-3c and figures 2.3-4a, 

2.3-4b, and 2.3-4c in Chapter 2) would be constructed in the same location as under 

Alternative C. 

Additional water management infrastructure at the expansion of the existing TDF would 

be similar to that described for alternatives A and B. At the new TDF, new runoff 

diversions would be required to divert non-contact surface water runoff from the facility. 

New finger and blanket drains, and groundwater curtain and slurry walls would be 

required to divert groundwater flow around the facility. The amount of water 

management infrastructure would expand as the TDF expanded. Effects to the mine site 

water balance would be similar to those presented for Alternative C. 

The total footprint of the two TDFs would be larger 

than the total footprint of Alternative B and slightly 

larger than the footprint of Alternative C. The 

increased requirements for the amount of water 

management infrastructure required under this 

alternative would be similar to that described for 

Alternative C. Additional pumps, pump stations, and 

a pipe system would be required to pump captured 

tailings contact water to the existing Pond 7 for 

treatment and discharge to the Hawk Inlet NPDES 

outfall. The pipe system would follow the existing 

road alignment approximately 20,000 feet. A break 

in this pipeline could result in spillage entering Hawk 

Inlet, Fowler Creek, other small streams, or wetlands, resulting in temporary water 

quality impacts. With procedures in place to reduce the magnitude of a potential spill and 

lack of proximity of the pipeline to major stream resources, effects from a pipeline break 

would likely be short term and not substantial. A truck wash facility would be 

established and a water right to withdrawal water from Fowler Creek would be required. 

After closure, pumping of TDF effluent to the WWTP would be required as long as 

active treatment is required to meet Alaska WQS, perhaps in perpetuity. 

Potential impacts to stream channel substrates and channel geomorphology from noncontact diversions would be the same as described for Alternative C. While it is 

The additional expansion of the 

current TDF footprint at the 

south site would reduce the 409 

acre Tributary Creek watershed 

by an additional 5 percent. The 

impacts to the flows in Tributary 

Creek and to Fowler Creek 

would be similar to those 

described for Alternative C 

(figures 3.5-4 and 3.5-5). 
3.5 Water Resources – Surface Water 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-69 

anticipated that a storm water detention structure would mitigate the effects of the 

increased flow velocities, the Forest Service would require HGCMC to conduct habitat 

and/or geomorphic surveys in Tributary Creek downstream of the TDF expansion area to 

detect unanticipated effects, if any. This program, including a monitoring plan, would be 

developed and incorporated into the GPO as it is updated to reflect the selected 

alternative. As with Alternative B, additional monitoring is being considered to detect 

unanticipated habitat and/or geomorphic effects. 

Establishing a new TDF would potentially allow fugitive dust to adversely affect water 

quality in a new watershed. BMPs would be employed to minimize fugitive dust from 

blowing off the tailings stack. 

Like Alternative C, potential impacts to the water quality in Tributary Creek could occur 

if the liner is compromised or the runoff and groundwater collection systems fail at the 

south TDF and short-term water quality impacts could occur to Fowler Creek should the 

liner or collection systems fail at the north TDF. The duration of these impacts would be 

until the affected facility is repaired. Water could additionally discharge to Hawk inlet 

through the Pond 7 emergency spillway and the water collection pond for the north TDF 

under storm events exceeding the 25-year, 24-hour storm event. 

3.5.4 Surface Water – Summary 

Geochemical modeling conducted by HGCMC indicates that there is very little difference 

in the expected water quality of tailings seepage and runoff among alternatives. It also 

suggests that water treatment may be required for at least 100 years after closure, perhaps 

in perpetuity. 

Some small changes to the flow regime would occur to base flows and storm flows in 

affected drainages (Tributary Creek under all alternatives; Fowler Creek under 

alternatives C and D) under all alternatives. However these changes would not be out of 

the realm of normal fluctuations and would not result in changes to stream 

geomorphology, sediment loads or fish habitat. Potential impacts to stream 

geomorphology from non-contact diversions would be mitigated using storm water 

detention structures or detention ponds. 

The requirements for increased water management infrastructure and the complexity 

associated with maintaining those facilities to contain tailings contact water and manage 

industrial storm water would be highest for alternatives C and D. For alternatives C, D, 

and Mitigated Alternative B, pumping of the effluent from additional TDF collection 

points to a water treatment plant would be required as long as active treatment is required 

to meet Alaska WQS, perhaps in perpetuity. The northeast expansion under Alternative 

Mitigated B would place tailings and infrastructure facilities near Cannery Creek. The 

northeast expansion under this alternative would increase the risk of water quality 

impacts to Cannery Creek, HGCMC’s drinking water source. 

Under all alternatives, potential impacts to the water quality in Tributary Creek could 

occur if the liner is compromised or the runoff and groundwater collection systems fail at 

the south TDF. Under alternatives C and D, short-term water quality impacts could occur 

to Fowler Creek should the liner or collection systems fail at the north TDF. Discharges 

to Hawk Inlet from collection ponds could occur over emergency spillways if a storm 

event exceeds the 25-year, 24-hour storm event. 
Chapter 3. Affected Environment and Environmental Consequences

3-70 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.6 Water Resources – Groundwater ______________ 

Groundwater in the Greens Creek project area is found in several aquifers. These 

include: a shallow peat/sand aquifer underlain by a silt confining unit, a till aquifer, and a 

deeper bedrock aquifer. The following subsections describe these resources and the 

potential effects that may occur under the various alternatives. 

3.6.1 Water Resources - Groundwater – Pre-mining 

Environment 

There is no known regional aquifer system in the project area. However, the aquifer 

systems in this area are typical of those in the glaciated environment of southeast Alaska. 

Regionally, the irregular topography and geology make for numerous small-scale 

aquifers and groundwater flow systems. Groundwater can be found in peat, glacial, 

marine, fluvial sediments, and fractured bedrock aquifers. Where bedrock is exposed or 

near the land surface, the sedimentary aquifers and confining materials are absent. The 

existing tailings facility is located on a beach terrace formed by deposition of marine 

sediments. 

3.6.1.1 Hydrogeologic Units 

Hydrogeologic units present at the site occur in layers (or units) and are described below. 

Peat: Peat is dense organic matter, often containing root masses and stumps. It was 

found widely throughout project area prior to development and remains a commonly 

occurring substrate outside disturbed areas, except on some of the steeper sloping areas. 

The peat varies in thickness, with a maximum thickness of approximately 20 feet. Peat 

deposits developed during recent geologic times on gently sloping areas. 

Oxidized Sand: Sand occurs as a relatively thin layer across much of the project area 

directly beneath the peat. The sand is generally coarse and gravelly, with a moderate 

amount of silt and traces of marine shell fragments. The sand layer resulted from beach 

or alluvial deposits during periods of higher sea levels. In places, the sand is over 20 feet 

thick, but in most areas of the project area, it is about 2 to 10 feet thick. 

Marine Sand with Silt and Clay: Directly beneath the sand layer that covers most of the 

site is a relatively continuous layer of marine sand with silt and clay. This layer reaches 

50 feet in thickness in places, and it is sometimes inter-layered with the underlying 

glacio-marine unit. Analyses of this layer indicate that it is made up of approximately 40 

percent silt, 30 percent clay, and 30 percent sand. 

Glacio-Marine Unit (formerly considered till): This unit, thought to be primarily 

marine in origin, is characterized by high silt and clay content, glacial dropstones, and 

reworked glacial sediments or till. Isolated pockets of stratified sand and gravel from 

glacial activity are also found within this unit. The unit lies beneath the marine sand 

layer and directly above bedrock; it is present throughout much of the area except where 

shallow bedrock occurs. The thickness averages about 15 feet, but it is up to 60 feet deep 

in places. 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-71 

Bedrock: Bedrock in the area consists of hard, banded schist, phyllite, and argillite. 

These rocks are metamorphosed from volcanic and marine sedimentary rocks. The 

bedrock surface is highly irregular—in some places it stands out with minimal soil cover; 

in others, basins are filled with layers of glacio-marine silt and clay, marine sand and silt, 

oxidized sand, and peat. The bedrock in the project area is not highly fractured. 

3.6.1.2 Groundwater Flow 

Groundwater flow is strongly influenced by local geological features and surface water 

drainages and is driven by local precipitation, snowmelt, and the local terrain. With 

average annual precipitation at the site of approximately 60 inches, groundwater recharge 

is large, above 10 percent of average annual precipitation. Flow is generally from the 

ridge to the east of the existing TDF to Hawk Inlet on the west. The steep ridge to the 

east is a bedrock recharge area, with Hawk Inlet the major discharge area. More locally, 

the TDF straddles a three-way divide, with groundwater flow components draining 

towards Cannery Creek to the north, Tributary Creek to the south, and Hawk Inlet to the 

west. A minor bedrock recharge area is the bedrock knoll at the northwest corner of the 

site. 

Groundwater is found in several aquifers, listed from top to bottom: 

 Peat/Sand Aquifer: Peat and sand units are physically adjacent and function as a 

single aquifer. The peat/sand aquifer is underlain by a silt layer that functions in 

places as a confining unit between the peat/sand aquifer and the underlying aquifer 

that occurs within the glacio-marine layer (EDE 2007). Flow in the peat/sand aquifer 

is unconfined, with a water table close to the land surface. The water table fluctuates 

seasonally. 

 Glacio-Marine Deposit Aquifer: This aquifer includes groundwater present in the 

marine sand and the glacio-marine units. Groundwater in these undifferentiated 

deposits occurs mainly in isolated small sand and gravel lenses within the deposits. 

The majorities of the deposits are of relatively low permeability and are intermediate 

in permeability between sandy units and silt/clay units at the site. On a local scale, 

the more silty portions of the deposits serve as confining units for sand and gravel 

units within the aquifer (EDE 2007). Flow in this aquifer is confined and wells 

exhibit artesian conditions in the discharge areas for Tributary and Cannery creeks. 

 Bedrock Aquifer: The entire area is underlain by bedrock that contains groundwater 

in fractures. In areas where bedrock is near the surface, groundwater is considered to 

be unconfined; in areas where the bedrock is covered by other materials, groundwater 

is considered to be confined (EDE 2007). Artesian conditions occur in areas where 

bedrock is overlain by glacial and marine deposits, (e.g., in the discharge areas for 

Tributary and Cannery Creek). 

Groundwater discharges to the surface from the peat/sand aquifer on all sides of the 

groundwater divide. Groundwater discharge forms a marsh near Cannery Creek. The 

marsh and Cannery Creek are a discharge area for groundwater whose sources are the 

peat and the gravelly sand underlying the peat. The sand source may indirectly discharge 

to the creek via the peat, as the sand and the peat are in hydraulic communication. As a 

discharge area for shallow groundwater, Cannery Creek controls groundwater levels in 

the peat and gravelly sand along the north and northeast side of the groundwater divide 

(EDE 2002a). 
Chapter 3. Affected Environment and Environmental Consequences

3-72 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

On the south side of the groundwater divide, groundwater feeds Tributary Creek during 

base flow conditions. Tributary Creek is a perennial stream. Flow/wet conditions are 

observed in this headwater area during relatively dry periods without visible surface 

tributaries, which indicates that Tributary Creek is a local groundwater discharge area for 

the aquifers south of the groundwater divide (EDE 2002a). 

On the west side of the groundwater divide, peat discharges into several small 

intermittent and ephemeral channels, particularly after a recharge event (rainfall or 

snowmelt) (EDE 2002a). 

Groundwater flow within the bedrock appears to follow the topography down-gradient, 

with a general east to west gradient toward the ocean at Hawk Inlet. The northwest 

bedrock knob is a local groundwater recharge area, with flows following the topography 

and not adhering to the principal east to west gradient. 

3.6.1.3 Groundwater Quality 

Groundwater in and around the project area is exposed to variable geologic materials: 

decomposition of peat creates acidic muskeg water, while groundwater in contact with 

marine sediments is more alkaline in nature. Bedrock composition is also variable. A 

series of wells are completed in various strata in and around the project area. 

Examination of the field data shows that the specific conductance values of background 

water are relatively low, ranging from 95 μS/cm (micro Siemens per centimeter) to 

258 μS/cm. Specific conductance is a measurement of total dissolved solids and salts and 

is used as an indicator of sulfate and other salt concentrations. The pH values are 

generally neutral or lower, ranging from 5.2 to 7.5. The alkalinity ranges from 30 to 160 

mg/l as CaCO3. Groundwater in the peat/sand aquifer is at least slightly reducing (as 

opposed to oxidizing) (EDE 2002b). 

Pre-mining groundwater quality for four wells in peat, glacio-marine sediment, and 

bedrock is shown in tables 3.6-1 and 3.6-2. Water quality for the peat/sand aquifer and 

glacio-marine aquifers was measured from 1988 to the present and, thus, 1988 data was 

used as representative pre-mining baseline data. However, no bedrock water quality data 

exists until 2000; thus, bedrock wells upstream of the tailings facility were selected to 

represent pre-mining water. Because shallow groundwater supports a majority of base 

flow in area streams, applicable surface Alaska WQS are shown for comparison to 

groundwater quality for the peat/sand aquifer and the glacio marine aquifer. Surface 

Alaska WQS were discussed in Section 3.5. 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-73 

Table 3.6-1. Pre-mining Groundwater Quality in Peat/Sand Aquifer (Data from 1988). 

Parameter 

MW-1S MW-2S MW-3S MW-4 MW-5 

Most 

Stringent 

Water 

Quality 

Avg Min Max Avg Min Max Avg Min Max Avg Min Max Avg Min Max Standard 

Total 

Alkalinity, mg/l 

as CaCo3

132.4 102.7 153.9 148.2 119.7 171.0 136.8 119.7 171.0 92.3 85.5 102.6 112.9 85.5 136.8 Not 

applicable

Specific 

Conductance 

(μS/cm @ 

25c) 

240 140 338 380 165 1801 208 138 252 190 100 458 202 125 310 Not 

applicable

pH, lab, s.u. 6.46 6.30 6.70 6.29 6.00 6.50 5.99 5.90 6.40 7.47 7.20 7.60 5.78 5.30 5.90 6.5-8.5 

Arsenic, 

dissolved, μg/l

<5 <5 <5 <5 <5 <5 13 8 20 <5 <5 6 8 <5 37 10 

Barium, 

dissolved, μg/l

130 80 190 128 37 260 140 <20 390 45 <20 100 106 40 170 2,000 

Cadmium, 

dissolved, μg/l

<2 <2 <2 8 <2 58 <2 <2 3 <2 <2 <2 <2 <2 <2 0.14 

Copper, 

dissolved, μg/l

13 5 36 10 <2 22 4 <2 9 5 <2 20 14 <2 49 3.1 

Lead, 

dissolved, μg/l

12.5 <10 30 18 <10 110 <10 <10 <10 <10 <10 <2 <10 <10 <2 1.07 

Selenium, 

dissolved, μg/l

<5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 5 

Silver, 

dissolved, μg/l

<2 <2 <2 <2 <2 <2 <2 <2 <2 <2 <2 <2 <2 <2 <2 0.85 

Sulfate, mg/l 2 1 3 3 2 8 3 1 9 5 4 6 18 10 34 250 

Zinc, 

dissolved, μg/l

74 35 180 438 49 2900 81 55 150 27 9 94 81 <2 130 61 

Notes: 

Averages are calculated using half detection limit. 

In the peat/sand aquifer, pH values regularly fall below the aquatic life standard lower limit of 6.5. Barium, 

copper, lead, and zinc concentrations also exceed the WQS. 

Criteria for hardness based metals (cadmium, copper, lead, nickel, silver, and zinc) are based on the longterm average hardness of 46 mg/L CaCO3 in Tributary Creek 

< denotes a value below the analytical method detection limit 
Chapter 3. Affected Environment and Environmental Consequences

3-74 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.6-2. Pre-mining Groundwater Quality in Glacio-Marine Aquifer (Data from 1988). 

Parameter 

MW-1D MW-2D MW-3D Most 

Stringent 

Water Quality 

Avg Min Max Avg Min Max Avg Min Max Standard 

Total Alkalinity, mg/l as 

CaCo3

329.2 307.8 342 102.6 102.6 102.6 273.6 239.4 307.8 Not applicable 

Specific Conductance 

(μS/cm @ 25c) 

616 55 910 197 125 330 448 299 500 Not applicable 

pH, lab, s.u. 8.69 8.50 8.80 8.24 8.10 8.40 8.53 8.30 8.80 6.5-8.5 

Arsenic, dissolved, μg/l 75 69 81 68 64 71 32 <5 40 10 

Barium, dissolved, μg/l 244 70 740 36 <20 90 186 73 720 2,000 

Cadmium, dissolved, μg/l <2 <2 <2 <2 <2 <2 <2 <2 <2 0.14 

Copper, dissolved, μg/l 17 <2 66 <2 <2 4 6 3 10 3.1 

Lead, dissolved, μg/l 1 <10 30 <10 <10 10 <10 <10 <10 1.07 

Selenium, dissolved, μg/l <5 <5 <5 <5 <5 <5 <5 <5 <5 5 

Silver, dissolved, μg/l <2 <2 <2 <2 <2 <2 <2 <2 <2 0.85 

Sulfate, mg/l 26 22 45 10 9 11 3 2 4 250 

Zinc, dissolved, μg/l 20 <5 120 8 <2 21 21 <2 92 61 

Notes: 

Averages are calculated using half detection limit. 

In the glacio-marine aquifer, arsenic and barium concentrations commonly exceed WQS. Copper, lead 

and zinc concentrations also exceed the WQS occasionally. 

Criteria for hardness based metals (cadmium, copper, lead, nickel, silver, and zinc) are based on the longterm average hardness of 46 mg/L CaCO3 in Tributary Creek 

< denotes a value below the analytical method detection limit 

3.6.2 Water Resources – Groundwater – Baseline 

Conditions 

The initial discovery of the Greens Creek deposit was made in 1975. In 1989, site 

construction and development work began, and the mine has operated almost 

continuously since that time. Thus, current conditions include the existing TDF and 

supporting infrastructure. 

3.6.2.1 Hydrogeologic Units 

In addition to the hydrogeologic units described in the pre-mining environment section, 

the existing TDF is also a water bearing unit. In the tailings, depths to water range from 

about 33 to 102 feet below the top of the tailings. In the northern part of the pile, the 

tailings water-table surface indicates flow in a generally radial pattern away from the 

southern part of the existing TDF and towards the perimeter of the pile. A mound in the 

phreatic surface corresponds generally to the thickest part of the tailings in the oldest part 

of the TDF. A generally east-to-west flow gradient also appears to exist within the 

tailings, as in the other hydrogeologic units in the area (EDE 2011). 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-75 

3.6.2.2 Groundwater Flow 

The existing TDF has not altered the principal pre-mining groundwater flow system, but 

some local changes are apparent. 

To ensure groundwater does not mix with water that has been in contact with tailings 

(contact water), groundwater control structures were put in place around the TDF. These 

include a bentonite/soil slurry wall and french drain along the eastern margin of the 

tailings facility to divert up-gradient groundwater to Cannery Creek (north) and Tributary 

Creek (south). Slurry walls also exist along the northern, western, and southern margins 

of the facility. Contact water collected by these slurry walls flows into french drains, wet 

wells, and containment ponds for treatment. Part of the tailings area is lined with 

polyethylene liners to prevent contact water mixing with groundwater. The original 

permitted tailings disposal allowed for the facility to be unlined in areas that were 

overlying a Glacio-Marine Clay formation. It was also not lined in areas overlying 

bedrock in the northwest corner of the original facility. Since 2003, all new disposal 

areas are lined. Contact water in the underdrains is a combination of leachate that has 

drained through the TDF (within the containment boundaries) and groundwater that 

upwells to the underdrain collection system in areas that were originally unlined. This 

upwelling occurs because the flow gradient from the Glacio-Marine formation is upward. 

It was found that originally unlined bedrock outcrops protruding under the northwest 

corner of the TDF may have allowed contact water to mix with groundwater. Excavation 

of materials in the northwest corner of the TDF allowed installation of an underdrain to 

convey surface and contact water from the northern to the southwestern part of the TDF, 

in order to reduce flows to a retention pond in the northern portion of the TDF area and 

facilitate long-term closure drainage. One area in the initial location of tailings 

placement is underlain directly by bedrock and is still unlined (EDE 2011). A network of 

blanket drains and finger drains at the base of the tailings collects a mixture of contact 

water and upwelling groundwater. Water from these underdrains is pumped or flows by 

gravity to Pond 7 (EDE 2007). 

Water flow in the aquifers has changed as follows: 

 Tailings: Water moves in the tailings as both saturated flow and unsaturated flow. 

Precipitation in the form of rain and snow enters the tailings. Infiltration occurs even 

though the TDF is sloped and compacted to promote runoff and minimize infiltration. 

Infiltrating water percolates through the upper tailings under unsaturated flow 

conditions, eventually reaching the water table within the tailings. Tailings water 

eventually exits the TDF via the system of under-drains. The drainage water is then 

pumped to Pond 7 for treatment. The flow gradient is toward the blanket drains and 

toward the pumped wet well sumps (EDE 2002). 

 Peat/Sand Aquifer: Excavation of peat and sand underneath the tailings facility has 

removed the peat/sand aquifer underneath parts of the TDF (EDE 2011). Where peat 

was not removed beneath the tailings, it has been compacted and may act as a natural 

liner and hydraulic barrier (EDE 2011). Bentonite slurry walls partially divert 

groundwater flow in this aquifer around the tailings facility. 
Chapter 3. Affected Environment and Environmental Consequences

3-76 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

 Glacio-Marine Deposit Aquifer: This aquifer is still present in its original extent 

underneath the TDF, and flow is confined underneath the tailings (EDE 2011). 

 Bedrock Aquifer: The bedrock aquifer is confined in areas where it is overlain by 

tailings facility deposits. The tailings act as a confining unit. Recharge to the 

original bedrock outcrop area in the northwest of the tailings facility is reduced where 

the tailings facility covers the bedrock, which has lead to a lowering of the 

potentiometric surface in that area. 

Groundwater originally surfaced in muskeg areas to form Tributary Creek. A portion of 

the muskeg area is now covered by the existing tailings facility, and groundwater comes 

to the surface as small perennial seeps and streams to the south of the tailings, continuing 

to contribute to the flow of Tributary Creek. 

The groundwater control structures remove and divert groundwater from the underground 

flow system. An extensive network of monitoring wells and piezometers is in place to 

observe if groundwater heads (pressures) are falling due to groundwater removal. 

Several bedrock wells exhibit trends of falling groundwater levels. Bedrock wells 

located in the Northwest/Pit 5 expansion area of the TDF (MW-T-96-03, MW-T-01-07, 

MW-T-01-09, MW-T-04-13, MW-T-04-14, MW-T-05-01, and MW-T-05-04) show a 

drop in heads around 2008, during the time when excavation and lining in the 

Northwest/Pit 5 occurred. Piezometric water levels appear steady since 2009, and it is 

likely that a new steady-state flow system with lower heads has been created in the 

northwest area of the tailings facility. Bedrock well MW-T-02-11 near the center of the 

TDF shows a similar trend, with a drop in heads occurring in 2007. Heads in bedrock 

also show a declining trend in the East Ridge expansion area. A bedrock well in the 

southwest tailings facility area (MW-T-96-02) exhibits a drop in water levels. A trend of 

declining water levels cannot be confirmed for the southern part of the TDF, partially due 

to a lack of long term established monitoring wells there. To the northeast of the tailings 

facility, groundwater control structures seem to divert water from the peat/sand and 

glacio-marine aquifers into the bedrock aquifer, as evidenced by water levels increasing 

in bedrock well MW-T-96-04, and declining in peat/sand wells MW-T-95-05B and C, 

and glacio-marine well MW-T-95-05A. 

3.6.2.3 Groundwater Quality 

Current groundwater quality is monitored by the operator in accordance with the mine’s 

FWMP for six groundwater monitoring wells surrounding the tailings facility (MW-2S, 

MW-2D, MW-3S, MW-5S, MW-T-00-01A, and MW-T-001C) (Hecla 2009). Additional 

groundwater data was collected for the Stage II Tailings Expansion Hydrologic Analysis 

Update (EDE 2007a). 

Four of the wells (MW-2S, MW-3S, MW-5S, and MW-T-001C) monitored in accordance 

with the FWMP are completed in the shallow peat/sand aquifer, and two (MW-2D and 

MW-T-00-01A) are completed in the glacio-marine deposit aquifer. None are completed 

in bedrock. 

Tables 3.6-3 and 3.6-4 show groundwater quality measured in 2009 for the FWMP for 

peat/sand aquifer and the glacio-marine unit. 
3.6 Wate

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 3.6-3. Groundwater Quality in Peat/Sand Aquifer Wells (after Hecla 2009). 

Sample Date/Parameter 

MW-T-00-01C MW-2S MW-3S MW-5 

5/5/2009 9/22/2009 5/5/2009 9/22/2009 5/5/2009 9/22/2009 5/5/2009 9/22/2009 

Specific Conductance (μS/cm @ 25c) 

61 69 89 127 74 69 65 58 

pH, lab, s.u. 6.12 6.13 5.61 6.35 5.18 5.29 4.99 5.05 Total Alkalinity, mg/l as CaCo3

21.2 28.2 18.5 26.5 26.4 27 16.7 14.7 

Sulfate, mg/l 1.4 2.6 14.4 35.4 0.3 0.2 0.3 0.3 Hardness (mg/l) 24.6 29.6 28.3 54.4 29.1 30.5 10 10.3 Arsenic, dissolved, μg/l 0.184 0.277 4.29 7.02 11.8 11.7 7.84 5.91 Barium, dissolved, μg/l 11.9 18.1 25.7 46 12.9 12 15.6 17.1 Cadmium, dissolved, μg/l <0.002 <0.006 0.006 <0.006 0.013 0.014 0.025 0.029 Chromium, total, μg/l 1.49 1.17 2.2 1.21 11.4 2.77 11.6 3.43 Copper, dissolved, μg/l 0.069 0.131 0.168 0.212 0.335 0.429 0.748 0.876 Lead, dissolved, μg/l 0.0272 0.109 0.224 0.253 0.963 1 1.79 2.63 Nickel, dissolved, μg/l 0.425 0.525 1.66 1.65 1.6 1.55 3.77 3.74 Silver, dissolved, μg/l <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 0.006 <0.003 Zinc, dissolved, μg/l 2.66 0.71 2.74 2.89 10.1 10.9 12.7 14.4 Selenium, dissolved, μg/l 0.167 0.211 0.14 0.142 0.29 0.19 0.586 0.222 Mercury, dissolved, μg/l 0.000566 0.000774 0.000815 0.00177 0.000446 0.00102 0.000858 0.00172 Criteria for hardness based metals (cadmium, copper, lead, nickel, silver, and zinc) are based on the long-term average hardness of 46 

Creek < denotes a value below the analytical method detection limit 
Chapter 3. Affected Environment and Environmental Consequences

3-78 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.6-4. Groundwater Quality in Glacio-Marine Deposit Aquifer Wells (after Hecla 2009). 

Sample Date/Parameter 

MW-T-00-01A MW-2D Average Most Stringent 

Water Quality 

5/5/2009 9/22/2009 5/5/2009 9/22/2009 2009 Standard 

Specific Conductance 

(μS/cm @ 25c) 115 107 213 202 159 Not applicable 

pH, lab, s.u. 6.62 6.52 8.18 8.3 7.41 6.5-8.5 

Total Alkalinity, mg/l as 

CaCo3

44.2 42.5 76 75.5 59.6 Not applicable 

Sulfate, mg/l 5.4 5.6 11.3 7.4 250 

Hardness (mg/l) 51.5 49.5 74.9 77.6 63.4 None 

Arsenic, dissolved, μg/l 0.158 0.148 82.3 72.4 38.75 10 

Barium, dissolved, μg/l 7.2 7.3 6.5 6.4 6.9 2,000 

Cadmium, dissolved, μg/l 0.016 0.012 0.004 <0.006 0.009 0.14 

Chromium, total, μg/l 4.22 4.51 1.21 1.57 2.88 100 

Copper, dissolved, μg/l 0.082 0.059 0.083 0.054 0.070 4.6 

Lead, dissolved, μg/l 0.0059 0.0166 <0.0030 <0.0030 0.006 1.1 

Nickel, dissolved, μg/l 1.11 0.871 0.861 0.559 0.85 27 

Silver, dissolved, μg/l <0.003 <0.003 <0.003 <0.003 <0.003 0.32 

Zinc, dissolved, μg/l 0.52 0.54 0.13 0.29 0.4 61 

Selenium, dissolved, μg/l 0.418 0.322 0.109 0.138 0.247 5 

Mercury, dissolved, μg/l 0.00017 0.000128 0.000103 0.000133 0.00013 0.012 

Criteria for hardness based metals (cadmium, copper, lead, nickel, silver, and zinc) are based on the longterm average hardness of 46 mg/L CaCO3 in Tributary Creek 

< denotes a value below the analytical method detection limit 

In 2006, groundwater in several bedrock wells had elevated sulfate concentrations and 

conductivity. These wells are down-gradient and in close proximity to the TDF. Tailings 

contact water from the old unlined portion of the TDF likely seeped into the bedrock 

aquifer. This is also shown by the increasing (albeit very slowly) sulfate concentration in 

MW-2S. MW-2S is located in an area where groundwater has an upward gradient and 

bedrock water may discharge to the shallow aquifers and surface water. Since then, the 

northwestern part of the tailings facility was excavated to install a liner, before redepositing tailings. Currently, sulfate concentrations remain elevated above pre-mining 

levels but are decreasing in all but two wells measured. Sulfate concentrations increased 

in wells MW-T-04-14 and MW-T-05-04 in the most recent sampling event. It is possible 

that construction for the liner installation temporarily caused the increases. Trends in 

groundwater quality data are analyzed according to the FWMP and reported annually to 

ADEC and the Forest Service. 

Both MW-3S and MW-5S have higher than pre-mining lead and zinc levels. Fugitive 

tailings dust may be contributing to the elevated metal levels monitored at these sites 

(Hecla 2009). 

High dissolved arsenic values have been detected in MW-2D since before mining began, 

and are considered background values. In addition to monitoring these and other sites 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-79 

specified by other permits and through the GPO, HGCMC has initiated a study to better 

define and determine natural background water quality for both surface and groundwater 

in the area. This study will assist the Forest Service and ADEC as well as other agencies 

evaluate site conditions, potential impacts, and mitigation success. 

Specific conductance and sulfate concentrations for bedrock wells as monitored between 

2004 and 2010 are listed in Table 3.6-5. All available data for sulfate for 2010 are listed. 

Table 3.6-5. Sulfate Concentration and Specific Conductance in Bedrock Aquifer Wells 

(adapted from EDE 2007). 

Site Id Sample Date Specific Conductance, Field (μS/cm) Sulfate, Total (Mg/L) 

MW-T-00-02B 4/12/2005 297 19.7 

3/16/2010 266 12.2 

MW-T-01-01A 12/7/2005 47.2 1.61 

MW-T-01-02A 6/30/2004 858 66.4 

9/28/2010 87.3 27.3 

MW-T-01-03A 3/24/2005 604 122 

MW-T-01-04 5/13/2004 1332 566 

MW-T-01-05 8/26/2004 284 11.8 

MW-T-01-06A 3/18/2004 366 40.7 

MW-T-01-06B 3/18/2004 426 58.4 

MW-T-01-07 2/22/2006 1459 645 

5/26/2010 1142 294 

MW-T-01-08 7/2/2004 731 295 

MW-T-01-09 2/22/2006 1358 591 

5/26/2010 1320 424 

MW-T-01-15A 6/30/2004 118.4 5.97 

MW-T-02-07 4/21/2005 799 220 

MW-T-02-08 7/22/2004 878 104 

MW-T-02-11 4/18/2006 404 25.3 

4/26/2010 9.5 

MW-T-04-12 2/23/2006 971 139 

MW-T-04-13 2/8/2006 644 148 

5/27/2010 604 64.3 

MW-T-04-14 2/8/2006 599 27.6 

5/26/2010 629 98.6 

MW-T-05-01 4/18/2006 1739 621 

5/27/2010 907 255 

MW-T-05-04 4/18/2006 500 28.7 

6/30/2010 1054 304 

MW-T-05-06A 2/8/2006 544 158 

MW-T-07-01 5/27/2010 1133 277 
Chapter 3. Affected Environment and Environmental Consequences

3-80 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.6-5. Sulfate Concentration and Specific Conductance in Bedrock Aquifer Wells 

(adapted from EDE 2007). 

Site Id Sample Date Specific Conductance, Field (μS/cm) Sulfate, Total (Mg/L) 

MW-T-07-02 5/26/2010 626 50.4 

MW-T-96-3 6/6/2005 49.1 9.2 

MW-T-96-04 2/8/2006 893 323 

4/25/2010 524 186 

MW-T-98-01 6/6/2005 293 22.5 

4/7/2010 103.4 11.9 

MW-T-98-4 6/6/2005 74.2 4.3 

3.6.3 Water Resources – Groundwater – Environmental 

Consequences 

There are several ways in which the project may affect groundwater. 

Changes of groundwater flow patterns could occur from the construction or expansion of 

tailings disposal facilities and groundwater control structures. Groundwater quality could 

be affected by mixing of contact water with groundwater, spills from concentrate and 

tailings haul trucks, or seepage from the tailings pile itself. Additionally, fugitive dust 

from the tailings may contaminate ground and surface water. Thus, project actions that 

affect the following factors are of most concern in assessing potential effects to 

groundwater resources: 

 Changes in groundwater flow patterns that cause changes in groundwater discharge to 

surface waters; and 

 Water quality changes caused by contact water seeping into groundwater, or fugitive 

dust contaminating near-surface groundwater. 

3.6.3.1 Effects Common to All Alternatives 

Under all alternatives mining activities would continue through at least 2019. 

Groundwater monitoring would continue to be required by the Forest Service and ADEC 

under all alternatives to monitor groundwater levels and determine if groundwater 

contamination occurs so that it can be remedied. 

3.6.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceased, 

disturbed sites were reclaimed, and human activity in the area reduced. The existing TDF 

would continue to be built out to the maximum footprint and height permitted in the 2003 

EIS (Forest Service 2003). After the TDF was fully built out in 2019, reclamation would 

begin as described in the 2003 EIS (Forest Service 2003). Impacts to groundwater would 

be similar to current conditions. The TDF would continue to divert groundwater from the 

Tributary Creek and Cannery Creek drainages through the groundwater management 

structures after closure. Heads in bedrock would remain at a lower level, where a new 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-81 

steady-state flow system has established itself, and heads would keep falling in other 

areas, where a decline is currently occurring until a new steady-state system is achieved. 

The up-gradient groundwater would continue to be diverted around the existing TDF to 

Cannery Creek to the north and Tributary Creek to the south. 

Decreases of elevated sulfate concentrations in bedrock aquifer monitoring wells would 

continue to be monitored, and the effectiveness of excavating and relining sections of the 

originally unlined TDF determined. 

BMPs are currently employed to minimize fugitive dust from blowing off the TDF. 

Additional BMPs may be added if monitoring indicates this is necessary. BMPs to 

reduce fugitive dust are included in Section 3.2.3. After successful reclamation fugitive 

dust would no longer occur. 

3.6.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF and south into the 

Tributary Creek drainage. 

Groundwater flow would be impacted through the presence of the TDF, which would be 

much larger than under Alternative A. The TDF expansion would be constructed with a 

liner and tailings underdrains atop and below the liner. Groundwater collected in the 

tailings underdrains would also be contained, treated, and discharged under the NPDES 

permit. This includes both groundwater originating from infiltration through the pile and 

groundwater passing immediately beneath and contacting the placement location as it 

moves through the local water table. This groundwater would be collected in order to 

avoid potential groundwater contamination from contact with tailings and to promote the 

geotechnical stability of the TDF. The required contact groundwater collection volume 

would increase proportionally to the area of tailings placement, as the TDF was 

expanded. Petros (2011) estimates a drainage from the TDF to be between 107 and 163 

gpm after closure. Additional and increased lowering of groundwater heads in bedrock in 

the expansion area would likely occur. However, similar to Alternative A, up-gradient 

groundwater flow would continue to be diverted around the TDF to Cannery Creek and 

Tributary Creek. 

Groundwater quality could be affected by spills or contact water seeping into 

groundwater. With the extended operating period, the chance of chemical, fuel, or 

concentrate spills introducing contaminants into groundwater would also be extended, 

though a spill would be unlikely. Operational procedures and BMPs are intended to 

reduce the likelihood and severity of a spill so the chance of these effects would be 

limited. Expanding the TDF with a liner and complete set of groundwater control 

structures would limit the probability of contact water entering and contaminating 

groundwater. The groundwater monitoring system will be used to catch unanticipated 

ground water contamination early enough to allow for it to be mitigated. No pyritic rocks 

would be used in the construction of roads or other facilities, to avoid sulfate leaching 

into groundwater. 

The longer time period of an active TDF would allow more fugitive dust to escape the 

tailings stack. Best management methods would be employed to minimize fugitive dust 

from blowing off the tailings stack. This could reduce the metal concentrations in 
Chapter 3. Affected Environment and Environmental Consequences

3-82 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

groundwater potentially contributed by fugitive dust. After reclamation fugitive dust 

would no longer occur. 

3.6.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Relocation of 

these facilities out of wetlands in the area could have a very minor effect on shallow 

groundwater flows and discharge into Tributary Creek. The relocated reclamation 

material storage area could produce very minor effects on the shallow groundwater 

system at its new location. 

3.6.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located approximately three miles north of the existing TDF 

in a portion of the Fowler Creek drainage. Alternative C would also extend the operating 

period of the mine by 30–50 years. Effects to surface and groundwater would be more 

widely spread than in alternatives A and B due to the development of a new TDF and 

supporting infrastructure. 

Disturbances of groundwater from construction and placement of a new TDF would 

occur in a small portion of the previously undisturbed watershed of Fowler Creek and a 

small drainage basin that empties in Hawk Inlet. Groundwater control structures 

including liner and diversion structures similar to the control structures under Alternative 

B would have to be constructed under the new TDF, resulting in minor, local changes in 

groundwater flow patterns in Fowler Creek drainage and potentially in the North Hawk 

Inlet drainage. Lowering of groundwater heads in bedrock in the expansion area could 

likely occur. Reduction in groundwater discharge to both drainages could occur. 

Expansion of the original TDF in the Tributary Creek watershed would also require 

additional liner and water control structures. Effects on groundwater flow in the 

Tributary Creek watershed would be similar to Alternative A. 

With the development of a new TDF, groundwater contamination is also possible in this 

area. Proper construction techniques and BMPs would be used to reduce the likelihood 

of impacts on groundwater quality in the Fowler Creek and the North Hawk Inlet 

drainage. The underdrains of the TDF would be built on a pad of unreactive material. 

Depending on the materials used for the pad, some localized changes in water quality 

characteristics could occur. The underlying pad would be graded and the underdrain 

system designed so that, if the liner was compromised, contact water from the new TDF 

would drain toward Hawk Inlet and avoid Fowler Creek, which supports anadromous fish 

populations. The developed rock quarry could potentially include acid generating 

material that would have to be managed. 
3.6 Water Resources – Groundwater 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-83 

Establishing a new TDF in a new watershed would potentially allow fugitive dust to 

contaminate ground and surface water in this area. BMPs would be employed to 

minimize fugitive dust from blowing off the tailings stack. This would decrease metal 

concentrations in groundwater caused by fugitive dust. After reclamation fugitive dust 

would no longer occur. Adverse impacts from fugitive dust near the existing TDF would 

be smaller. 

3.6.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve the expansion of the existing TDF and the construction of 

the new TDF. Like alternatives B and C, Alternative D would extend the operating 

period of the mine by 30–50 years. The expansion of the existing TDF would be 

substantially smaller than Alternative B; however, larger than the footprint under 

Alternative C. Effects to surface and groundwater would be similar to Alternative C. 

The TDF would be developed similar to alternatives B and C, with a liner and underdrain 

system to capture any contact water and groundwater monitoring surrounding the TDF to 

ensure that contact water is not escaping the system. Should unanticipated contamination 

occur, it has the potential to be more widespread than alternatives A and B because the 

TDF area is greater under this alternative. 

Disturbances of groundwater due to construction and placement of a new TDF would 

occur in the same location as Alternative C. Groundwater control structures including 

liner and diversion structures similar to the control structures under Alternative C would 

have to be constructed under the new TDF, potentially resulting in changes in 

groundwater flow patterns in the Fowler Creek and the North Hawk Inlet drainage. 

Lowering of groundwater heads in bedrock in the expansion area could likely occur. 

Similar to Alternative C the development of a new TDF could potentially impact 

groundwater quality. Depending on the materials used for the pad, some localized 

changes in water quality characteristics could occur. Like Alternative C, the underlying 

pad would be graded and the underdrain system designed so that, if the liner was 

compromised, contact water from the new TDF would drain toward Hawk Inlet and avoid 

Fowler Creek. Similar risks to groundwater quality would exist from development of the 

rock quarry. 

Establishing a new TDF in a new watershed would allow fugitive dust to contaminate 

ground and surface water in this area. Best management methods should be employed to 

minimize fugitive dust from blowing off the tailings stack. This would decrease metal 

concentrations in groundwater that could result from fugitive dust. After reclamation 

fugitive dust would no longer occur. Adverse impacts from fugitive dust near the 

original TDF would be smaller. 

3.6.4 Groundwater – Summary 

The largest impact under all alternatives would be the capture and collection of 

groundwater through groundwater control structures necessary to protect the groundwater 

quality. Groundwater would thus be removed from the groundwater flow system and 

discharged to Hawk Inlet. This ensures that groundwater contamination will not occur, 

but it also reduces the availability of groundwater to recharge surface waters. Based on 

groundwater level monitoring and observed changes at the existing TDF, impacts on 
Chapter 3. Affected Environment and Environmental Consequences

3-84 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

groundwater hydrology under all alternatives would occur, but would be minimal. The 

implementation of groundwater control structures would protect the groundwater quality. 

3.7 Aquatic Resources __________________________ 

Impacts associated with waters of the United States 

are evaluated in Section 3.5, Water Resources – 

Surface Water; Section 3.7, Aquatic Resources; and 

Section 3.8, Wetlands. Aquatic resources in the 

project area occur in the freshwater and marine 

environment. Freshwater aquatic resources are 

present in the streams surrounding the mine, 

associated facilities, and project roads. Marine 

aquatic resources of interest are those found in 

Hawk Inlet and adjacent Chatham Strait, which may 

be influenced by treated water discharge as well as 

concentrate and supply transport. 

3.7.1 Aquatic Resources – Premining Environment 

The historical conditions are presented separately for the freshwater and marine 

environment. 

3.7.1.1 Pre-mining Aquatic Resources – Freshwater 

A total of five major streams or tributaries are present in the project area, including 

Greens, Zinc, Tributary, Cannery, and Fowler creeks (Figure 3.5-1). A few other streams 

also enter Hawk Inlet outside of the project area (Figure 3.5-1). Table 3.7-1 lists the 

length of streams within each watershed by stream class, including tributaries. The 

streams are classified based on the Forest Service stream value class or Aquatic Habitat 

Management Unit class. The classification is based on the Forest Service GIS stream 

layer, where available. Some additional stream channels were added by interpreting high 

resolution LiDAR data collected within potential areas of disturbance. Streams identified 

by LiDAR interpretation that were within potential areas of disturbance were field 

verified in the summer of 2011. Streams identified as “Unclassified” have not been field 

verified and are outside the area of potential disturbance. 

Physical characteristics and water quality of the key streams and watersheds in the area 

are discussed in Section 3.5, Water Resources – Surface Water. Overall, the freshwater 

aquatic resources in the project area prior to development would be considered typical of 

Tongass National Forest, containing resident and anadromous fish species common to the 

region and water quality conditions not markedly different from unaffected stream 

environments of this region.

Benthic macroinvertebrates exhibited diverse populations in Zinc, Greens, and Cannery 

creeks. Common cold mountain stream families of insects were present, dominated by 

mayflies and stoneflies, followed by less abundant caddisflies and dipterans, and 

occasionally stream worms (Oligochaetes) were also present (Forest Service 1983). 

Aquatic resources are directly 

connected to significant Issues 1 

and 3. Impacts to anadromous 

and resident fish streams are 

addressed in this section. 

Measures of impacts to aquatic 

resources include length of 

anadromous and resident fish 

streams impacted and acres of 

fish-bearing watersheds 

impacted. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-85 

Table 3.7-1. Project Area Major Stream and Watershed Characteristics. 

Watershed Name 

Watershed 

Acres 

Stream Length (ft) 

Total (ft) Class I Class II Class III Class IV

Unclassified 

Area a

Greens Creek 14,429 211,340 61,323 60,249 89,768 0 Not mapped

Zinc Creek 3,084 48,849 7,973 32,479 8,397 0 Not mapped

Tributary Creek b 409 10,040 5,169 2,991 0 1,880 Not mapped

Cannery Creek 689 12,761 0 7,420 4,721 0 620

Fowler Creek b 5,089 132,719 38,388 36,208 12,062 1,486 44,575

North Hawk Inlet b 261 7,660 0 4,517 0 703 2,440

Notes: 

Class I = Anadromous fish stream, Class II = resident fish stream, Class III = non-fish stream with 

potential to transport sediment to a fish stream, Class IV = non-fish stream less than 5 feet wide that 

would not affect downstream fish stream water quality.

a. Mapped from LiDAR data as very small streams; not in Forest Service GIS stream layer.

b. Portions of these watersheds were surveyed in greater detail due to proximity to project area. 

As shown in Table 3.7-2, anadromous and resident salmonid species are common in many 

of the project area streams. Coho (Oncorhynchus kisutch), pink (O. gorbuscha) and chum 

(O. keta) salmon were widely distributed in these streams prior to development. Greens 

Creek and Fowler Creek have the largest amount of fish habitat for watersheds affected by 

the project, although much of this habitat is outside the project area. 

Table 3.7-2. Fish Species Found in Streams in or near the Greens Creek Mine Project Area.

Creek 

Juveniles / resident adults Anadromous adults 

Coho 

Salmon 

Cutthroat 

Trout 

Dolly Varden 

Sockeye 

Salmon Sculpin 

Stickleback 

Pink Salmon 

Chum 

Dolly Varden 

Coho 

Salmon 

Greens Creek ++ + ++ 0 ++ + ++ ++ + + 

Zinc Creek ++ + ++ 0 ++ + ++ ++ + + 

Tributary Creek ++ + ++ 0 ++ 0 ++ 0 + + 

Fowler Creek ++ + ++ 0 ++ + ++ + ++ + 

Lower Fowler Tributary ++ + ++ 0 ? 0 0 0 ? + 

Upper Fowler Tributary 0 0 0 0 0 0 0 0 0 + 

Lower Greens Creek 

Tributary 0 0 0 0 0 0 0 0 0 0 

Upper Hawk Tributaries + ? + 0 ++ ++ + ? ? ? 

Cannery Creek 0 ? ? 0 0 0 0 0 0 0 

Note: Abundance indicators: ++ = abundant; + = moderate occurrence or few; 0 = not found; ? = presence 

strongly suspected but not confirmed. Observations were made in the early 1980s, except recently updated 

for Tributary Creek juvenile and resident fish. 
Chapter 3. Affected Environment and Environmental Consequences

3-86 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Chinook salmon (O. tshawytscha), which are rare in island streams of southeast Alaska, 

were also observed in Greens Creek, although its presence may be incidental. Resident 

cutthroat trout (O. clarki clarki) and the more abundant Dolly Varden (Salvelinus malma) 

were also present in most streams, and rarely rainbow trout (O. mykiss). Cannery Creek 

has a large natural fall at the mouth preventing anadromous fish from entering this basin. 

While it is classified as a Class II stream (non-anadromous fish stream) by the Forest 

Service, no fish have been documented. Tributary Creek, a relatively small and lowgradient stream that originates near the existing TDF, also contains anadromous fish. 

Monitoring of metals in fish was very limited prior to mining, including only juvenile 

coho salmon in Tributary Creek. Because of limited data and lack of comparability to 

current studies, results are not reported here. 

Management Indicator Species 

The use of management indicator species (MIS) is directed by the National Forest 

Management Act for forest planning. They are used to represent habitat types that occur 

within the National Forest boundary and/or because they are thought to be sensitive to 

National Forest System management activities. In the Tongass National Forest MIS fish 

species include coho and pink salmon, Dolly Varden char, and cutthroat trout. Coho 

salmon represent anadromous fish that are generally limited in their freshwater life period 

by rearing areas. Pink salmon serve as an indicator of spawning gravel habitat conditions 

as this is their limiting habitat condition in freshwater. Dolly Varden char were chosen 

because of their common distribution in many freshwater systems including high gradient 

streams. Cutthroat trout were selected because of their dependency on small freshwater 

streams, areas often affected by development actions. 

General Historical Stream Habitat Conditions 

Stream conditions prior to mine development were presented in the 1983 EIS. Specific 

stream data was based on surveys by Buell (1981). The information presented below is 

summarized from these surveys. Where available and relevant, recent survey results 

from 2010 and 2011 have been included. 

Greens Creek 

Greens Creek the largest stream in the study area with a watershed area of 14,429 acres. 

The total channel length of Greens Creek is about 10 miles, originating from an elevation 

of over 4,600 feet. The stream empties into Hawk Inlet at a large river delta shared with 

Zinc Creek. The stream has a set of natural falls approximately 4 and 5 miles up from the 

mouth that are considered barriers to fish passage including salmon. The channel 

consists of a Forest Service MMM (medium moderate gradient contained) channel type 

(Paustian 2010). The area below the falls is considered to contain good to excellent 

spawning habitat for pink, chum, and coho salmon as well as Dolly Varden char. Rearing 

habitat is generally fair to good for salmonids in the mainstream, and excellent where the 

channel is braided. 

Zinc Creek 

Zinc Creek with a watershed of 3,084 acres is just north of Greens Creek where it shares 

the delta area at its mouth in Hawk Inlet. In its lower reaches, its channel meanders in a 

flat meadows area. The gradient is generally low, less than 2 percent. A natural 

upstream barrier occurs at about river mile 2.2. Good to excellent spawning habitat 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-87 

occurs in the lower reaches for salmon, Dolly Varden char, and cutthroat trout. Rearing 

habitat for coho salmon, trout, and char is considered good in the lower reaches. The 

mouth of this stream is a Forest Service FPS channel type which is a small floodplain 

channel, typical of valley bottom and flat low lands. 

Tributary Creek 

Tributary Creek is small; about 7,400 feet long with a watershed area of about 409 acres. 

Its drainage area begins near the existing TDF and flows south before it joins Zinc Creek 

at river mile 0.8. It consists of floodplain (FPS) and palustrine (PA) channel types. The 

stream is narrow, low gradient (<2 percent), typical of valley bottoms or low land flat 

muskeg regions. Leaning and fallen trees contribute to pool formation and substrate 

retention, forming pool and riffle complexes. Channel widths are up to 7 to 10 feet in its 

downstream reaches. Flow may be intermittent near its headwaters. The substrate is 

organic in the upstream portions with gravel and sand in the lower parts. Large woody 

debris is present in some areas helping to form pools and retain gravel. The downstream 

portion provides good rearing habitat for coho salmon, cutthroat trout and Dolly Varden 

char. The lower 5,600 feet of this stream is accessible to salmon with and provides 

spawning habitat for coho, chum, and pink salmon as well as cutthroat and rainbow trout. 

Cannery Creek 

Cannery Creek is a non-anadromous stream that was the historical water source for the 

local cannery, located just north of the existing TDF. It also has a small watershed area 

of about 689 acres. A 15-foot high waterfall 50 feet from tidewater blocks anadromous 

fish entry to the system. A reservoir dam is present 0.6 miles upstream from tidewater. 

Between the falls and the dam, the substrate is primarily cobble with some bedrock. 

Water depth was measured ranging from about 0.1 to 1 foot with no spawning or good 

rearing habitat identified for salmonids. Cannery Creek is a Forest Service HCV3 

channel type, which is a high gradient upper valley channel (6 to >15 percent slopes). 

This channel type has deeply incised streams that may provide fish habitat but do not 

contain fish. Anecdotal information suggests resident fish presence in Cannery Creek; 

however, fish were not detected during limited sampling efforts in August 2011. 

Fowler Creek 

Fowler Creek enters Young Bay after being fed by several major tributaries. The Fowler 

Creek watershed area is approximately 5,089 acres, most of which is outside the project 

area. Within the project area two small palustrine stream channels drain from near the A 

Road and contribute to Fowler Creek. These are small streams (approximately 1 to 3 feet 

wide within the project area) with low gradient (0 to 1 percent) containing beaver ponds 

(PAB channel types). These unnamed tributaries to Fowler Creek are described below. 

Other tributaries of Fowler Creek include low and moderate gradient channel types 

including floodplain (FPS), and low gradient contained (LCM – medium low gradient 

contained) channels in the lower portion. Further up the main tributaries moderate 

gradient channels are present including alluvial fan (AFM – moderate gradient) moderate 

gradient (MCM – medium moderate gradient contained), and some smaller high gradient 

channels (HCV – high gradient upper valley) found further up the drainage. Salmon 

including pink, chum, and coho salmon, use this system, as well as Dolly Varden char 

and cutthroat trout. The low-gradient habitat supplies good habitat for rearing coho 

salmon that use pool areas formed by large woody debris and beaver dams. The upper 
Chapter 3. Affected Environment and Environmental Consequences

3-88 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

areas with moderate and higher gradients would be more suitable for resident fish rearing 

and spawning. 

Unnamed Tributary to Fowler Creek and North Hawk Inlet Drainage 

The area contains two small unnamed tributaries to Fowler Creek and two additional 

small unnamed tributaries that drain directly to Hawk Inlet (Figure 3.5-1). One of the 

small Fowler Creek tributaries drains a very large flat area just west of the A Road in the 

central western most area of Fowler Creek (Figure 3.5-1). This drainage includes an area 

of flats with bogs and old and new beaver ponds; the area is heavily vegetated area with 

poorly defined channels. Near the eastern edge, the drainage supports a flow rate of 

approximately 1 cfs (Forest Service 2003). The substrate is composed of mud and 

organic debris. In the eastern region the channel slope increases to 2 to 3 percent. Spot 

sampling using electrofishing, conducted in July 1981, found no fish. The area was 

considered suitable for a small number of fish but was absent any spawning habitat in the 

upper portion of the drainage. This stream does not occur in either the Forest Service or 

Alaska Department of Fish and Game (ADF&G) database. The other (northern) Fowler 

Creek tributary drains an area of muskegs, beaver ponds, and forests. Recent surveys of 

these channels found cutthroat trout present above the road. Downstream of the A Road, 

these unnamed tributaries intersect a Forest Service Class I, palustrine beaver dam/pond 

channel type (Forest Service 2010). This channel is considered an anadromous fish 

stream containing beaver dams and a low gradient (typically less than 1 percent). These 

PAB channels would normally have fine substrate and organic matter bottoms and are 

considered good rearing habitat for fish. 

Two channels flowing north to Hawk Inlet are small and drain muskeg areas. 

Observations in 2011 found no fish present in these channels, but the sampling effort was 

limited. 

3.7.1.2 Pre-mining Aquatic Resources – Marine 

Marine aquatic resources, including habitat and biota, were discussed in both the 1983 

and 2003 EISs. A more detailed description of habitat and environment is provided in the 

Review of Essential Fish Habitat in Hawk Inlet (Oceanus 2003). Information in the 

following sections is primarily from these documents. 

Physical Environment 

Hawk Inlet is a long narrow bay located on the northwest portion of Admiralty Island 

running almost due north and south (Figure 3.5-1) with a narrow inlet opening to 

Chatham Strait to the west. Hawk Inlet is about 7 miles long and ranges from 0.3 to 1.1 

miles wide. The midchannel depth ranges from 35 feet at the shallow sill near the mouth 

to 250 feet. The sill area is near a large stream delta area formed on the eastern side of 

the inlet by outwash from Greens and Zinc creeks. The head of the inlet opens into a 

large cove containing large mudflats. 

With a tidal range of about 25 feet, large tidal exchange of water and strong currents 

occur within the inlet, especially near the entrance. Wind and freshwater inflow also 

influence flows, speed, and vertical mixing, especially near the surface. Currents near the 

sill, where the existing mine Outfall 002 discharge site is located, are about 2.3 ft/sec 

maximum on a flood tide and about 1.3 ft/sec on an ebb tide and in other areas of the inlet 

near the surface (Oceanus 2002). Highest tidal currents occur near the surface and 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-89 

decrease with increasing water depth. Below depths of approximately 100 feet the tidal 

velocities are less than 10 percent of the surface velocities. However, the velocities and 

exchange flows are sufficient to provide mixing of the near bottom layers of the inlet and 

good water exchange between the inlet and Chatham Strait. 

Habitat and Biota 

A variety of intertidal shoreline, subtidal benthic and demersal, and pelagic habitats and 

organisms occur within Hawk Inlet and nearby Chatham Strait. Bottom substrates are 

varied and include muddy, sandy, cobble, and bedrock conditions depending on location, 

depth, and flow within the inlet. Due to currents and wave actions, much of the area 

consists of gravel and cobble. Strong currents scour some portions of the inlet to 

bedrock. The muddy sand habitat is found primarily at the head of the inlet. The 

substrate of the deep central area consists of muds with high organic matter, whereas 

submerged rocky areas occur along the shorelines. 

Hard bottom organisms included anemones (Metridium), large snails (Polinices, 

Nucella), green sea urchins, starfish, sea cucumber, sponges, bryozoans, and variety of 

attached algae. Soft bottom areas support populations of polychaete worms, clams, and 

small crustaceans. The soft and hard bottom tidal and subtidal organisms are similar in 

Young Bay and Chatham Strait but of greater abundance and variety. Table 3.7-3 lists 

the pre-mine development composition of benthic organisms in Hawk Inlet. 

Table 3.7-3. Features of Major Marine Habitat Types in Hawk Inlet, Admiralty Island. 

Habitat Type 

Area 

(hectare)

Number 

of 

Species 

Density 

Organisms per 

square meter Dominant species 

Location in 

Hawk Inlet 

Protected (estuarine) 

intertidal muddy sands 

226.4 36 49,480 Gastropods, 

bivalves, polychaetes 

Head of Inlet 

Protected subtidal 

muddy sands 

147.3 41 7,596 Bivalves, 

polychaetes 

Head of Inlet 

Protected intertidal 

and subtidal muddy 

sands 

48.8 52 13,776 Polychaetes, 

foramanifera, 

bivalves, copepods. 

Piledriver Cove 

Unprotected intertidal 

sand 

41.3 36 99,900 Foramaniferans 

(sponges) 

Greens Creek 

Delta 

Intertidal and subtidal 

rocky 

66.3 — — (samples from 

Chatham) 

Shoreline and 

mouth of Inlet 

Deep subtidal muds 321.8 52 14,061 Polychaetes, 

bivalves 

Basin -- 

Cannery 

Submerged sill of 

sand-gravel-cobble 

187.2 80 30,526 Polychaetes, 

gastropods, 

amphipods 

Greens Creek 

Delta/002 

Nereocystis kelp beds 

(sand) 

125.4 69 67,352 Polychaetes, 

amphipods, bivalves 

Interspersed 

Transition areas 168.5 — — — Interspersed 

Source: Holland et al. 1981. 
Chapter 3. Affected Environment and Environmental Consequences

3-90 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Fish and Shellfish Resources 

A variety of commercial and noncommercial, sport, and subsistence species of fish and 

shellfish resources are present in Hawk Inlet and the surrounding area. Based on surveys 

conducted prior to mine development known commercial fish resources included halibut 

(Hippoglossus stenolepis), flathead (Hippoglossoides elassodon), yellow-fin (Limanda 

aspera) and rock sole (Lepidopsetta bilineata), arrowtooth (Atheresthes stomias), starry 

flounder (Platichthys stellatus), and Pacific cod (Gadus macrocephalus). 

Noncommercial fish include whitespotted (Hexagrammos stelleri) and masked greenling 

(Hexagrammos octogrammus), shortfin eelpout (Lycodes brevipes), snake prickelback 

(Lumpenus sagittal), sturgeon poacher (Podothecus accipenserinus), staghorn 

(Leptocottus armatus) and great (Myoxocephalus polyacanthocephalus) and spinyhead 

(Dasycottus setiger) sculpins, Pacific sandlance (Ammodytes hexapterus), daubed shanny 

(Leptoclinus maculatus), and copper rockfish (Sebastes caurinus). Some Pacific herring 

(Clupea pallasii) had been reported spawning near the inlet entrance, but overwinter use 

was unknown. Young Bay species are likely similar. 

Marine-rearing early juvenile and subadult stages of salmon and anadromous stages of 

trout and Dolly Varden char were also common in Hawk Inlet. Juvenile rearing in the 

inlet would occur for juvenile chum and pink salmon that spend their early rearing 

periods (about 40 days) in waters near their stream of origin. 

Commercial crab including Dungeness (Metacarcinus magister), tanner (Chionocetes 

tanneri), and red king crab (Paralithodes camtchatica) would also have been present, as 

well as noncommercial hermit crabs (Pagurus spp.). Extensive beds of clams including 

littlenecks (Protothaca staminea), cockles (Clinocardium nuttallii), soft shell (Mya 

arenaria), and horse clams (Tresus nuttallii), as well as mussels (Mytilus trossulus) were 

present. 

Metals in Sediment in Hawk Inlet 

Metals have been monitored in Hawk Inlet sediment and selected marine organisms prior 

to and during mining operations. Pre-mining sampling was conducted to provide a 

baseline condition to help determine if metals were potentially causing adverse 

conditions to native biota and to compare to future conditions once mining operations 

began. Originally 10 parameters were sampled in sediment and marine organism tissues: 

silver, arsenic, cadmium, chromium, copper, mercury, nickel, lead, selenium, and zinc. 

Various studies assessing metals in water, sediment, and organisms were conducted prior 

to full production, which began in 1989, including (IEC 1980), Holland et al. (1981), and 

Oceanographic Institute of Oregon (OIO 1984–1988) (all as cited in Oceanus 2003). The 

OIO studies set the parameters for the monitoring program that would be conducted once 

the project began; the program identified the metals and biota to be sampled as well as 

the sample locations. The sampling stations established for this study and carried on 

through project development and operations are shown in Figure 3.5-2. Some 

modifications to the sampled parameters and sample locations have occurred over time to 

adapt to changing conditions and operations (Oceanus 2003; HGCMC 2011). 

Oceanus (2003) summarized and compared sediment and tissue data for the 10 monitored 

metals against a variety of national standards to help compare baseline and operating 

conditions in Hawk Inlet and assess the level of concern for metals in this environment. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-91 

For pre-mining condition comparisons, only stations S-1, S-2, and S-3 were consistently 

monitored prior to mine development. Comparisons of the average metals concentrations 

in Hawk Inlet sediment prior to mine development indicated that many metals at various 

locations exceeded the National Status and Trends levels for low level effects to 

organisms. Average chromium and nickel values were exceeded at all Hawk Inlet sites. 

The arsenic and copper values were slightly above these guideline levels at station S-3. 

3.7.2 Aquatic Resources – Baseline Conditions 

Existing conditions for the freshwater and marine environments are summarized below. 

The characterization is based primarily on monitoring selected streams and Hawk Inlet as 

part of the mine’s monitoring program. The monitoring results for Hawk Inlet compare 

the pre-mining environmental conditions to the conditions after the initiation of mining 

activities. 

3.7.2.1 Baseline Conditions – Aquatic Resources – Freshwater 

Greens Creek Mine operations include roads; process, storage, and transport facilities; 

and instream structures that affect the freshwater environment of the project area. The A 

and B roads include multiple stream crossings in the Greens, Zinc, Tributary, Cannery, 

and Fowler Creek watersheds. A total of two Class I, four Class II, and two Class III 

stream crossings occur along these roads. The existing TDF intercepts some drainage 

area and flow from the Cannery Creek and Tributary Creek drainages, but has not 

directly impacted fish bearing stream channels. As discussed in Section 3.5.2.1, noncontact surface runoff from native areas is diverted from contacting the TDF using 

upslope ditches. Depending on the location, the ditches direct the runoff to either 

Cannery Creek or Tributary Creek. A weir installed on upper Greens Creek, near the 

mine and mill facilities, blocks upstream passage of fish. In 1989, the mine operator 

developed a fish passage facility in a rock chute at river mile 3.6 in a stream segment that 

had been naturally impassible to anadromous species prior to that time (Scannell and 

Paustian 2002). 

Since the mine has been in operation, multiple monitoring activities have been conducted 

in the affected area including an assessment of water quality conditions (see Section 

3.7.1.1, Pre-mining Aquatic Resources – Freshwater) and an aquatic biomonitoring 

program at several of the site area streams beginning in 2001. Aquatic biomonitoring is 

conducted annually and includes two sites on Greens Creek. The aquatic biomonitoring 

program includes measurements of stream periphyton, benthic macroinvertebrates, and 

fish (Scannell and Paustian 2002; Durst and Jacobs 2010, and others). One site on 

Greens Creek (Site 48) is located upstream of all mine activity and is included in the 

annual monitoring program. The second site (Site 54) is located below all mining 

activities and waste rock disposal. A third site (Site 6) is downstream of the mine portals 

and mill facilities but upstream of the waste rock disposal area (Site 23); Site 6 is 

sampled every five years. Tributary Creek (Site 9) is downstream of the TDF and is 

sampled annually. 

Periphyton 

The periphyton abundance and trends, based on chlorophyll pigment analysis, was 

similar among the Greens Creek sites sampled (sites 54 and 48) (Kanouse 2012). 

Periphyton abundance was lowest during 2001, 2002, 2007 and 2008. Peak values 
Chapter 3. Affected Environment and Environmental Consequences

3-92 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

occurred from 2003 to 2006 and corresponded with a period of low stream flow. 

Tributary Creek (Site 9) had similar trends with the highest abundance during 2001 to 

2005 and lower values during 2006 to 2011. Based on pigment composition, the 

Tributary Creek site showed more variability than the two Greens Creek sites. The 

differences in site specific natural environmental conditions relating to flow, stream 

cover, and morphology correspond to the observed differences in species distributions. 

Benthic Macroinvertebrates 

Benthic monitoring studies have presented data on 

abundance (as measured by number of insects per net), 

density (number of insects per square meter), richness 

(as measured by the number of taxa represented), and 

the percentage of Ephemeroptera, Plecoptera, and 

Trichoptera versus Chironomidae within the project 

area. 

Benthic communities were similar among the Greens 

Creek sites, being dominated by mayflies (Ephemeroptera) and much fewer stoneflies 

(Plecoptera), caddis flies (Trichoptera) (EPT taxa) and aquatic true flies (diptera 

consisting of midge and black fly larvae) (Kanouse 2012). Overall, benthic 

macroinvertebrate densities and richness observed at each site in Greens Creek during 

2011 were similar to those observed in the previous 10 years of sampling under the 

biomonitoring program (Kanouse 2012). Taxonomic richness, which can be an indicator 

of water quality conditions, and the large proportion of EPT taxa and pollution-sensitive 

species in samples collected at each site in Greens Creek suggest complex and healthy 

benthic macroinvertebrate communities are present at all three Greens Creek sites. 

Tributary Creek was dominated less by mayflies and contained more non-insect taxa than 

other sites. Mean benthic macroinvertebrate density and richness data from 2011 

Tributary Creek samples were not statistically different compared to data from previous 

years (Kanouse 2012). The aquatic insect community continues to be dominated by EPT 

taxa, many of which were rated “extremely sensitive” to impaired water quality (Kanouse 

2012). As with periphyton, the differences among stations likely result from differences 

in channel morphology, riparian cover, flow rate, and flood frequency. Overall, the high 

portion of taxa intolerant to pollution present in Greens Creek and Tributary Creek, well 

developed complex community structure, and similarity between the control and 

treatment sites on Greens Creek provide an indication that no marked adverse effects 

have occurred to stream ecology in these systems since monitoring began in 2001. 

Fish 

As noted previously, historical accounts describe fish presence and relative abundance in 

local streams. Additionally, streams in the project area have had varied composition and 

abundance of adult salmon. The current aquatic monitoring program examines fish 

abundance, composition, and metals concentration in whole body fish tissue. 

Anadromous Fish Escapement 

Salmon use of the project area streams is common with an index number of spawning 

fish, based on observed peak count escapement, ranging from 0 to about 100,000 fish 

depending on stream and fish species. Peak escapement counts are available for seven of 

Generally high 

Ephemeroptera, Plecoptera, 

and Trichoptera levels 

indicate a relative abundance 

of taxa intolerant to 

pollutants. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-93 

the project area streams, including Greens, Zinc, and Fowler creeks, which could be 

directly affected by the mine’s activities. Survey records are variable among the streams 

so complete comparisons among streams are not possible. Greens Creek has been 

consistently surveyed since 1960, while surveys of other streams were more spotty. 

Aerial surveys have also been the most consistent method of surveying, although foot 

surveys are more accurate, especially for species composition. 

The purpose of most spawning surveys has been primarily to index pink salmon, 

information collected on chum salmon was secondary (Geiger and McPherson 2004). 

However, some general conditions are apparent. Overall, escapement peak count for 

pink salmon in Greens Creek was typically about 7,400 pink salmon and has been as high 

as 100,000. Other streams in the area have had typical peak escapement counts of about 

1,000 to 2,000 pink salmon. Based on a 47-year aerial survey period, the median peak 

escapement for Greens Creek has been about 1,200 chum salmon with observations 

ranging as high as 11,500 fish. Chum salmon escapement peak counts are much lower in 

other area streams. These peak count numbers are much less than the total number of 

escaped salmon attributed to these systems because they represent a point in time and do 

not account for missed fish. 

Fish Monitoring 

Dolly Varden char density (based on total sample reach population estimates) as 

monitored by minnow traps in the three annual monitoring sites have continued to follow 

similar abundance patterns over the eleven-year sampling period (2001–2011) (Kanouse 

2012) (see Figure 3.7-1). The Tributary Creek Site 9 has been more variable over the 

years but generally lower in Dolly Varden char density than Greens Creek sites except 

the markedly higher density in 2010 (Figure 3.7-2). When considering this information, 

it is important to note that the Greens Creek and Tributary Creek systems are 

geomorphically different and each support different aquatic species, including fish, which 

directly influence juvenile Dolly Varden char populations. 

Coho abundance has remained low at Greens Creek Site 54, and has been noticeably 

lower the last five years (2007–2011) (Figure 3.7-2), being absent in 2011 (Kanouse 

2012). The decline in coho abundance at Site 54 is presumed to be due to damage to the 

fish passage structure that occurred in 2005 (Kanouse 2011). The density at this site was 

only one-ninth of the forest average for this channel type through 2009 (Durst and Jacobs 

2010). Coho salmon density in the Tributary Creek site has been highly variable with no 

distinct trends, but with values much higher than the Greens Creek site in nearly all years 

of the study, having the highest density ever in 2010 (Kanouse 2012). In 2009, density 

was greater than 1.5 times the regional average for this channel type (Durst and Jacobs 

2010). However some differences in relative coho salmon density may be related 

channel type, as lower gradient Tributary Creek is more typical juvenile coho salmon 

habitat than the moderate gradient Greens Creek. 
Chapter 3. Affected Environment and Environmental Consequences

3-94 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Source: Kanouse 2012 

Figure 3.7-1. Dolly Varden Char Density at Biomonitoring Sites on Greens and Tributary 

Creeks. 

Source: Kanouse 2012 

Figure 3.7-2. Coho Salmon Juvenile Density at Biomonitoring Sites on Greens and 

Tributary Creeks. 

Additionally, a study compared fish population changes between pre-mining conditions 

(1981) to current conditions (2010 and 2011) in Tributary Creek (Kanouse 2011b). 

Kanouse concluded that fish populations (abundance and composition) were generally 

similar from the pre-mining period (1981) to current conditions (2010 and 2011). One 

apparent exception is fewer cutthroat trout in two of three reaches in the current period 

than in 1981. Although sample design limited obtaining good, statistically comparable 

information some of the highest densities of fish (coho salmon juveniles and Dolly 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-95 

Varden) occurred in 2010 and 2011 compared to lower densities in 1981. Overall fish 

populations appear to be similar from pre-mining to present day in Tributary Creek. 

The change in patterns of Dolly Varden char may relate to high flows in 2005 that greatly 

modified channel conditions in Greens Creek and resulted in continued channel 

modification of pools, gravel, and large woody debris conditions of this system (Durst 

and Jacobs 2010). As a result, habitat in local areas may have become less suitable for 

spawning and rearing Dolly Varden char. The low abundance of coho salmon juveniles 

at the Greens Creek site may be partly related to these habitat changes. Damage to the 

fish passage structure due to high flows in 2005 is presumed to be the cause of low 

juvenile coho numbers in subsequent upstream monitoring (2006–2010) (Kanouse 2011). 

The ADF&G evaluated salmon presence above the barrier before the failure and 

determined that the fish pass was successful (Timothy 2011). Failure of the fish passage 

structure would also affect cutthroat and Dolly Varden movement. In March 2012, 

ADF&G issued Fish Habitat Permit FH11-I-0123 to HGCMC authorizing repair and 

maintenance of the fish pass in perpetuity. Success of the fish pass will be documented 

when juvenile coho salmon are captured upstream of the fish pass during the annual 

biomonitoring sampling. If juvenile coho salmon are not captured within three years 

after fish pass repair, ADG&G will require Hecla to investigate adult coho salmon 

passage through the fish pass. 

Dolly Varden Metals Concentration 

The biomonitoring that began in 2001 has included an assessment of whole body metals 

concentrations at Site 48 (control – upstream of mining activities) and Site 54 (treatment 

– downstream of mining activities) noted above. Monitoring of fish tissues metals 

concentrations is intended as an indicator of whether mining activity may be affecting 

metals concentrations in stream biota. Juvenile Dolly Varden (2–3 years old, determined 

by length) are used for the sampling to ensure metal concentrations are based on resident 

fish populations. The tissue metals monitoring was not intended to indicate direct effects 

to fish but to provide an indicator of how mining operations may influence metal 

availability and trends in the biological environment. 

Overall, monitoring results of Site 48 and Site 54 on Greens Creek provide an indication 

that relative metal concentrations in fish are similar above and below the direct mining 

activity. Comparisons between Site 48 (control) and Site 54 (treatment) indicate that 

nearly every year no statistically significant difference was apparent between the fish at 

the two sites for each of the six metals monitored (Kanouse 2011a) (Table 3.7-4). While 

metals concentration in Dolly Varden is also monitored at Site 9 (Tributary Creek), there 

is no comparable segment upstream of mine-related activities for comparison. 
Chapter 3. Affected Environment and Environmental Consequences

3-96 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.7-4. Number of Years Dolly Varden Char Total Body Metals Concentration 

Ranked Relative to Indicated Sites (2001–2010). 

Greens Creek Site 54 (treatment) Relative to Site 48 (control) 

Relative to Silver Cadmium Copper Lead Selenium Zinc 

Higher 0 1 0 1 2 0 

Same 10 8 10 8 8 10 

Lower 0 1 0 1 0 0 

Tributary Creek Site 9 Relative to Greens Creek Sites (54 and or 48) 

Relative to Silver Cadmium Copper Lead Selenium Zinc 

Higher 7 1 0 8 2 0 

Same 3 7 6 2 6 2 

Lower 0 2 4 0 1 8 

Source: Kanouse 2011a and others 

One exception was an increase in lead at the Greens Creek downstream site in 2009 

relative to the upstream site, but lead levels observed in fish tissue have been higher in 

the past at both sites. A dedicated control for the Tributary Creek site was not available 

but comparison with the Greens Creek sites suggests some differences in metals in the 

fish. Most often silver and lead concentrations are higher in Tributary Creek Dolly 

Varden char than in Greens Creek fish, while zinc levels are often lower. The other 

metals including cadmium, copper, and selenium are usually similar between sample sites 

at these creeks. The reasons for these trends are not readily apparent. Water quality 

samples taken from the Greens and Tributary creeks in 2010 tend to mirror these 

differences with relatively higher lead and silver concentrations in Tributary Creek 

samples than in Greens Creek (HGCMC 2010; also see Section 3.5, Water Resources – 

Surface Water). Metals concentrations in Dolly Varden char have remained relatively 

consistent from year to year with little evidence of any trends (increasing or decreasing) 

over the 10 years of sampling. 

In summary, the biological conditions at Greens Creek and Tributary Creek have 

remained robust, as measured by the diversity and productivity during the study period. 

No trends in reduced ecological function have been observed. However, reduced coho 

abundance in Greens Creek and reduced benthic abundance in Tributary Creek are 

conditions that would continue to be monitored by the operator and ADEC. 

3.7.2.2 Baseline Conditions – Aquatic Resources – Marine 

The general marine physical, habitat and biota conditions, and overall fish and shellfish 

species noted in the pre-mine conditions in Hawk Inlet area remain unchanged under 

current conditions. However, past and current harvest of commercial and sport marine 

species may have changed. Additionally, historic and existing metals concentrations in 

the marine environment and their uptake by marine organisms may have changed from 

pre-mining conditions. Local harvest of marine fish and shellfish, and metals 

concentrations in tissues of these species relative to pre-mine production conditions are 

discussed in this section. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-97 

Commercial and Sport Fish and Shell Fish Harvest 

Information on amount of harvest by sport, commercial, and subsistence fishing in the 

Hawk Inlet area has not been well documented. Some commercial halibut fishing 

between 1914 and 1976 produced large catches. Apparently between that period and 

mine opening in 1987, little commercial halibut fishing occurred in the inlet. Also, some 

commercial crab and shrimp fishing occurred in the inlet. Shrimp and scallop of 

commercial value have been found in or at the mouth of the inlet. 

The Chatham Strait area of southeast Alaska supports substantial commercial harvest of 

fish and shellfish. Salmon is the largest local harvest. Current harvest in or near Hawk 

Inlet has also been substantial for some species (Table 3.7-5). Information on harvest 

within the inlet is limited but it is known to be a popular crabbing area for recreational 

and commercial fishing. 

Table 3.7-5. Commercial Fish and Shellfish Harvest in Hawk Inlet Area, 2001–2010. 

Species 

Statistical Area 112-16 Statistical Area 112-65 

West Mansfield Peninsula (part of 

Chatham Strait) Hawk Inlet 

Years Number Pounds Years Number Pounds 

King Salmon 2001–2010 291 4,264 

Sockeye Salmon 2001–2010 39,163 222,954 

Coho Salmon 2001–2010 25,084 168,410 2001–2010 475 3,158 

Pink Salmon 2001–2010 2,452,447 8,640,254 

Chum Salmon 2001–2010 147,278 1,167,476 

Spot Shrimp 2001–2010 Yes 2001–2010 Yes 

Sea Cucumber 2002, 2005, 

2008 

 22,718 2002, 2005, 

2008 

 27,483 

Dungeness Crab 2001–2010 12,227 2001–2010 15,793 

Tanner Crab 2003–2008 Slight 2003–2008 8,547 

Golden King 

Crab 

2001–2010 11,215 2001–2010 None 

Red/Blue King 

Crab 

3 Years Slight 3 Years 329 

Sources: ADF&G Personal Contacts May 18, 2010: Adam Messmer, David Harris. 

Notes: 

Salmon pounds are approximate based on average seasonal weights. 

All values are yearly average. 

Coho Salmon: only troll fishery in Hawk, area 112-16 include troll and seine fishing. 

Spot Shrimp: harvest but less than 3 permit holders so no information can be released. 

Sea Cucumber: only open these years in last 10 years. 

Dungeness Crab: one year had no effort in 112-16 so average for 9 years. 

Tanner Crab: no harvest 2001, 2002, 2009, 2010, and limited permit holders using Chatham. 

Golden King Crab: Hawk Inlet too shallow for species. 

Red/Blue King Crab: only three years in 10 did fishing occur in this area, king crab closed since 2006. 
Chapter 3. Affected Environment and Environmental Consequences

3-98 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Sediment Metals Concentrations 

Monitoring for metals was modified when the parameter list was reduced to five based on 

the USEPA NPDES permit requirements issued in 2005: cadmium, copper, mercury, 

lead, and zinc. Sediment metal concentrations have been monitored for these five metals 

allowing levels to be compared at selected sites. Mine-related activities are the only 

actions that affect sites S-1 and S-2 (Figure 3.5-3), so these sites can be compared to premine conditions. A landslide of sediment related to historic mining activities (pre-Greens 

Creek Mine) located near Site S-3 at the head of Hawk Inlet was thought to potentially 

affect values at this location. The average and range of values for these five metals for 

sites S-1 and S-2 are shown in Table 3.7-6. Based on these data, it appears that heavy 

metals in sediment near the outfall 002 site continue to vary from year to year, and have 

not increased above the range of area-wide baseline levels since operations began 

(HGCMC 2010). 

Table 3.7-6. Hawk Inlet Sediment Data: Pre-Production Baseline, Production Period and 

Current Year Comparison. 

Metal 

Pre-Production 

(6/1984-8/1989) 

Past Production 

(9/1989-9/2009) 

Current 

2010 

Avg Min Max Avg Min Max Avg Min Max 

Cd 0.245 0.03 0.87 0.206 0.06 0.89 0.118 0.11 0.13 

Cu 18.75 11.9 33 14.8 7.5 39.5 10.2 7.5 13.5 

Pb 6.72 2.2 13 5.7 <0.02 23.7 3.94 1.6 6.5 

Hg 0.035 0.002 0.094 0.02 0.02 0.14 0.0307 0.02 0.04 

Zn 96 52.8 155 74 26.1 185 62.4 33.8 101 

Source: HGCMC 2010 Hawk Inlet Monitoring Program Report. 

Note: Data are compilation of results from Stations S-1 and S-2. 

Two events may have effected metals concentrations at two of the sampling sites, S-4 and 

S-5 (Figure 3.5-4). Debris from a fire in 1974 at the old cannery affected metals 

concentrations at sites S-4 and S-5, which were selected to monitor metals near the 

concentrate loading dock. A concentrate spill occurred from the shiploader site in 1989 

at the shiploader facility near Site S-5. In 1995, a suction dredge was used to remove 

sediments in the area of the spill. Based on sampling results, a rapid increase in metals 

concentrations occurred after the spill and sample values have been highly variable but 

remain elevated in the immediate vicinity of the shiploader relative to metals 

concentration in other inlet sampling sites. Following the attempted cleanup in 1995, Site 

S-5 was split into two sites: S-5N (at original Site S-5) and S-5S, which now bracket the 

original spill area (HGCMC 2011). Site S-4 is in the intertidal beach area. As a result of 

recent evaluations, ADEC’s 2012 Draft Water Quality Assessment Report (ADEC 2012) 

has proposed listing a small portion of Hawk Inlet in the area of the 1989 spill as 

impaired under Section 303(d) of the CWA. This proposed listing would not affect the 

area of Hawk Inlet where the 002 discharge outfall is located. 

Average concentrations at Site S-4 have increased for all five metals for a time after 

mining operations began relative to pre-mining concentrations. However, the average 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-99 

concentrations for this station have been decreasing since at least 2002 with the averages 

for all five parameters in 2009 less than they were in 2002 (Oceanus 2003; HGCMC 

2011; Table 3.7-7). Recent average concentrations at the S-5N and S-5S sites were 

higher than at S-4 (Table 3.7-7). At Site S-5S, concentrations of cadmium, copper, and 

lead have remained about the same from 2002 to 2009 while mercury concentrations 

have increased, and zinc concentrations have decreased. 

Table 3.7-7. Average and Standard Deviation Values for Preproduction and Production 

Sediment Data. 

Metal 

(mg/kg 

dw) 

S-1 S-2 

Pre-production 

(9/1984 – 8/1989) 

Production 

(9/1989 – 9/2009) 

Pre-production 

(9/1984 – 8/1989) 

Production 

(9/1989 – 9/2009) 

avg stdev avg stdev avg stdev avg stdev 

Cd 0.253 0.222 0.248 0.186 0.236 0.119 0.174 0.083 

Cu 22.50 5.19 17.9 7.3 15.0 2.68 12.1 4.15 

Pb 8.175 2.628 8.80 4.58 5.26 2.16 2.85 1.79 

Hg 0.0441 0.0209 0.0317 0.0341 0.0253 0.0150 0.0086 0.0204 

Zn 129.18 11.55 102.9 31.3 62.9 6.7 46.4 13.9 

Metal 

(mg/kg 

dw) 

S-4 S-5N S-5S 

Pre-production 

(9/1984 – 8/1989) 

Production 

(9/1989 – 9/2009) 

Post spill 

(9/1989 – 9/2009) 

Post spill 

(6/1995 – 9/2009) 

avg stdev avg stdev avg stdev avg stdev 

Cd 0.761 1.097 0.933 0.909 13.3 41.4 3.85 3.90 

Cu 49.0 19.3 54.4 57.0 260.4 394.8 84.6 43.6 

Pb 108.2 136.8 120.3 138.6 1062 2424 260.2 202.8 

Hg 0.115 0.083 0.216 0.612 2.09 5.75 0.391 0.311 

Zn 179.2 125.5 190.6 189.3 2141 5643 804.1 785.4 

Note: Underlined averages are higher than pre-production averages. Pre-production data are not available 

for sites S-5N and S-5S. 

Oceanus (2003) noted that metals concentrations at S-4, S-5N, and S-5S often exceeded 

the lower ERL (effects range low) guideline levels4 and occasionally exceeded the higher 

effects ERM (effects range medium) guidelines through 2002. For station S-4, ERL 

guidelines for sediment metal concentrations were exceeded during the whole motoring 

period for all ten parameters and most often for copper, lead, nickel, and zinc. The higher 

level effects ERM guidelines were exceeded most often for lead and zinc. Exceedences 

 

4

 National Status and Trends (non-regulatory) numerical sediment quality guidelines (NOAA 1999) relating 

to ranges of biologic effects of various metals in sediment: 

Effects Range Low (ERL) = Based on the 10th percentile of effects observations – ERL is indicative of 

concentrations below which adverse effects rarely occur. 

Effects Range Median (ERM) = Based on the 50th percentile of effects observations – ERM are 

representative of concentrations above which effects frequently occur. 
Chapter 3. Affected Environment and Environmental Consequences

3-100 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

of the sediment concentrations guidance levels occurred both before and after mining 

began for all of the metals, but with greater frequency and for more parameters between 

1989 and 2002. 

The metals levels observed through 2002 in the immediate area of the shiploader could be 

toxic to bivalves amphipods and burrowing organisms in Hawk Inlet. However the 

decrease in metals concentrations from 2002 to 2009 is expected to continue. 

Metals in Mussels 

Mussels were collected at four sample sites (1, 2, 3, and ESL; see Figure 3.5-3) for metal 

analysis. These sites were selected to monitor the metal accumulation in close proximity 

to the Outfall 002 discharge location. Oceanus (2003) compared trend data for ten metals 

compared to Alaska Mussel Watch values at these same four sites. Alaska Mussel Watch 

values are average values collected from various stations in Alaska and are only used for 

comparison purposes; values are not indicators of metal effects in mussels. Oceanus 

noted that average arsenic, chromium, copper, lead, mercury, nickel, and selenium 

concentrations increased from the pre-mine period to the production period; however, 

increases were slight except for chromium, copper, and lead. Average concentrations 

during mine production did not deviate substantially from the Mussel Watch averages; 

concentrations at the sites overall were markedly higher for cadmium, slightly higher for 

lead and nickel, and lower for arsenic, copper, mercury, selenium, and zinc though 2002. 

Updated data through 2010 show a slightly different trend for the five metals being 

surveyed in mussels (HGCMC 2011). Average values for cadmium, copper, and zinc are 

similar to pre-mining averages, and the value for mercury has decreased. However, the 

average for lead increased and is now about 5 times higher than pre-mining average. 

Average production-period lead in mussel tissue also exceeded the Mussel Watch value 

for Alaska reported in 2002. A potential increasing trend of lead throughout Hawk Inlet 

was suggested by Oceanus (2003). The Oceanus study noted that data from the U.S. Fish 

and Wildlife Service (USFWS) study showed increases in lead at Hawk Inlet similar to 

those observed at the outfall sampling area; so these increases may be naturally 

occurring. Overall, of the five metals currently being monitored, only lead 

concentrations in mussels appear to have increased since mine production began. 

Metals in Polychaete Worms 

The polychaete worm (Nephtsy procera), which inhabits soft sediment, had been 

historically sampled at stations S-1, S-2, S-3, and S-4. But as noted for sediment metals, 

Site S-3 was dropped from sampling after 2004. Oceanus (2003) reported results and 

trends in metals monitoring in this worm through 2002. The study noted that 

concentration averages of S-1, S-2 and S-3 increased most noticeably for chromium, lead, 

and nickel, with other metals remaining unchanged or decreasing from pre-mining levels. 

Station S-4 showed metal concentrations increases for arsenic, chromium, copper, lead, 

nickel, and silver, with only lead and silver showing large increases (more than 5 times 

higher). Data through 2010 show similar trends (HGCMC 2011). During the production 

period, average values of cadmium and zinc decreased from pre-mining concentrations 

for worms at stations S-1 and S-2, and increased for copper, lead, and mercury, with the 

largest relative change for lead (about twice pre-mine values). 2010 results show a 

marked reduction in the lead values. For Site S-4, near the loading dock, mining period 

levels remained elevated from pre-mining for cadmium, copper, and lead, but lower for 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-101 

mercury and zinc. Again the most noticeable difference is in lead, which is about three 

times greater than pre-mining levels. The lead levels in the worm at S-4 increased 

dramatically from 1990 to 1993 and have been gradually decreasing since 1995 with 

levels after about 2003 near pre-mining concentrations in worms (HGCMC 2011). 

The levels of toxicity of lead or other metals in these or other worms are unknown. 

However, even shortly after the 1989 spill when concentrations were at their highest, 

these worms were present near Site S-4. The worms also continue to be present in the 

area. The level of harm, if any, of the metals being passed into the local food chain is 

unknown, but benthic polychaetes are a common food source for many marine fish 

species. Fish species in Hawk Inlet most likely to be present in the project area that 

would consume polychaetes and many other benthic organisms would include rock sole, 

yellowfin sole, starry flounder, and arrowtooth flounder. Most individuals, however, 

undergo local, seasonal (e.g., spawning), and regional movements and migration, so the 

chance of individual fish feeding specifically on local organisms to a level causing 

marked bioaccumulation or direct toxicity appears remote. 

Overall Marine Conditions 

While specific information is not available for Hawk Inlet, the inlet appears to be 

supplying an abundant and diverse environment for marine sport, non-sport, commercial, 

and recreational fisheries resources. The common use of this area for harvest of marine 

resources including crab, shrimp, demersal fish, and salmon; abundant production of 

salmon in the local streams; and anecdotal observations by fishermen suggest Hawk Inlet 

has remained productive since mining operations began. Systematic monitoring of 

biological and sediment resources indicate that there have been increases in some 

locations in some metal concentrations in sediment and benthic resources. The levels of 

these metals appear to be influenced heavily by natural conditions in the area; the region 

is a natural supplier of metals from the surrounding stream basins. However, some 

increases have occurred since mine production began, which appear to be local such as 

near the loading dock. There are no distinct indications of direct effects of metals to this 

environment although some degradation of the habitat near the shiploader facility is 

possible. Previous whole effluent toxicity tests of mine effluent did not detect levels of 

adverse effects to tested marine organisms (as a result, the testing was discontinued in 

2005) (HGCMC 2011). The level of transfer of metals into the higher levels of the food 

chain is unknown. Overall, however, monitoring results indicate that the marine system 

in the vicinity is healthy. 

The current project facilities including the dock and transit of concentrate shipping 

vessels may have some effect on local conditions. The dock facility would affect local 

habitat (e.g., shading) and possibly local shoreline fish movements. Ship traffic for 

concentrate transfer can cause local disturbance of fish from boat wakes, movement, and 

noise. 

3.7.3 Aquatic Resources – Environmental 

Consequences 

Factors that affect freshwater and marine resources relative to the TDF expansion 

alternatives are varied. Project-related habitat alterations and water quantity or quality 

changes may affect aquatic resources. 
Chapter 3. Affected Environment and Environmental Consequences

3-102 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Impacts to freshwater resources could occur from loss of habitat resulting from 

modifications or reductions in flow to those habitats. Water quality could be affected by 

spills from concentrate and tailings haul trucks. Additionally, land disturbance near 

streams or from road surface runoff could increase sediment in streams. Construction of 

roads over fish streams can affect fish passage success, including upstream passage of 

adult and juvenile fish. Land clearing near streams can influence stream habitat in the 

short and long term. Thus, project actions that affect the following factors are of most 

concern in assessing potential effects to freshwater resources: 

 Flow reductions to stream systems; 

 Water quality changes; 

 Sedimentation of stream habitat; 

 Fish passage and habitat access; 

 Instream habitat modifications; and 

 Permanent habitat loss. 

Concerns differ from freshwater to the marine environment. Permitted discharges of 

treated wastewater could potentially affect fish, shellfish, and other organism survival 

and production. Suspended matter in discharges and actions near piers could affect local 

area habitat conditions. Transportation activity has the potential to cause harm should a 

major spill of concentrate or fuels occur. Thus, the following indicators are used to 

evaluate potential effects to marine resources: 

 Water quality modifications that affect resources of concern; and 

 Habitat modifications. 

3.7.3.1 Effects Common to All Alternatives 

The common effects to freshwater and the marine systems are those that would occur 

from ongoing operations, reclamation/closure and ongoing site maintenance following 

closure of the TDF (e.g., continued operation of the Pond 7 WWTP). While the overall 

duration and location of TDF operations and the location of subsequent closure and 

reclamation would vary among alternatives, types of effects and general magnitude 

would be similar among alternatives. Since mining would continue to some degree 

before closure began under any alternative, operational-related effects are discussed in 

the separate alternatives subsections. 

Freshwater 

The construction of the TDF reclamation cover at closure would include hauling material 

along the roadway possibly from off-site areas and some additional road work within the 

lease area. This action poses a slight risk of sediment runoff to freshwater fish streams 

including Greens, Fowler, Zinc, and Tributary creeks. Sediment increases in streams 

could affect periphyton and benthic organism production and fish spawning success. 

The risk of a fuel and other hazardous substance spill to streams from road transport 

exists should an accident result in the release of concentrate, fuel, or a hazardous 

substance near streams. Such hazardous substance spills into streams could cause local 

mortalities of aquatic resources including fish with some short- and long-term effects 

depending on magnitude and location of the spill and the effectiveness of the response 

and clean up. However, past operations including fuel and chemical transport have had a 

few small (less than 100 gallons) incidents of fuel or other materials entering streams. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-103 

Greens Creek Mine has a detailed Spill Prevention Control and Countermeasures Plan 

addressing procedures to be followed to prevent spillage of all hazardous liquids to water 

systems. With the Spill Prevention Control and Countermeasures Plan in place, including 

personnel training, the chance of impacts to streams from spills of this type would be 

limited. 

Because seepage and runoff from the tailings is captured, treated, and discharged to 

Hawk Inlet, it is removed from the system and does not impact freshwater aquatic 

resources. Treatment of tailings contact water will be required for at least 100 years after 

closure and perhaps in perpetuity to ensure Alaska WQS are not exceeded. 

Monitoring of stream biota and water quality similar to the monitoring currently 

occurring in Greens and Tributary creeks would continue until such time that ADEC is 

confident that the discharges would meet Alaska WQS and no future impacts would be 

anticipated. The actual schedule and criteria for termination of monitoring would be 

determined through agency coordination as set forth in GPO Appendix 14, Reclamation 

Plan. 

Diverting non-contact runoff around the TDF could increase peak flow velocities in the 

natural stream channel during large storm events. This could potentially cause erosion of 

channel substrates and impact channel geomorphology. These potential impacts could be 

mitigated by using a storm water detention structure or detention pond at the confluence 

of the diversion and the natural channel. While it is anticipated that a storm water 

detention structure would mitigate the effects of the increased flow velocities, the Forest 

Service and ADEC may require HGCMC to conduct habitat surveys in Tributary Creek 

downstream of the TDF expansion area to detect any unanticipated effects. This program 

would be developed and incorporated into the GPO as it is updated to reflect the selected 

alternative. 

Mitigation 

During the 1983 EIS process, the mine operator reached agreement with agencies about 

mitigation for potential lost fish production by creating upstream fish passage on Greens 

Creek at river mile 3.6. This passage improvement was constructed in 1989 to supply 

about 6.5 acres of spawning and rearing habitat for anadromous fish. This fish passage 

facility, however, has not been properly functioning since at least 2005. This facility will 

be repaired and maintained to again provide adult fish passage (ADF&G October 26, 

2011, Draft Fish Habitat Permit FH11-I-0123). The fish passage project was constructed 

as mitigation for a tailings disposal configuration that was never implemented. 

Therefore, the Forest Service and ADF&G consider that it can still be mitigation for the 

lost habitat associated with the proposed action and other action alternatives. An estimate 

of benefit of this passage facility relative to potential coho salmon smolt production can 

be developed using the Tongass Forest Aquatic Habitat Management Handbook FSH 

2090.21 (43 - Exhibit 01). When repaired, the passage facility will allow access of 

anadromous species to about 10,600 feet of stream. Based on the channel type, this 

method assumes that 0.10 coho smolts are produced per linear foot of stream length. 

Applied to the length of anadromous habitat currently available above the fish passage 

facility, the potential production is estimated to be about 1,056 coho salmon smolts. This 

benefit would be present for any alternative as long as the fish passage is maintained as 

required. 
Chapter 3. Affected Environment and Environmental Consequences

3-104 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

However, the Forest Plan (Forest Service 2008a) emphasizes protection of habitat over 

mitigation. The Forest Plan states “Stress the protection of fish and wildlife resources 

habitat to prevent or minimize the need for mitigation.” Thus, actions that can be taken 

to eliminate the need for mitigation are preferred. Due to the ubiquitous nature of fish 

habitat within the project area and the size of the project (TDF footprint and associated 

facilities), none of the action alternatives completely avoids direct or indirect effects to 

aquatic habitat. The selection of the north TDF site proposed under alternatives C and D 

was partly influenced by the fact that no ADF&G and Forest Service streams were 

mapped at the north site and previous studies (Buell 1981) had not identified fish bearing 

streams in the area. Ground truthing in 2011 and 2012, however, identified resident fish 

in a previously unmapped streams. Due to the design and geotechnical considerations, 

the alternative facility footprint could not be shifted away from the stream. 

Marine Waters 

As noted for freshwater, treatment of TDF effluent would be required for at least 100 

years, perhaps in perpetuity. Meeting WQS would ensure the protection of beneficial 

uses of the waters, including aquatic life. With cessation of concentrate transport, the 

risk of concentrate spills near the loading facility affecting the marine environment would 

be eliminated. Other types of marine spill hazards from fuel or other chemical delivery to 

the marine environment would also be eliminated or substantially reduced compared to 

current conditions. Overall, the risk and related impacts would not be substantial after 

closure. 

3.7.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. The TDF would 

continue to be built out to the maximum footprint and height permitted in the 2003 EIS 

(Forest Service 2003). After the TDF is fully built out in 2019, reclamation would begin 

as described in Forest Service 2003. 

Since mining would cease in about 2019 under this alternative, sources of impact are 

primarily those related to closure as described in Section 3.7.3.1, Effects Common to All 

Alternatives. 

Freshwater 

The potential for higher concentrations of metals such as lead and silver in Dolly Varden 

char in Tributary Creek could continue during the remaining three years of operations. 

These elevated metals levels in fish, though higher than Greens Creek, have not shown 

any increasing trends over the ten years of monitoring. Thus, they are expected to remain 

similar over the remaining years of operation. Additionally, adverse effects to 

periphyton, benthic macroinvertebrates, or fish have not been observed as a result of the 

higher metals concentrations in fish. Potential changes in some metals levels in Greens 

Creek, if related to mining, are possible in the short term; however, metals levels have 

remained relatively consistent in the control and treatment sites, so short-term changes 

for the remaining operating period appear unlikely. Also, the aquatic environment has 

not shown effects or changes from the ongoing mining operations that differ noticeably 

from natural conditions. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-105 

As discussed in Section 3.5.3.2, completion of the TDF under Alternative A would 

reduce the watershed area approximately one percent. Flows in Tributary Creek would 

only be slightly affected because upper basin surface runoff and up-gradient groundwater 

is diverted around the TDF back to the creek. Non-contact surface runoff would continue 

to be routed directly in diversion channels, potentially increasing peak flow velocities in 

natural stream channels during large storm events. This could potentially cause erosion 

of channel substrates and impact channel geomorphology and habitat. 

Only minor impacts to both anadromous and freshwater fish would be expected from 

reduced stream flow. These impacts would be similar to current conditions. No direct 

loss of stream habitat and corresponding potential fisheries production from burial of 

stream channels would occur with this alternative (Table 3.7-8 shows loss by habitat, 

Figure 3.5-4). 

Table 3.7-8. Stream Habitat and Estimated Coho Salmon Smolt Potential Production lost 

by Stream Class. 

Alternative Parameter 

Estimated Stream Length Lost and Modeled Coho Salmon Smolt 

Potential Lost 

Tributary Fowler Grand 

Class I Class II Total Class I Class II Total Total 

Alt A Length (ft) 0 0 0 0 0 0 0 

Coho Smolts 0 NA 0 0 NA 0 0 

Alt B Length (ft) 1,646 2,400 4,046 0 0 0 4,046 

Coho Smolts 66 NA 66 0 NA 0 66 

Mitigated Alt B Length (ft) 1,248 1,169 2,416 0 0 0 2,416 

Coho Smolts 50 NA 66 0 NA 0 50 

Alt C Length (ft) 0 0 0 0 1,044 1,044 1,044 

Coho Smolts 0 NA 0 0 NA 0 0 

Alt D Length (ft) 0 0 0 0 1,044 1,044 1,044 

Coho Smolts 0 NA 0 0 NA 0 0 

Source: Aquatic Habitat Management Handbook FSH 2090.21 (43 - Exhibit 01), for coho smolt production 

model. 

Class I= anadromous fish streams; Class II=resident fish streams. 

Marine Waters 

Beyond the expected life of the mine and closure in 2019, effects to marine biota and 

habitat for this alternative would be the same as described in Section 3.7.3.1, Effects 

Common to All Alternatives. Operational effects would be similar to those discussed 

below for Alternative B but for a shorter duration (about 2 years). 
Chapter 3. Affected Environment and Environmental Consequences

3-106 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.7.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

existing TDF would be expanded southward. The expanded TDF and associated 

infrastructure (water management ponds, quarries, and new support roads) would result 

in impacts to aquatic resources including the filling of portions of Tributary Creek and 

adjoining wetlands (see Section 3.8, Wetlands). 

Freshwater 

Monitoring data show that mine operations have not affected aquatic organisms including 

periphyton, benthic macroinvertebrates, or fish since monitoring began in 2001. These 

conditions would likely remain similar in the future under Alternative B. With continued 

operations, road runoff near streams may add cumulative sediment to these systems along 

Greens, Zinc, and Fowler creeks. Sediment increases to Greens Creek based on all mine 

operations were previously estimated to be about 7 to 12 percent per year above baseline 

conditions, which was considered to be within annual natural variability of sediment 

supply (Forest Service 1983, 1988). Since the amount of roads within the basins is low 

and traffic volumes are restricted, sediment input should remain below levels that would 

cause substantial effects and annual peak flow levels are expected to continue to remove 

fine substrate from these systems. 

As discussed in Section 3.5.3.3, the Tributary Creek watershed would be reduced 

approximately 20 percent under this alternative. However, the flow reduction to 

Tributary Creek is expected to be less than 20 percent because surface water runoff east 

of the TDF will be diverted back to the groundwater system through the use of a slurry 

wall and underground drainage system (see Section 3.5.3.3). The flow reduction has the 

potential to reduce the quantity of habitat in Tributary Creek even if it is less than the 

overall portion of the basin area diverted. Slight effects to flows in the lower portion of 

Zinc Creek could also occur. Flow in Tributary Creek, however, is only 17 percent of the 

combined flows of the Zinc Creek and Tributary Creek basins so the flow reduction in 

Tributary Creek would have little or no perceptible change in flow in lower Zinc Creek. 

Additionally, the change in Tributary Creek headwater flow timing, volume, and pathway 

could affect stream temperature. However the direction and magnitude of change cannot 

be estimated as the relative contribution of flow (i.e., surface water, which responds more 

rapidly to air temperature, compared to groundwater, which has more moderate changes) 

is not known. Once flows reach the stream they typically equilibrate to local stream 

temperatures which are the result of shading and air temperatures (Hetrick et al. 1998; 

Poole et al. 2001), so adverse effects of temperature changes are unlikely. Some loss of 

food source to the stream may occur from loss of upstream non-fish habitat. While 

organic fish food sources from non-fish stream segments upstream of fish reaches 

contribute to downstream areas, this contribution is generally a small portion of total food 

sources (Wipfli and Baxter 2010). Also, because of the low gradient in this basin, nearly 

all stream segments affected would be fish bearing. Thus, the loss of non-fish bearing, 

food supplying, stream segments would be minimal. 

Similar to Alternative A, diverting non-contact runoff could increase peak flow velocities 

in the natural stream channel during large storm events. This could potentially cause 

erosion of channel substrates and impact channel geomorphology and habitat. These 

potential impacts could be mitigated by using a storm water detention structure or 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-107 

detention pond at the confluence of the diversion and the natural channel. While it is 

anticipated that a storm water detention structure would mitigate the effects of the 

increased flow velocities, the Forest Service and ADEC may require HGCMC to conduct 

habitat and or surveys in Tributary Creek downstream of the TDF expansion area to 

detect any unanticipated effects. This program would be developed and incorporated into 

the GPO as it is updated to reflect the selected alternative. 

About 4,000 feet of Class I and II streams in the Tributary Creek watershed (Table 3.7-8) 

would be directly lost to the TDF expansion. This represents about 50 percent of fish 

habitat in Tributary Creek by length. Fill from past development in the Tributary Creek 

watershed was limited to non-stream areas. The proposed activities for this alternative 

would reduce spawning and rearing habitat and ultimately anadromous and resident fish 

production in these streams. The loss would be primarily of small resident fish stream 

habitat. Overall, potential production of coho salmon smolts from direct habitat burial 

loss is estimated to be about 66 smolts for the 1,600 feet of class I stream that would be 

lost. The maximum loss of this habitat from burial would occur at full build-out with 

most of the changes occurring gradually over a 30- to 50-year period. The maximum loss 

would occur at mine closure and would be permanent. Depending on the drainage 

patterns reestablished at reclamation and the success in meeting Alaska WQS for 

freshwater, near natural flows could be returned to Tributary Creek sometime after 

closure. If WQS could not be met and TDF runoff could not be restored to near natural 

conditions, flows in Tributary Creek would continue to be reduced, continuing habitat 

reduction in Tributary Creek and, to a lesser extent, Zinc Creek (Figure 3.5-4). 

Marine Waters 

Several metrics were used to assess likely effects of the existing discharge and loading 

operations on the marine biotic environment. It is expected that past patterns of metals in 

the environment and organisms would continue during the operating life of the project 

under Alternative B and, in the vicinity of Outfall 002, beyond. 

With continued operation for another 30 to 50 years, the chance of accidental spills of 

concentrate during loading or transport would continue. However, since the 1989 spill, 

no observed spills or leakage of concentrate to the marine environment have been 

documented. While the monitoring program has indicated some metals have remained 

elevated near the loading dock, there is no indication of a trend of increasing metals 

concentrations and such a trend is not anticipated to develop under Alternative B. 

Large fuel spills from offloading to the terminal or during transit of the fuel vessel is also 

a risk that would continue for the duration of operations (30–50 years). Typical fuel 

barge offloading to a 200,000-gallon storage facility occurs about every 10 days. The 

largest reported spill to marine waters at the site was 3,000 gallons and occurred in 1989 

during an offloading. In the entire project area all other documented spills were less than 

100 gallons per event. The Greens Creek Mine has a detailed Spill Prevention Control 

and Countermeasures Plan addressing procedures to be followed to prevent spillage of all 

hazardous liquids to water systems. While the risk of spills at the dock seems remote, 

effects of a spill near the dock could have substantial short-term adverse effects and some 

potential long-term effects. The effect would depend on weather, tides, size, location, 

and material involved in the spill. While there is substantial water exchange locally, 

Hawk Inlet is a confined bay and the confined nature of this area would aid in retaining 
Chapter 3. Affected Environment and Environmental Consequences

3-108 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

much of a spill in the inlet where it could impact shoreline intertidal areas. Depending on 

the season and where a spill occurred, various resources could be affected. For example, 

during early spring pink and chum salmon rear in shallow shoreline areas. With the 

substantial salmon runs into several of the Hawk Inlet tributaries the number of early 

rearing fish potentially exposed to hydrocarbons could be high. But these fish may 

actively move away from toxic concentrations thereby reducing effects. There is a 

substantial intertidal community; especially at the head of the inlet where extensive 

shallow areas could be affected by a spill. Dissipation and evaporation of oil and fuel 

would limit effects over time. However, spill control plans and rapid response to spills 

would be the primary mitigation measures to avoid or minimize adverse spill effects to 

marine resources. The confined nature of Hawk Inlet aids cleanup and response actions 

compared to unsheltered waters, potentially retaining much of a spill within a smaller 

area and reducing effects outside of the inlet. HGCMC maintains marine spill response 

equipment onsite and fuel barge unloading is closely monitored by trained employees to 

ensure rapid response in the event of a spill. Additionally, HGCMC maintains an active 

membership in the Southeast Alaska Petroleum Resource Organization. This 

membership makes available substantial quantities and types of response equipment and 

personnel in the event of a petroleum spill as well as training and support. 

3.7.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. The relocation 

would moderately reduce the amount of fish habitat directly lost from direct burial of 

Tributary Creek stream channels. Compared to Alternative B without mitigation, this 

measure would preserve about 1,230 feet of class II resident fish streams in the Tributary 

Creek watershed (Table 3.7-8). Loss of anadromous fish stream channel would be 

reduced by 400 feet. Potential production of coho salmon smolts from direct habitat 

burial loss is estimated to be about 50 smolts for the 1,248 feet of class I stream that 

would be lost, compared to 66 smolts under Alternative B. Mitigated Alternative B 

would reduce the acreage impact to the Tributary Creek watershed from 20 percent to 

15 percent (Figure 3.5-4). The slight difference in wetlands impacted may produce a 

very minor improvement in flow attenuation and groundwater discharge to Tributary 

Creek compared to Alternative B. Relocation of the reclamation material storage area 

may also provide a small improvement in shallow groundwater discharge to Tributary 

Creek compared to Alternative B. Other effects would remain similar to Alternative B 

(Figure 3.5-4). 

3.7.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located adjacent to the Fowler Creek drainage. Additionally, 

the A Road would be upgraded for about 3 miles and additional facilities would be 

constructed. Alternative C would also extend the operating period of the mine by 30–50 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-109 

years. Effects to aquatic resources would be more widely spread than in alternatives A 

and B due to the development of a new TDF and supporting infrastructure. 

Freshwater 

Conditions in Greens and Tributary creeks relative to metals, sediment, and flow would 

remain the same as alternatives A and B for the first few years because tailings disposal 

would continue in this area while the new TDF site was being developed. 

Effects to Tributary and Zinc creeks would be similar to those described for Alternative 

A, the No Action Alternative. The Tributary Creek watershed would be reduced by an 

additional 3 percent. The diversion of flows would continue to slightly reduce spawning 

and rearing habitat and ultimately anadromous fish production in these streams similar to 

Alternative A. Expansion of the TDF in the Tributary Creek watershed would be 

completed within 3–5 years beyond that of Alternative A. The habitat loss in the 

Tributary Creek and Zinc Creek watersheds from flow reduction would occur at that time 

and may be permanent depending on the amount of flow that would continue to be 

diverted and the duration that contact water would continue to need treatment. No direct 

stream burial would occur in Tributary Creek with this alternative, so no direct loss of 

anadromous habitat would occur in these watersheds (Figure 3.5-4). 

The north TDF footprint would reduce the area of the Fowler and North Hawk Inlet 

watersheds. The new TDF footprint would reduce a portion of the Fowler Creek 

watershed by approximately 2 percent. Only minor effects to both the base flow and 

storm flows of Fowler Creek would be expected. Up-gradient groundwater would be 

routed to Fowler Creek. About 1,044 feet of small class II resident fish streams would be 

lost (Table 3.7-8). This would result in permanent loss of mostly rearing and some 

spawning habitat of resident fish. Overall, stream channel loss is a small portion of 

Fowler Creek, which has over 132,000 feet (estimated) of channels in the watershed. 

Fowler Creek has the potential to support anadromous fish downstream of the north TDF 

site (see Section 3.7.1.1 for North Hawk Inlet for stream characteristics). Additionally, 

reduced flow to the downstream channel in Fowler Creek would result in some loss of 

rearing habitat from minor flow reductions. 

The proposed new TDF may slightly reduce flows in two small stream channels that 

drain north to Hawk Inlet. These channels are not indicated on ADF&G or Forest 

Service stream databases. No fish were observed during limited surveys in summer 2011 

(Tetra Tech 2011c); however, one of these streams (furthest west), was determined to 

potentially provide resident fish habitat. Because of the limited habitat in the area, effects 

to freshwater aquatic resources in the streams draining north to Hawk Inlet would be 

minor (Figure 3.5-6). 

Potential impacts to stream channel substrates and channel geomorphology from noncontact diversions would be the same as described for alternatives A and B, except that 

impacts could also occur in the Fowler Creek watershed. These potential impacts could 

be mitigated by using a storm water detention structure or detention pond at the 

confluence of the diversions and the natural channels. As with Alternative B, additional 

monitoring is being considered to detect unanticipated habitat and/or geomorphic effects. 
Chapter 3. Affected Environment and Environmental Consequences

3-110 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

It is expected that the existing Greens Creek fish passage structure, when repaired, will 

provided adequate mitigation for lost habitat in project area creeks, or other project 

related activities. 

The upgrade of the A Road and additional truck traffic have the potential to increase 

sediment runoff to streams. Traffic on the A Road would be equivalent to current levels 

on the B Road. Generally, forest roads with high use have greater sediment discharge to 

streams than those with light use (Reid and Dunn 1984; Kahklen and Hartsog 1999). The 

route has few stream crossings (approximately 3) with most of the draining area flowing 

to Young Bay through Fowler Creek. The stream channels near this crossing are small, 

low-gradient, often having beaver ponds and bottoms consisting of fines and organic 

matter. The limited road length that would contribute sediment to this area, small size of 

streams, and the presence of ponds containing fine sediment, would result in the potential 

increase in sediment to the streams having slight or no effect to the aquatic system and 

likely no adverse effect to anadromous fish segments of Fowler Creek. 

A pipeline would be built to carry contact water from the TDF to the existing water 

treatment facility. Water from the TDF would contain some elevated metals and possibly 

other chemicals that could cause adverse effects to aquatic systems. A break in this 

pipeline could result in spillage entering Hawk Inlet or Fowler Creek resulting in impacts 

to fishery habitat. With procedures in place to reduce the magnitude of a potential spill 

and lack of proximity of the pipeline to major stream resources, effects from a pipeline 

break would likely be short term and not substantial. 

Effects of a tailings spill would be similar to Alternative B except there would also be the 

possibility of a tailings truck spill occurring in the Fowler Creek drainage. 

Marine Waters 

Effects would be the same as Alternative B because all major project actions relative to 

the marine environment including: location, chemical concentrations and amount of 

discharge are essentially the same as Alternative B under Alternative C. 

3.7.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of a new TDF to the north. Like alternatives B and C, Alternative D would extend the 

operating period of the mine by 30–50 years. The expansion of the existing TDF would 

be substantially smaller than Alternative B but larger than the footprint under Alternative 

C. The disturbance footprint of the new TDF would be similar to that of Alternative C. 

Effects to aquatic resources in the northern drainages, including Fowler Creek, would be 

similar to Alternative C but would not occur for an additional 10 years. Development of 

new facilities could further impact aquatic resources. The aquatic impacts of this 

alternative would be more widespread than alternatives A and B as a result of the 

development of a new TDF. 

Freshwater 

Conditions in Tributary Creek relative to metals, sediment, and flow would remain the 

same as Alternative B for up to 20 years because tailings disposal would continue in this 

area during the operational life of the water treatment facility. 
3.7 Aquatic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-111 

With the reduction in future tailings disposal the Tributary Creek watershed, compared to 

Alternative B, effects to Tributary and Zinc creeks would be intermediate between 

alternatives B and C. This alternative would increase the existing TDF area to 73 acres. 

The total basin area that would have flow diversion would be 98 acres of Tributary Creek 

basin, part of the larger Zinc Creek basin. However, no length of Tributary Creek would 

be directly lost due to the tailings pile expansion. The design would also require the 

placement of tailings as well as the construction of a water management pond within the 

Cannery Creek drainage and the Tributary Creek drainage. Flow reductions would 

reduce spawning and rearing habitat and ultimately anadromous fish production in each 

of these streams. The full loss would be permanent depending on future flow diversions, 

similar to Alternative C (Figure 3.5-4). 

With the movement of a portion of the tailings to the new TDF, effects to the Fowler 

drainage and small creeks draining north to Hawk Inlet would be similar to Alternative C. 

The direct loss of fish bearing streams from direct burial would be about 1,044 feet, the 

same as Alternative C (Table 3.7-8). The main difference is the duration of effects would 

be shorter because fill would begin 15 years later, reducing the period of effect. The 

magnitude of effect would be similar to the TDF under Alternative C since the total area 

disturbed would be similar. Overall, effects from TDF development would be 

permanent. The effect of flow reduction from flow interception of the tailings pile on 

fish habitat downstream in Fowler Creek drainage would also be the same as Alternative 

C, resulting in some loss of rearing habitat from minor flow reductions (Figure 3.5-6). 

Potential impacts to stream channel substrates and channel geomorphology from noncontact diversions would be the same as described for Alternative C. These potential 

impacts could be mitigated by using a storm water detention structure or detention pond 

at the confluence of the diversions and the natural channels. As with Alternative B, 

additional monitoring is being considered to detect unanticipated habitat and/or 

geomorphic effects. 

Effects of a tailings spill would be similar to Alternative C. There would be the 

possibility of a tailings spill occurring in the Fowler Creek drainage as well as either spill 

type in the Zinc or Greens creeks watersheds. The period of time during which a spill 

could affect the Fowler Creek drainage would be less under Alternative D than under 

Alternative C because of when the construction of the new TDF would begin. 

Marine Waters 

Effects would be the same as Alternative B because all major project actions relative to 

the marine environment including location, chemical concentrations, and amount of 

discharge are essentially the same as Alternative B. 

3.7.4 Aquatic Resources – Summary 

Aquatic life conditions in the freshwater streams project area and Hawk Inlet appear to 

remain healthy and similar to pre-mining conditions. Metals concentrations in stream 

Dolly Varden char have shown some variability between control and downstream sites 

but generally, trends of increases resulting from mining activity have not been apparent. 

Some tissue metals concentrations are higher in areas potentially affected by mine 

activity. The Forest Service and ADEC require ongoing monitoring of freshwater aquatic 
Chapter 3. Affected Environment and Environmental Consequences

3-112 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

resources, including bioassessment and fish tissue monitoring. The ongoing monitoring 

will be used to assess whether future impacts occur. 

Monitoring in Hawk Inlet has shown some elevated concentrations of metals in sediment 

near the shiploader site and also variable levels near Outfall 002. Monitoring has not 

indicated that there has been any adverse effect on the overall marine environment of 

Hawk Inlet. The TDF wastewater is treated before it is discharged and there is a large 

amount of flushing and dilution that occurs in Hawk Inlet. Marine organisms (mussels 

and polychaete worms) have shown increased metals concentrations near the marine 

loading facility and near the NPDES discharge site, with some decrease in metals 

concentrations in more recent results. Alternative A would continue current conditions 

though about 2019 when the TDF would reach capacity and mining operations would 

cease. Alternative B would reduce fish habitat for both freshwater species and 

anadromous salmon and trout in the Tributary Creek drainage through TDF expansion by 

about 4,000 feet (stream length), or about 50 percent of Tributary Creek by length. 

Alternatives C and D each would include a small loss of stream habitat accessible to 

resident fish in an unnamed tributary to Fowler Creek. Under all alternatives, flow 

reductions due to water collection and treatment would reduce downstream habitat to 

some extent. Other than Alternative A, which has mining terminated in about 2019, none 

of the alternatives would change conditions in the marine environment from current 

operations. Mitigation for all alternatives would include improving anadromous fish 

passage facilities on Greens Creek, producing about 1,056 coho smolt based on the coho 

smolt production model (Aquatic Habitat Management Handbook FSH 2090.21, 43 – 

Exhibit 01). In addition, the Forest Service and ADEC will require that monitoring 

programs continue in order to identify potential impacts to freshwater and marine 

resources. 

3.7.4.1 Essential Fish Habitat Summary 

As required by Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and 

Management Act (MSFCMA), the National Marine Fisheries Service (NMFS) as 

consulted regarding potential effects to essential fish habitat (EFH). EFH is designated in 

marine and fresh waters within the project area. Marine EFH is designated for 

groundfish, shellfish, and all five species of Pacific salmon. Freshwater rearing and 

spawning EFH for coho salmon (Oncorhynchus nerka), pink salmon (O. gorbuscha), and 

chum salmon (O. keta) is also present. Tributary Creek, which would lose 1,646 feet of 

anadromous waters under the preferred alternative, provides EFH for spawning coho and 

pink salmon, and rearing coho. Zinc Creek, which Tributary Creek joins at mile 0.8, and 

Greens Creek provide EFH for spawning coho, chum, and pink salmon, and rearing coho. 

An EFH assessment was prepared for this project and submitted to the NMFS (Tetra 

Tech 2012). The assessment concluded that project actions under any action alternative 

create the potential for effects to EFH through possible changes in water quality and 

sedimentation, flow alteration, impacts to prey base or food resources, fish passage or 

habitat access, and direct loss of habitat. Alternative A would allow current conditions to 

continue though about 2019 when the tailings storage site would become full and mining 

operations would cease. Alternative B would result in some reduction in overall fish 

habitat for EFH species in the Tributary Creek drainage through TDF expansion, 

including the loss of about 1,600 feet of anadromous stream length. Additionally, there 

could be a loss of downstream habitat accessible to anadromous fish due to flow 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-113 

diversion and increased sedimentation. While both alternatives C and D would reduce 

the effects to EFH in the Tributary Creek basin and would not result in the direct burial of 

anadromous stream by TDF expansion, each would expand development in the Fowler 

Creek basin and decrease downstream habitat due to flow diversion and increased 

sedimentation. None of the action alternatives would significantly alter conditions in the 

marine environment from current operations. Mitigation for any alternative would 

include improving anadromous fish passage facilities on Greens Creek. 

The NMFS provided comments on the EFH assessment on July 19, 2012. In its review, 

the NMFS noted adverse effects to EFH under all alternatives, though effects would be 

greatest under Alternative B and would be “substantial and permanent.” The NMFS 

provided nine EFH conservation recommendations including expanding the aquatic 

monitoring program, providing fish passage at road crossings, additional mitigation for 

loss of fish production, and long-term monitoring of the Greens Creek fish passage 

structure. The Forest Service responded to the NMFS EFH conservation 

recommendations, indicating which recommendations will be implemented, and how, 

based on the final alternative selected. The EFH assessment and related correspondence 

is available in the project record 

3.8 Wetlands __________________________________ 

Wetlands are a subset of aquatic resources that for 

purposes of this analysis are discussed independently 

in this section. Other aquatic resources are addressed 

in Section 3.7, Aquatic Resources, and Section 3.5, 

Water Resources – Surface Water. This section 

describes wetland resources within the vicinity of the 

mining operation beginning with the pre-mining 

environment, the baseline conditions that include 

current mining operations, and the effects of each 

alternative under consideration. 

Wetlands are transitional areas existing between 

uplands and open water, commonly considered bogs, 

swamps, and muskegs. Wetlands provide benefits 

within the landscape, ranging from providing fish 

and wildlife habitat to improving water quality. The 

Classification of Wetlands and Deepwater Habitats 

of the United States (Cowardin et al. 1979) provides a basis for characterizing wetlands 

that can be applied across the United States. This system has been adopted by USFWS 

for use in its National Wetland Inventory mapping program and is the standard approach 

used to identify and characterize wetlands. Under the Cowardin/National Wetland 

Inventory approach, the wetlands occurring in the area are “palustrine” wetlands, which 

have three classes: scrub-shrub, emergent, and forested. Scrub/shrub wetlands are 

dominated by shrubs less than 20 feet (6 meters) tall. Emergent wetlands are dominated 

by herbaceous (non-woody) vegetation, including grasses and sedges, and forested 

wetlands are dominated by trees. Additional detail on project area wetlands is provided 

in Section 3.8.2. 

The potential to impact wetlands 

was identified as significant 

Issue 3 during the scoping 

process. Concerns raised 

during scoping include impacts 

to the function and values of 

wetlands, specifically from the 

alteration of surface and 

groundwater. Measures of 

impacts to wetlands include 

acres and types of wetlands 

affected as well as associated 

habitat values.
Chapter 3. Affected Environment and Environmental Consequences

3-114 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The U.S. Army Corps of Engineers (USACE) defines wetlands as “those areas that are 

inundated or saturated by surface or groundwater at a frequency and duration sufficient to 

support, and that under normal circumstances do support, a prevalence of vegetation 

typically adapted for life in saturated soil conditions” (USACE 1987). The USACE 1987 

Manual and the 2007 Alaska regional supplement along with regulations at 33 CFR 328 

are the tools by which jurisdictional wetlands are identified in the State of Alaska. 

Jurisdictional wetlands are subject to Section 404 of the CWA and are defined using 

soils, vegetation, and hydrologic characteristics. Areas displaying hydric soils with 

hydrophytic (water loving) vegetation that are saturated or inundated for a defined 

portion of the growing season and are not isolated from navigable waters of the U.S. are 

considered jurisdictional wetlands (USACE 1987). 

The connectivity of wetlands to navigable waters is a component of jurisdictional wetland 

determination that has come under closer review in recent years as a result of legal 

rulings. Tributary Creek is a perennial stream and tributary to Zinc Creek, which empties 

into Hawk Inlet, a navigable water. Additionally, Cannery Creek empties directly into 

Hawk Inlet, as do the other small streams that would be impacted by the project, 

including CC Creek, Franklins Creek, and Further Creek (south and north forks). For 

purposes of the analysis, wetlands within the project area are adjacent (connected) to 

these creeks and tributaries and are, therefore, considered jurisdictional. 

3.8.1 Wetlands – Pre-Mining Environment 

Very little is known about the presence of wetlands prior to mining in the areas that have 

already been disturbed. The 1983 EIS included only a very brief discussion on wetlands, 

and stated that muskeg plant communities covered approximately 4 percent of the project 

area. The dock facilities, TDF, and portions of the road system approved under the 1983 

ROD occupy former wetland areas. These areas were poorly drained, non-forested areas 

covered with sphagnum and lichens as well as vascular plants including sedges, 

ericaceous shrubs, and goldthread. Western hemlock and mountain hemlock also 

occurred, ranging from small shrubs to stunted trees (Forest Service 1983). The EIS also 

identified riparian plant communities characterized by alder (Alnus spp.), graminoids, 

ferns, and Ribes spp. The value of the wetlands was primarily its contribution to fisheries 

and brown bear habitat. 

3.8.2 Wetlands – Baseline Conditions 

This section describes the current condition that resulted from the construction and operation 

of the Greens Creek Mine. The construction and operation of the mine has resulted in 

changes from the pre-mining conditions, including direct impacts to wetlands. As noted, the 

number of wetlands actually disturbed by construction of the mine and associated facilities 

cannot be accurately measured because of the lack of detail in pre-mining surveys. 

Bosworth Botanical Consulting conducted a jurisdictional wetland delineation in the area 

in July and September 2011 and contributed to a functional assessment of wetlands in the 

area potentially affected by the expansion considered in this EIS (Bosworth 2011; 

Adamus 2012). The reports address four types of wetlands (bogs, fens, forested 

wetlands, and marshes) (Figure 3.8-1), which are discussed in greater detail below 

followed by a description of the results of the functional assessment. 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-115 

Figure 3.8-1. Wetlands.
Chapter 3. Affected Environment and Environmental Consequences

3-116 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

National Wetland Inventory Classification Descriptions 

As noted in the introduction to Section 3.8, the Cowardin/National Wetland Inventory 

mapping system is used consistently to describe wetland habitats. The following section 

reflects the Cowardin/National Wetland Inventory descriptions provided by Bosworth 

Botanical Consulting (Bosworth 2011) for wetland communities occurring within the 

vicinity of the mine site. National Wetland Inventory identifiers used by wetland 

scientists are presented in parentheses below following the names of the wetland 

communities. Table 3.8-1 provides the existing acreage for each wetland community. 

Table 3.8-1. Wetlands Occurring within the Study Area. 

Community Dominant Species 

Existing 

Coverage 

(acres) 

Bog/Bog 

Woodland 

Lodgepole pine, mountain hemlock, Labrador tea, crowberry, 

cloudberry, sphagnum. 44 

Sedge Fen/Fen Red alder, crabapple, lady fern, skunk cabbage, Sitka sedge, deer 

cabbage 52 

Forested wetlands Western hemlock, Alaska blueberry, false azalea, skunk cabbage 2,555 

Marsh Sitka sedge, skunk cabbage 3 

Wetland* Not available. 549 

Wetland with 

Upland Inclusions* 

Not available. 

65 

Total 3,268 

*Wetlands were mapped by 3 Parameters Plus for the 2003 EIS, and did not categorize wetlands as bog, 

forested wetlands, sedge fen, or marsh. These wetlands were included in the forested wetlands category 

for subsequent analyses. 

Bog/Bog Woodland (Emergent / Scrub-shrub / Forested) 

The open wetlands in the center of the study area, and in the southwest corner of the TDF 

are bogs that grade from open woodland bog dominated by lodgepole pine (Pinus 

contorta), mountain hemlock, Labrador tea (Ledum groenlandicum), crowberry 

(Empetrum nigrum), cloudberry (Rubus chaemamorus), and several species of 

Sphagnum, to an open bog dominated by several small Carex species, round-leafed 

sundew (Drosera rotundifolia), and several species of sphagnum. 

Sedge Fen/Fen (Emergent / Scrub-Shrub) 

The toe-of-slope areas just west of the B Road and south of the TDF has a high water 

table that results in a fen community dominated by red alder, crabapple, lady fern, skunk 

cabbage, Sitka sedge, and deer cabbage. The water table of the fen supports in part the 

hydrology of Tributary Creek. The fen transitions to the south into a forested wetland 

dominated by western hemlock, Sitka spruce, lady fern, and skunk cabbage. Another fen 

wetland occurs north of the A Road, along and east of Fowler Creek. The wetland 

supports a similar vegetation community and its hydrology would similarly support some 

of the flows in Fowler Creek. 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-117 

Forested Wetland (Forested) 

The dominant plant species in forested wetland communities typically include western 

and mountain hemlock, false azalea (Menziesia ferruginea), deer cabbage 

(Nephrophyllidium crista-galli), and skunk cabbage. Much of the forested wetland on the 

western side of the project area is a western hemlock forest with an understory of early 

and Alaska blueberry, false azalea and skunk cabbage. The wetlands on the southeast 

side of the study area (the gently east-west sloping toe of slope and headwaters for 

Tributary Creek) grades from south to north, from a forested wetland dominated by Sitka 

spruce-western hemlock, lady fern (Athyrium felix-femina), and skunk cabbage to a 

mixed shrubby fen dominated by red alder, crabapple, false azalea, lady fern, and skunk 

cabbage. Forested wetlands in the vicinity of the new TDF site proposed under 

alternatives C and D is an alluvial type forested wetland with an overstory of Sitka spruce 

and western hemlock and an understory of skunk cabbage. 

Marsh (Emergent) 

The largest marsh area on the site is located near the northeast corner of the existing TDF 

and consists of Sitka sedge and skunk cabbage. The marsh contributes to the hydrology 

of Cannery Creek. A series of inactive beaver dams along Tributary Creek also have 

small fringing areas of marsh wetlands. 

Wetland Functions and Values 

The CWA requires that impacts to waters of the U.S. be mitigated on a function and 

values (or service) basis. “Functions” are the processes or series of processes that a 

wetland performs under natural conditions. “Values” consider where a wetland is 

positioned relative to people or features that might benefit from its services, and whether 

its species or habitat has special designations. In concept, wetland “services” are the 

combination of functions and values. For a wetland to be considered as providing a high 

level of services, both its functions and values of those functions should be high. 

A functional assessment entitled Wetland Ecosystem Services Protocol for Alaska – 

Southeast (WESPAK-SE) was used to describe the wetland functions and values for the 

Greens Creek Mine (Adamus 2012). The methodology used to define and rate types of 

functions for each wetland is based on a variety of factors including wetland type, habitat 

quality, climate, land use, geology, etc. The analysis presented here is based on wetland 

services and synthesizes the function and value data presented in the Adamus report. 

Wetlands in the study area were observed to be intact and fully functioning; most are 

interconnected with one type grading into another. The wetlands support the streams 

within their respective watersheds by storing and releasing water, adding nutrients and 

providing habitat for aquatic and terrestrial species. While most wetland types in the 

study area directly or indirectly support resident fish habitat. The forested and fen 

wetlands adjoining Tributary Creek also support anadromous fish species that are present 

within the creek, providing a service that is not provided by other wetlands in the study 

area. The performance of these habitat-related services in relation to other wetlands 

within Southeast Alaska is presented in Table 3.8-2 and depicted in Figure 3.8-2 

(functions) and Figure 3.8-3 (values). 
Chapter 3. Affected Environment and Environmental Consequences

3-118 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.8-2. Wetland Service Ratings. 

Services 

Forested 

Althea 

Creek A, 

B, MB

Forested 

Middle 

Hawk 

Inlet MB

Forested 

North 

Creek C, D

Forested 

Tributary 

Creek B, 

MB

Marsh B, 

MB, C, D

Fen B, 

MB, C, D Bog A, B, MB, D

Aquatic Habitat 

Streamwater 

Cooling +2 +3 +3 +3 +3 +3 +1 

Streamwater 

Warming +3 +3 +3 +3 +2 +2 +3 

Stream Flow 

Support +3 +3 +3 +3 +3 +3 +2 

Aquatic 

Invertebrate 

Habitat 

+2 +3 +3 +3 +3 +3 +2 

Anadromous 

Fish Habitat* NA NA NA +3 NA +3 NA 

Resident & 

Other Fish 

Habitat 

+1 +1 +2 +2 +3 +3 +2 

Amphibian 

Habitat +2 +3 +2 +3 +2 +3 +2 

Terrestrial Habitat 

Waterbird 

Feeding Habitat +1 +3 +3 +1 +3 +3 +2 

Waterbird 

Nesting Habitat +1 +3 +3 +1 +3 +3 +1 

Songbird, 

Raptor, & 

Mammal Habitat 

+3 +3 +3 +3 +2 +3 +3 

Pollinator 

Habitat +3 +1 +1 +3 +1 +1 +1 

Native Plant 

Habitat +3 +3 +2 +3 +3 +3 +2 

Wetland 

Sensitivity +3 +3 +3 +3 +2 +3 +3 

Wetland 

Ecological 

Condition 

+2 +3 +3 +1 +1 +3 +2 

Wetland 

Stressors +1 +2 +3 +1 +2 +1 +1 

Notes: A = Alternative A; B = Alternative B; MB = Mitigated Alternative B; C = Alternative C; D = Alternative D. 

* Forested Tributary Creek Wetlands and Fen Wetlands were each given an additional point for Anadromous fish 

habitat because the original study did not recognize Tributary Creek correctly as an anadromous stream. No other 

Project wetlands provide anadromous fish habitat and therefore were given a ranking of Not Applicable (NA). 

+3 Above median score compared to other wetlands in the region 

+2 Median scores compared to other wetlands in the region 

+1 25% < Median score compared to other wetlands in the region 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-119 

Figure 3.8-2. Wetland Functions. 
Chapter 3. Affected Environment and Environmental Consequences

3-120 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.8-3. Wetland Values.
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-121 

3.8.3 Wetlands – Environmental Consequences 

Direct effects to wetlands would generally result in long-term adverse impacts. Longterm impacts are defined as those that would last beyond the lifetime of the project. 

None of the wetlands directly impacted by the construction of the TDF expansion would 

be restored after final closure of the mine since the TDF would be covered and reclaimed 

as an upland. Wetlands that could be restored following mining activities would mostly 

be those affected by the construction and operation of water management ponds, storm 

water diversions, and fill placed in the construction of ancillary facilities, such as 

reclamation storage areas. The amount of time required to restore the wetlands after 

closure would depend on the wetland type. While facilities like quarries and reclamation 

material storage areas could be reclaimed as wetlands, restoration of some wetlands 

would not be conducive on the TDF(s) because of the potential to enhance infiltration and 

potentially produce geotechnical instability. Mitigation for impacts to wetlands is 

discussed below. 

3.8.3.1 Effects Common to All Alternatives 

Wetlands are protected under Executive Order 11990, the “no net loss” policy and the 

CWA. Executive Order 11990 directs agencies to minimize the “destruction, loss, or 

degradation” of wetlands in carrying out their responsibilities. The order also directs 

agencies to avoid undertaking or funding of new construction in wetlands unless there are 

no practicable alternatives and all practical measures to minimize impacts to wetlands 

have been included in the proposal. The no net loss policy reinforces the ideas set forth 

in the executive order, calling for avoidance, minimization of impacts, and mitigation for 

unavoidable impacts. Section 404 of the CWA establishes requirements, including a 

permit program, for dredge and fill activities within waters of the U.S., including 

wetlands. Among other requirements, issuance of Section 404 permits requires 

compliance with Section 404(b)(1) guidelines. Subpart B of the guidelines requires 

minimization of impacts to the extent practicable. Ultimately, the guidelines require 

selection of the “least damaging practicable alternative” identified through the permitting 

process. 

The proponent prepared a Section 404 permit application for the TDF expansion. 

Mitigation measures imposed through this NEPA process require that the proponent 

catalog all wetlands disturbances that have occurred onsite to date and determine which 

sites, if any, could be permanently reclaimed prior to mine closure. Additional mitigation 

will be required by the USACE through the Section 404 permitting process. 

3.8.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites were reclaimed, and human activity in the area was reduced. The TDF 

would continue to be built out to the maximum footprint and height previously permitted 

following the 2003 EIS process (Forest Service 2003) (Figure 3.8-4). After the TDF was 

fully built out in 2019, reclamation would begin as described in the 2003 EIS (Forest 

Service 2003). 
Chapter 3. Affected Environment and Environmental Consequences

3-122 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.8-4. Impacts to Wetlands by Alternative (South).
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-123 

Impacts to wetlands from current mining operations would continue at rates as described 

in the 2003 Final EIS (Forest Service 2003) and no new dredge and fill activities would 

be authorized. 

3.8.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. 

The TDF expansion would have a long-term adverse impact to approximately 85 acres of 

wetlands (Table 3.8-3). The majority of the impacts would occur on forested wetlands 

and fens within the footprint of the TDF. These wetlands would be filled by the liner 

material, drainage layers, and ultimately, tailings. Wetlands would also be filled by 

construction of ponds, reclamation material storage areas, and the truck wheel wash 

facility (Figure 3.8-4). 

Table 3.8-3. Wetlands Disturbed by Alternative B. 

Wetland Type Acres of Disturbance Highly Ranked Services 

Bog/Bog Woodland 20 Aquatic invertebrate habitat; 

streamwater warming 

Sedge Fen/Fen 

28 

Anadromous fish habitat; stream 

water cooling; stream flow support; 

aquatic invertebrate habitat; native 

plant habitat 

Forested Wetland * 

36 

Anadromous fish habitat; stream 

flow support; stream water 

warming; native plant habitat 

Marsh 

1 

Sediment and toxicant retention 

and stabilization, stream water 

cooling 

Total 85 

* Includes 0.5 acre of wetlands not assigned to a specific type in data provided by Three Parameters 

Plus (2001). 

The functions and values provided by wetlands disturbed under Alternative B would be 

lost throughout the life of the mine, and in some cases in perpetuity. Table 3.8-3 includes 

the prominent services of wetlands that would be disturbed. Alternative B would result 

in the direct fill of forested wetlands and fen along Tributary Creek. As described in 

Section 3.7, Aquatic Resources, Tributary Creek is the only stream in the area that 

supports anadromous fish populations and impacts to fish species was recognized as one 

of the significant issues in development of the EIS. Alternative B would impact 67 acres 

of wetlands that serve anadromous fish populations. The associated effects on the 

hydrologic patterns of the stream and the habitat values for resident and anadromous fish 

are discussed in sections 3.5.3 and 3.7.3 respectively. 
Chapter 3. Affected Environment and Environmental Consequences

3-124 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Where wetlands are restored in settings such as reclaimed water management ponds or 

growth media storage piles, some of the functions of the emergent wetlands would return 

relatively quickly because the structure of vegetation in these wetlands is simple and the 

plants would grow quickly. Water storage and stream flow functions in emergent 

wetlands would take longer to develop since they are tied in part to the accumulation of 

thick organic soils. Functions associated with the forested wetlands would recover more 

slowly, reflecting the time it would take for trees and shrubs to reestablish. Sites 

determined to be suitable for wetland restoration would be contoured to ensure the 

presence of enough water to support the desired environment. To the extent they are 

available, soils typical of, and suited to, wetlands would be used as appropriate and 

hydric characteristics would be expected to develop over time. 

3.8.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion; the remaining volume would be placed in the final phase. 

The Mitigated Alternative B would place the reclamation material storage area in a 

forested wetland outside the Monument, near the junction of the A and B roads in the 

Middle Hawk Inlet drainage rather than in a forested wetland in the Tributary Creek 

drainage. Further, one of the quarries proposed in the Tributary Creek drainage (and 

inside the Monument) under Alternative B would be eliminated by deepening the quarry 

located near the north end of the TDF (outside of the Monument). These mitigation 

activities would slightly reduce the overall amount of disturbance to forested and bog 

wetlands (by 9 acres) in the Tributary Creek drainage compared to Alternative B 

(Table 3.8-4). Tailings placement in the area adjacent to the northeast corner of the 

existing would involve filling all 3 acres of marsh wetland within the Cannery Creek 

drainage. Based on the results of the Wetland Ecosystem Services Protocol for Alaska – 

Southeast assessment, the stockpile would be sited in a wetland that provides high levels 

of services located adjacent to a resident fish stream outside the Monument rather than in 

a forested wetland that supports anadromous fish in the Tributary Creek drainage inside 

the Monument (see Table 3.8-4 and Figure 3.8-4). Mitigated Alternative B would impact 

70 acres of wetlands that support anadromous fish populations. While the redesigned 

TDF under this alternative would shift some of the tailings disposal area to the north end 

of the existing TDF, impact to the fen in the Tributary Creek drainage could not be 

avoided; however, the redesign would reduce the extent of impacts to some of the 

forested wetlands in the Tributary Creek drainage. 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-125 

Table 3.8-4. Wetlands Disturbed by Mitigated Alternative B. 

Wetland Type Acres of Disturbance Highly Ranked Services 

Bog/Bog Woodland 8 Aquatic invertebrate habitat; 

streamwater warming 

Sedge Fen/Fen 

27 

Anadromous fish habitat; stream 

water cooling; stream flow support; 

aquatic invertebrate habitat; native 

plant habitat 

Forested wetland * 

35 

Anadromous fish habitat; stream flow 

support; stream water warming; 

native plant habitat 

Marsh 3 Sediment and toxicant retention and 

stabilization, stream water cooling 

Total 77 

* Includes 9.8 acres of wetlands not assigned to a specific type and with upland inclusions, in data 

provided by Three Parameters Plus (2001). 

3.8.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve a short-term expansion of the existing TDF and the 

concurrent construction of a new TDF in the north drainage to Hawk Inlet, located 

approximately 3 miles north of the existing TDF in the north drainage to Hawk Inlet. 

Once infrastructure for the new facility was completed, tailings disposal would shift to 

the new facility and closure of the existing TDF would begin. The new facility would 

require an upgrade to the A Road along with the construction of other supporting 

facilities. Alternative C would also extend the operating period of the mine by 30–50 

years, but would allow reclamation to begin in the existing TDF in approximately 3 

years. 

Effects to wetlands would be more widely spread than in alternatives A and B because of 

the need to develop a new TDF and supporting infrastructure. Alternative C would affect 

approximately half of the marsh wetland near the northeast corner of the existing TDF. 

Forested wetlands in the north drainage to Hawk Inlet that would be impacted by the new 

TDF are in better ecological condition than the forested wetlands that would be impacted 

by the expanded TDF under Alternative B (see figures 3.8-4 through 3.8-9). Forested 

wetlands that would be impacted by the new TDF in the north drainage provide high 

levels of services but do not support anadromous fish habitat like the forested wetlands 

that would be impacted by the expanded TDF under Alternative B. The level of services 

provided by relative function and values of the fen and bog wetlands in the area of the 

new TDF cannot be determined, as the Wetland Ecosystem Services Protocol for Alaska 

– Southeast assessment did not describe these wetlands separately. However, Alternative 

C would encroach only slightly on the high value sedge fen wetlands in the Tributary 

Creek drainage and avoid impacts to the portions of the wetlands that directly support 

anadromous fish habitat. However, construction of the new TDF would eliminate a large 

fen wetland in the Fowler Creek drainage. 
Chapter 3. Affected Environment and Environmental Consequences

3-126 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.8-5. Impacts to Wetland Functions by Alternative (South). 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-127 

Figure 3.8-6. Impacts to Wetland Values by Alternative (South). 
Chapter 3. Affected Environment and Environmental Consequences

3-128 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.8-7. Impacts to Wetlands by Alternative (North). 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-129 

Figure 3.8-8. Impacts to Wetland Functions by Alternative (North). 
Chapter 3. Affected Environment and Environmental Consequences

3-130 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.8-9. Impacts to Wetland Values by Alternative (North). 
3.8 Wetlands 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-131 

During the initial few years (2012–2015), wetlands in the Tributary Creek drainage 

would continue to be affected by the expansion of the existing TDF as well as preparation 

of infrastructure for the new TDF. Effects generated later in the project life would be 

focused in the north drainage to Hawk Inlet (new TDF) rather than the Tributary Creek 

drainage. Development of new facilities, including reclamation material storage areas, 

quarries, water management ponds; linear drain features and pipelines; truck wheel wash; 

as well as haul road improvements and truck pullouts would further impact wetlands. 

Alternative C would affect 112 acres of wetlands (Table 3.8-5). Figures 3.8-4 through 

3.8-9 illustrate the wetland types, number of functions exceeding the regional average, 

and number of values exceeding the regional average for each alternative. 

Table 3.8-5. Wetlands Disturbed by Alternative C. 

Wetland Type Acres of Disturbance Highly Ranked Services 

Bog/Bog Woodland 8 Aquatic invertebrate habitat; 

streamwater warming 

Sedge Fen/Fen 

25 

Downstream anadromous fish habitat; 

stream water cooling; stream flow 

support; aquatic invertebrate habitat; 

native plant habitat 

Forested Wetland * 

78 

Anadromous fish habitat; stream flow 

support; stream water warming; native 

plant habitat 

Marsh 1 Sediment and toxicant retention and 

stabilization, stream water cooling 

Total 112 

* Includes 1.1 acres of wetlands not assigned to a specific type and with upland inclusions, in data 

provided by Three Parameters Plus (2001). 

The upgrade of the A Road under Alternative C could result in indirect impacts to 

wetland hydrology by altering flows of surface water and shallow groundwater. The 

extent to which these impacts would occur is difficult to determine and depends to a large 

extent on the type of fill material and the effectiveness of the drainage controls along the 

disturbance. However, studies on roads in wetlands in southeast Alaska indicate that 

impacts are generally limited to the immediate vicinity of the road and the hydrologic 

regime recovers relatively quickly within 30 feet down-gradient of the road (Glaser 1999; 

McGee 2000). 

3.8.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new TDF. Like alternatives B, Mitigated B and C, Alternative D would extend the 

operating period of the mine by 30–50 years. The expansion of the existing TDF would 

be substantially smaller than Alternative B, however the footprint of the new TDF would 

be similar in size to Alternative C for the areas to the north. 

Effects to wetlands would be greater than under any of the other alternatives with effects 

similar to both alternatives B and C. Impacts to wetlands in the Tributary Creek drainage 

would be less than under Alternative B and Mitigated Alternative B but greater than 
Chapter 3. Affected Environment and Environmental Consequences

3-132 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

under Alternative C. A large portion of the fen wetland in the Tributary Creek drainage 

would be affected but the proponent would not place fill into Tributary Creek itself or the 

wetlands immediately adjacent to it. Like Alternative C, the wetland disturbance of this 

alternative would be more widespread than alternatives A, B, and Mitigated B due to 

development of a new TDF. Alternative D would affect 121 acres of wetlands (Table 

3.8-6). Figures 3.8-4 through 3.8-9 illustrate the wetland types, number of functions 

exceeding the regional average, and number of values exceeding the regional average for 

each alternative. 

Table 3.8-6. Wetlands Disturbed by Alternative D. 

Wetland Type Acres of Disturbance Highly Ranked Services 

Bog/Bog Woodland 9 Aquatic invertebrate habitat; 

streamwater warming 

Sedge Fen/Fen 

32 

Downstream anadromous fish habitat; 

stream water cooling; stream flow 

support; aquatic invertebrate habitat; 

native plant habitat 

Forested Wetland * 78 Stream flow support; stream water 

warming; native plant habitat 

Marsh 2 Sediment and toxicant retention and 

stabilization, stream water cooling 

Total 121 

* Includes 1.6 acres of wetlands not assigned to a specific type and with upland inclusions, in data 

provided by Three Parameters Plus (2001). 

3.8.4 Wetlands – Summary 

Wetland surveys identified approximately 3,267 acres of existing wetlands within the 

immediate vicinity of the mine, including bogs, fens, forested wetlands, and marshes. 

Direct effects to wetlands would primarily occur as long-term adverse impacts 

(placement of fill) and would result in permanent loss of wetlands. Most wetland would 

not be restored after final closure of the mine, and the amount of time required for 

wetlands that are restored would depend on the wetland type and the functions they 

provide. No new impacts to wetlands would occur under Alternative A, which would 

include continuation of mining until 2019 when project closure and reclamation would 

begin. Mitigated Alternative B would have the least amount of impacts to wetlands; 

compared to other action alternatives, with all impacts confined to the Middle and South 

Hawk Inlet and Tributary Creek drainages. Mitigated Alternative B would slightly 

reduce the overall amount of disturbance to wetlands, but would move the impacts from a 

forested wetland in the Tributary Creek drainage (supporting anadromous fish habitat and 

other high levels of services inside the Monument), to a wetland providing high levels of 

services outside the Monument. Mitigated Alternative B would impact 8 fewer acres of 

wetlands that support anadromous fish compared to Alternative B, but would move 

impacts into a previously undisturbed area. Mitigated Alternative B would also result in 

the loss of the high functioning fen wetland. 
3.9 Soils 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-133 

Impacts to wetlands would be greater and more widely spread under alternatives C and 

D, but would occur largely in the north drainage to Hawk Inlet outside the Monument 

rather than in the Tributary Creek drainage inside the Monument. However, forested 

wetlands in the north provide high levels of services, but did not support anadromous fish 

populations like those that would be impacted under Alternative B. Alternative C would 

have the least amount of impacts to the high value sedge fen wetlands in the Tributary 

Creek drainage that support anadromous fish populations. Alternative C would impact 

less of the highly functioning sedge fen wetlands in the Tributary Creek drainage, 

compared to Alternative D (Table 3.8-7). The Section 404 permit for the least 

environmentally damaging practicable alternative will require implementation of a 

mitigation plan. 

Table 3.8-7. Summary of Wetland Acreage Impacted by Alternative. 

Wetland Type 

Acres of Disturbance 

Alternative A Alternative B 

Mitigated 

Alternative B Alternative C Alternative D 

Bog/Bog Woodland 0 20 12 8 9 

Sedge Fen/Fen 0 28 27 25 32 

Forested Wetland * 0 36 35 78 78 

Marsh 0 1 3 1 2 

Total 0 85 77 112 121 

* Includes 2 acres of wetlands not assigned to a specific type and with upland inclusions, in data provided by 

Three Parameters Plus (2001). 

3.9 Soils ______________________________________ 

Soil characteristics provide the basis for the productivity 

of plant communities present on a particular site. 

Microbes function to break down organic matter within 

the soil and influence chemical and geochemical 

reactions. Thus soil characteristics have a strong 

influence on ecosystem structure and function. Soil 

productivity is related to numerous factors including the 

nature of the parent material, how the soil layers 

(horizons) are formed, temperature, and moisture conditions. Disturbances can range 

from simply removing vegetation from the surface (e.g., wind thrown trees) to complete 

removal of surficial material above bedrock. 

The description of the soils resource also forms the basis for the establishment of 

reasonable reclamation performance standards and identification of effective mitigation 

measures, which are designed to prevent, reduce, or eliminate impacts to soils. 

Soil productivity is not 

identified as a significant 

issue. Measures of soil 

productivity include acres 

and types of soils impacted.
Chapter 3. Affected Environment and Environmental Consequences

3-134 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The purpose of this section is to discuss the following: 

 Baseline soils conditions as they relate to existing vegetation communities; 

 Impact evaluation criteria; 

 Soil conditions as they relate to TDF closure and reclamation goals, current closure 

cover design and existing research. 

3.9.1 Soils – Pre-mining Environment 

The pre-mining description of the soils resource is extremely limited. The following 

section is based primarily on the Greens Creek Final Environmental Impact Statement, 

Admiralty Island National Monument, Alaska (Forest Service 1984). 

The 1984 Final EIS described soils as thick, silty, and granular with occasional peat and 

organic deposits up to 10 feet thick. Soils were described as having low nutrient status 

and not demonstrating elevated metal or salt concentrations. Soils immediately adjacent 

to the TDF were subsequently mapped and characterized and likely represent soils that 

existed prior to initial construction of the TDF (NRCS 2011; Bosworth 2011). The 

NRCS (2011) described soil pore water pH ranging from 4.0 to 6.0. The observed soil 

pore water pH of less than 6.0 in these soils is likely the result of organic matter 

decomposition into compounds including organic acids. 

The 1984 Final EIS identified the need to salvage and stockpile existing soils, redistribute 

soil at the time of final reclamation, and install and maintain erosion and sediment 

controls. 

3.9.2 Soils – Baseline Conditions 

This section describes the properties of the dominant soil map units as they relate to the 

development and structure of existing and possible reclaimed vegetation communities. 

The soils map unit delineations, descriptions, and engineering properties summarized in 

this section were derived from the Chatham Area Soils Survey (NRCS 2011). 

Based on the data available regarding the type and distribution of soil map units, 

Table 3.9-1 presents the extent of existing disturbance as a result of existing operations 

and those activities that have already been approved. 
3.9 Soils 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-135 

Table 3.9-1. Acres of Disturbance to Soil Map Units based on Existing Operations. 

Soil Map 

Unit ID Map Unit Name 

Disturbance 

(Acres) 

3624E Foad-Traitors complex, broken, 76 to 140 percent slopes 6 

4442C Kaikli-Chuck River complex, smooth hills, 36 to 55 percent slopes 13 

4454E Traitors-McGilvery complex, smooth hills, 76 to 120 percent slopes 4 

5121B Kupreanof gravelly silt loam, 6 to 35 percent slopes 12 

5145B Mitkof loam, footslopes, 6 to 35 percent slopes 8 

6141B Kasiana-Kushneahin complex, sloping lowlands, 6 to 35 percent slopes 34 

6174B Kina-Kasiana association, sloping lowlands, 6 to 35 percent slopes 18 

6290A Kina peat, 0 to 5 percent slopes 8 

Total 103 

Of the soil series represented in the project area, bedrock restricts rooting depths in seven 

of the soils series and glacial till restricts rooting depths in two series. The depths of 

these root-restricting layers range from eight to 44 inches with an average maximum 

depth of the root restricting layer of 29 inches. The dominant vegetation on all but one of 

these soil series is Sitka spruce or western hemlock. 

Based on soil series descriptions in the Soil Survey for Chatham Area, Alaska (NRCS 

2011) the following may be concluded: 

 The growth of Sitka spruce or western hemlock is not inhibited by rooting restricting 

layers at depths of eight to 44 inches; and 

 Sitka spruce-western hemlock vegetation communities proliferate in well-drained to 

poorly drained soils (also see Viereck et al. 1992). 

3.9.3 Soils – Environmental Consequences 

3.9.3.1 Effects Common to All Alternatives 

The description of the soils resource provided below forms the basis by which to assess 

the intensity, duration, and magnitude of soils impacts associated with the proposed 

action and alternatives. The primary impact to the soils resources associated with all 

alternatives would be loss in soil productivity in large part caused by stripping the topsoil 

and organic layers. 

Anaerobic conditions within growth media stockpiles are a major cause of soil 

productivity loss. Soils placed in stockpiles below a depth of approximately three feet for 

extended periods of time exhibit reduced organic matter cycling, microbial activity and 

mycorrhizae inoculation potential (Stark and Redente 1987; Gould and Liberta 1981; 

Rives et al. 1980). The anticipated reduction in soil productivity would be limited to the 

period between soil salvage and storage and the initial vegetation establishment period at 

the time of reclamation. Soil erosion potential would increase due to the increased 

exposure of soil to rain drop impact and concentrated overland flow during the clearing 

and grubbing of vegetation and soil salvage, stockpiling and redistribution activities. 
Chapter 3. Affected Environment and Environmental Consequences

3-136 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Common soil management practices could be used to enhance the success of reestablishing native plant communities by improving productivity at closure and 

minimizing erosion from soil salvage through re-application during reclamation. The 

practices to mitigate the extent of potential effects under all alternatives include: 

 Separate salvage and stockpiling of suitable soils prior to the initiation of tailings 

disposal activities; 

 Build storm water runoff diversions on and around soil stockpiles and reclaimed areas 

to minimize soil exposure to concentrated overland flow; 

 Install and maintain erosion and sediment control BMPs on soil stockpiles and at the 

time of final reclamation; 

 Handling soils during dry periods (to the extent possible) to reduce the potential for 

soil compaction; 

 Construct stable soil stockpiles; 

 Eliminate soil stockpiling through soil salvage and direct placement of soils on 

portions of the TDF that are ready for reclamation; 

 Construct stable reclaimed slopes; 

 Redistribute salvaged soil at the time of final reclamation; and 

 Scarifying compacted soils. 

Closure Cover Design 

The TDF closure cover design (from bottom to top) according to Hecla’s proposed TDF 

Expansion - Stage 3 (Hecla 2011) is as follows: 

 Lower Capillary Break – Thickness = 8–12 inches; Material Source = mine waste 

rock, quarry rock, or rock imported to the site from an off-island source; Material 

Properties = undefined. 

 Compacted (Barrier) Layer – Thickness = 24 inches; Material Source = 

unidentified; Material Properties = capable of compaction to a permeability of 10-6

cm/sec. 

 Upper Capillary Break – Thickness = 8–12 inches; Material Source = rock imported 

to the site from an off-island source; Material Properties = non-mineralized. 

 Plant Growth Layer – Thickness = 24–36 inches; Material Source = stockpiled 

growth media; Material Properties = undefined. 

While not all of the cover materials sources, types, properties, volumes and mass balance 

have been finalized at this time, the barrier and plant growth layers are currently planned 

to be supplied from on-site sources which may include reclamation material stockpiles. 

The materials that will serve as the capillary break are planned to be imported from an 

off-island source (Kennecott 2008). 

To assess the TDF closure cover and reclamation potential in terms of functionality, 

performance, constructability, design complexity, materials availability, and 

uncertainties, the impact analysis criteria used for the evaluation of alternatives A 

through D are as follows: 

 Maintain static and pseudo-static geotechnical stability (see Section 3.3.3, 

Geotechnical Stability – Environmental Consequences); 
3.9 Soils 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-137 

 Probability of establishing a predominant vegetation of mature Sitka spruce and 

western hemlock on the surface of the reclaimed TDF (see Section 3.10.3, Vegetation 

– Environmental Consequences); and 

 Minimize the penetration (flux) of water and oxygen through the closure cover and 

into tailings to reduce and manage the generation of acidic/metal-bearing waters in 

the TDF. 

These criteria were developed based in part on reclamation guidance provisions in the 

Tongass Land and Resource Management Plan (Forest Service 2008a) provided below. 

To function as designed, the engineered closure cover must balance percolation of rain 

water through the cover and into tailings, while providing adequate water storage and 

nutrient supply capacity to establish the desired vegetation cover. The cover must 

function to avoiding exposure of tailings due to erosion and slope failure. 

Mitigation 

A one-acre test plot at Site 23 is currently being used to assess the overall performance of 

the TDF engineered closure cover and to establish feasible cover design basis and 

criteria. The growth media depth at Site 23 is 24 inches. Information on the growth layer 

can be extrapolated from this study site; however, additional test plots should be 

established on the mine site to specifically evaluate depths up to 36 inches (which reflects 

the upper bounds documented in the literature) and determine the optimum depth of the 

plant growth layer for the desired plant communities. This would provide opportunities 

to evaluate the performance of full-scale implementation of the engineered closure covers 

and plant growth layer on tailings. Future investigations should be combined with past 

and ongoing observations at Site 23 to allow the operator to demonstrate the adequacy of 

the design and performance of the cover and evaluate potential refinements prior to final 

closure and reclamation of the TDF. 

Net Flux of Precipitation and Oxygen through TDF Engineered Closure 

Cover 

The measured average flux of precipitation through the test cover at Site 23 has been 

approximately 15 to 20 percent of annual precipitation (Hecla 2007 through 2009). 

The rate and magnitude of oxygen diffusion through the engineered closure cover and 

into the underlying TDF is a consideration in the prediction of tailings oxidation rates. 

Given that oxygen diffusion through water is approximately 104

 fold slower than in air 

(Reddy et al. 2000), the diffusion of oxygen through a saturated medium will be 

substantially less than if the same medium was dry or well below saturation with respect 

to water. Therefore, one of the design criteria for the engineered closure cover currently 

includes the installation and maintenance of the barrier layer at a relative saturation above 

85 percent to resist downward diffusion of atmospheric oxygen (OSU 2010). 

The consumption of oxygen and production CO2 within the plant growth layer that results 

from plant and soil microbial respiration should be high due to the relatively high 

biomass productivity potential of the proposed cover (See discussion below). As plant 

and microbial respiration doubles, soil oxygen is depleted by approximately 2.5 percent 

at a depth of one meter (39 inches) (Currie 1962). This should contribute to lowering the 

rate of oxygen diffusion into the underlying capillary break and barrier layers. 
Chapter 3. Affected Environment and Environmental Consequences

3-138 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.9.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. The TDF would 

continue to be built out to the maximum footprint and height permitted in the 2003 EIS 

(Forest Service 2003). After the TDF is fully built out in 2019, reclamation would begin 

as described in the 2003 EIS (Forest Service 2003). The soil productivity of existing soil 

stockpiles would be improved within 4 to 5 years following placement as growth material 

over the TDF. The plant growth layer under Alternative A would be maximized up to 36 

inches where spruce-hemlock forest is to be re-established. 

3.9.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. The expanded TDF 

and associated infrastructure (water management ponds, quarries, and new support roads) 

would impact additional acres with an effect to soil productivity of a minimum of 30–50 

years. The duration of the impact would last for the entire length of the mining operation 

because only a limited amount of concurrent reclamation could be conducted, resulting in 

long-term stockpiling of the soil resource. Alternative B also includes new roads and 

upgrades to existing roads that would cause further soil disturbance. 

3.9.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be located 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; eliminating the quarry within the 

Monument would require deepening the quarry at the north end of the existing TDF. 

Eliminating the quarry would result in a smaller overall footprint and thus slightly reduce 

the of soil productivity compared to Alternative B; moving the reclamation material 

storage area would simply shift disturbance footprint from one location to another. 

Concurrent opportunities under Mitigated Alternative B would be similar to the Proposed 

Action, resulting in a 30–50 year effect on the stored topsoil resource. 

3.9.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located approximately three miles north of the existing TDF. 

Once tailings placement in the existing TDF was completed in approximately 2019, the 

site would be regraded and the closure cover installed. Final reclamation could occur in 

approximately 2017 after the final cover was put in place. 

Soil disturbance would be more widely spread than in alternatives A, B, and Mitigated B 

due to the development of a new TDF and supporting infrastructure. Development of 

new facilities, including reclamation material storage areas, quarries, water management 

ponds; linear drain features and pipelines; and truck wheel wash would further impact 

soil productivity. While final reclamation could occur relatively quickly following the 
3.9 Soils 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-139 

completion of tailings placement on the existing TDF, contemporaneous reclamation of 

the new TDF may be difficult because of the configuration of the TDF’s footprint. The 

current design and phasing of the TDF may require modification to accommodate 

development and concurrent reclamation. 

3.9.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new northern TDF. Like alternatives B, Mitigated B, and C, Alternative D would 

extend the operating period of the mine by 30–50 years. The expansion of the existing 

TDF would be substantially smaller than under Alternative B, however the footprint of 

the new TDF would be similar in size to that built under Alternative C. Overall, the total 

soil disturbance would be similar to Alternative C; however, the disturbance would be 

phased to a greater extent since the area associated with the new TDF would not be 

disturbed until approximately 2030. Development of new facilities, including 

reclamation material storage areas, quarries, water management ponds; linear drain 

features and pipelines; and truck wheel wash would further impact soil productivity in 

disturbed areas. 

3.9.4 Soils – Summary 

The primary impact to the soils associated with all alternatives would be loss in soil 

productivity caused by stripping the topsoil and organic layers. The anticipated reduction 

in soil productivity would be limited to the period of soil salvage and storage and the 

initial vegetation establishment period at the time of concurrent or final reclamation. 

The greatest difference between the action alternatives is the spatial extent of 

disturbances and the period of time in which mining would continue, and the time until 

reclamation occurs. Soil disturbance would be more widely spread under alternatives C 

and D, compared to alternatives A, B, and Mitigated B due to the development of a new 

TDF and supporting infrastructure. Under alternatives A and C, the placement of growth 

media on the existing TDF would occur in the relative near-term; reclamation of the 

existing TDF under Alternative D would begin in approximately 10 years, compared to 

Alternative B which would not include final closure of the existing TDF until 30 to 50 

years from the present. Under each alternative, common soil management practices 

would be used to mitigate the extent of potential effects to soil productivity, as described 

in Section 3.9.3.1. Additionally, mitigation would be recommended under all action 

alternatives to establish test plots to determine the optimum depth of the plant growth 

layer for the desired plant communities. 

 
Chapter 3. Affected Environment and Environmental Consequences

3-140 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.10 Vegetation _________________________________ 

This section describes vegetation resources within the 

vicinity of the mining operation beginning with the premining environment, the baseline conditions that include 

current mining operations, and the effects of each 

alternative under consideration. Concerns raised during 

public scoping include the effects of tree roots on the 

closure cover, use of native wildflowers during 

reclamation, and contamination of lichens. The proposed 

mining project does not include plans for commercial 

timber sales, other than for timber that will be removed to 

clear the area for tailings expansion or other mine facilities. 

3.10.1 Vegetation – Pre-Mining Environment 

Prior to mining, vegetation in the vicinity of the mine was similar to the existing 

vegetation elsewhere on Admiralty Island. The area consists primarily of upland forests, 

Sitka spruce-western hemlock interspersed with a mosaic lowland, non-forested plant 

communities, including peat wetlands, shrub wetlands, and sedge meadows (Forest 

Service 2003). The well-drained slopes of the bedrock ridges and mountain slopes are 

mostly upland vegetation, and the flatter basin and terrace areas, underlain by uplifted 

marine silts and glacial tills that perch the water table, support wetland vegetation of 

various types (Bosworth 2010). Pre-mining descriptions of vegetation follow the Viereck 

et al. (1992) level IV classification system. 

Sitka Spruce-Western Hemlock Forest 

Sitka spruce (Picea sitchensis)-western hemlock (Tsuga heterphylla) forests are common 

in southeast Alaska. They occur mostly at low elevations on alluvial fans, floodplains, 

footslopes, and uplifted beaches. Sitka spruce-western hemlock forests are at a climax or 

near-climax successional stage. The spruce provides 35 to 60 percent cover and 

constitutes most of the overstory. Mature spruces are generally 95 to 145 feet tall and 20 

to 40 inches diameter breast height (dbh). Hemlock provides an understory 80 to 125 feet 

high with 30 to 60 percent cover. Average diameter of mature hemlock is 15 to 25 inches 

dbh. Other tree species are uncommon. 

A well-developed shrub layer 3- to 5-feet tall is usually present and consists of 

combinations of devil’s club (Oplopanax horridus), Vaccinium spp., and salmonberry 

(Rubus spectabilis). Common ferns and herbs include oak fern (Gymnocarpium 

dryopteris), spiny wood fern (Dryopteris expansa), goldthread (Coptis aspleniifolia), 

dogwood (Cornus spp.), trailing raspberry (Rubus pedatus), deer berry (Maianthemum 

dilatatum), skunk cabbage (Lysichiton americanus), and foamflower (Tiarella trifoliata). 

No other upland vegetation communities occur in the vicinity of the project area. The 

various wetland types are discussed in Section 3.8, Wetlands. 

The resource analysis of 

vegetation is related to Issue 

2 impacts to wetlands 

through removal of wetland 

vegetation. Measures of 

affects to vegetation include 

acres and types of vegetation 

impacted. 
3.10 Vegetation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-141 

3.10.2 Vegetation – Baseline Conditions 

The baseline condition for vegetation describes the current condition that has resulted 

from the construction and operation of the Greens Creek Mine. The construction and 

operation of the mine has resulted in changes from pre-mining conditions, including 

direct impacts to vegetation communities. To date, approximately 65 acres of vegetation 

have been directly disturbed by the existing TDF and associated facilities. The majority 

of this disturbance occurred within Sitka spruce-western hemlock forests, but a small 

amount of disturbance occurred within wetland communities (Forest Service 1983). 

Bosworth Botanical Consulting conducted a biological survey for sensitive plant species 

in the potentially affected areas in July 2010, September 2010, and again in July 2011 

(Bosworth 2010; Forest Service 2012). Sensitive plant species are discussed in greater 

detail in Section 3.12.3.6. The biological survey grouped the vegetation in the area into 

five communities: Sitka spruce-western hemlock forest (upland); and bogs, fens, forested 

wetlands, and marshes (wetland) (Figure 3.10-1). The upland vegetation on the slopes of 

the western bedrock ridges and the hill slopes along the eastern edge of the project area is 

a Sitka spruce and western hemlock forest with an understory of Early blueberry and 

Alaska blueberry (Vaccinium ovalifolium and V. alaskaense), spiny wood fern, and dwarf 

dogwood (Cornus canadensis). A section of steep hillside just east of the B Road has 

been clear cut. This area was previously a Sitka spruce-western hemlock forest. 

3.10.3 Vegetation – Environmental Consequences 

Direct effects to vegetation would include primarily long-term impacts. Long-term 

impacts are defined as those that would last beyond the project lifetime. Short-term 

impacts are defined as those expected to last less than or as long as the lifetime of the 

project. An example of a long-term impact would be a vegetative community disturbed 

for placement of the TDF. This would be considered a long-term impact because the 

vegetation would not be fully regenerated for a number of years beyond the lifetime of 

the project. 
Chapter 3. Affected Environment and Environmental Consequences

3-142 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.10-1. Vegetation. 
3.10 Vegetation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-143 

3.10.3.1 Effects Common to All Alternatives 

Reclamation 

A reclamation plan is currently in 

place and will be modified under any 

of the alternatives to accommodate the 

final configuration of the TDF. The 

objectives of the reclamation plan 

include: (1) establish plant 

communities (where appropriate) that 

are self-sustaining; (2) assist in 

protecting water quality by controlling 

erosion and preventing ARD; and (3) 

contribute to the proposed land use of 

the reclaimed site after closure (GPO 

2000). 

Disturbed areas would be reclaimed to 

one of three vegetation types including 

upland meadows, upland forest, or 

wetlands (GPO 2000). Specific seed 

mixtures, woody seedling density, and 

maps showing each vegetation type 

would be submitted within the detailed 

reclamation plan. Specific seed mixes 

would be developed to address the 

primary issue of erosion control, but 

would also consider proliferation of 

native species and diversity. 

Developing the appropriate seed or 

planting mixture to produce a plant 

community that eventually results in 

the establishment of Sitka spruce and 

western hemlock forest may need to be 

determined through test work prior to 

construction of the final cover. 

Forested areas would be revegetated 

using a combination of natural 

regeneration and reseeding or transplanting (GPO 2000). Natural regeneration is 

preferred over planting as a means of establishing a coniferous overstory in small areas 

where seed sources are available; because natural regeneration would ensure 

reestablishment of Admiralty Island genotype species, follow natural successional stages, 

and provide unique wildlife habitat during stand development. Naturally regenerated 

plants are also well adapted to local conditions. The coastal forests of southeast Alaska 

regenerate very quickly and profusely since western hemlock and Sitka spruce grow 

rapidly in the area. Natural regeneration of these climax species is evident throughout 

areas previously disturbed by mining activities and in areas without any reclamation 

preparation. 

Succession is an ecological process whereby 

the species composition of plant communities 

shift over time in response to changing 

environmental conditions. Depending on the 

size of a disturbance, pioneer species are the 

first to recolonize a site followed by one or 

more intermediate communities until a stable, 

climax community (such as Sitka spruce – 

western hemlock forest) becomes established. 

These stages of vegetation succession are 

typically observed in southeast Alaska in Sitka 

spruce-western hemlock forests (Alaback 

1984). Examples of vegetation succession 

are as follows:

Pioneer—From 0 to 25 years herbaceous 

pioneer species such as fireweed, and 

graminoid species would likely dominate. 

There may also be a shrub component of 

willow, and blueberry.

Willow-Alder—From 26 to 50 years the willowalder stage would likely dominate and the 

most common species would likely be Sitka 

alder, Sitka willow, black cottonwood, and 

Alaska willow.

Hemlock Forest—From 51 to 100 years 

western hemlock would begin to invade. In 

bare areas of wind throw or fire, Sitka spruce 

or red alder would be able to colonize.
Chapter 3. Affected Environment and Environmental Consequences

3-144 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

HGCMC proposes to monitor revegetation success for three years following seedbed 

preparation, fertilization, seeding, mulching, and temporary erosion control measures. 

Growth, ground cover, and species survival would be measured and reported on an 

annual basis. 

Revegetation efforts would be considered successful when the following conditions are 

met (GPO 2000): 

 The total vegetative cover (including live biomass of perennial species, litter, and 

standing dead) in each revegetated area is equal to or exceeds 80 percent aerial cover, 

with a 90 percent statistical confidence limit; 

 The density of actively growing trees is within 80 percent of target levels contained in 

the approved reclamation plan with a 90 percent statistical confidence; 

 The reclaimed wetland and meadow areas have at least three graminoids present each 

with relative herbaceous cover value equal to or greater than 5 percent, with no one 

graminoid comprising more than 70 percent relative cover; and 

 The reclaimed upland forest areas have at least two species of trees and one species of 

shrubs present, with each species comprising no less than 5 percent or no greater than 

95 percent of the relative density value. 

If vegetation monitoring indicates that, due to natural or other causes, a reclaimed area 

does not exhibit the potential to achieve the revegetation standards described above, 

corrective actions may be taken that include reestablishment of topsoil thickness, 

reseeding, and replanting of trees and shrubs (GPO 2000). 

Tailings Cover 

Natural regeneration with Sitka spruce and western hemlock is the best strategy for 

protecting the final tailings cover (described in Section 3.9.3, Soils – Environmental 

Consequences) from exposure to atmospheric conditions, specifically water and oxygen 

(OSU 2010). Neither of these species has a tap root which is likely to extend downward 

into the barrier layer. Western hemlock roots occur in flat mats near the surface and the 

majority of Sitka spruce roots are found in the top 1 meter (3.3 feet) of soil (OSU 2010). 

Additionally, the wind throw (uprooting) that is common in spruce/hemlock forested 

communities in southeast Alaska may actually protect the barrier layer by restoring the 

productivity and percolation of the soils above the barrier (OSU 2010). Without wind 

throw, podzolization occurs, leading to less productive vegetation (which eventually 

diminishes), and an increased chance for widespread erosion. 

In southeast Alaska, podzolization occurs primarily in coniferous forests, which have 

needles high in acid resins. As these decompose, soil acidity increases. Because the 

climate is cool, decomposition is slow, and a very acidic organic horizon (mor horizon) 

forms under the surface litter (Brady and Weil 2002; McClellan 1990). Below the mor 

horizon, an eluviated layer (horizon) develops, from which organic matter, iron, 

aluminum, and other complexes have been dissolved by the organic acids. These 

materials are transported downward with water percolating through the soils. The 

eluviated horizon is often composed entirely of sand-sized particles, without much color, 

and without much water holding capacity or plant nutrients – a zone not very useful to 

plant roots (Brady and Weil 2002; Bormann et al. 1995). Below the eluviated horizon, an 

illuviated horizon forms into which those dissolved mineral and organic complexes settle. 

Sometimes the illuviated iron-minerals form a placic horizon (or iron pan) that strongly 
3.10 Vegetation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-145 

reduces the ability of water to percolate through the layer. This placic horizon, together 

with the associated dense organic horizon, poses a barrier to moisture percolation and to 

plant roots seeking nutrients in the illuviated organics, and causes soil saturation 

(McClellan 1990; Bormann et al. 1995). The productivity of the soil diminishes, due to 

the unavailability of nutrients and the increase of soil saturation. 

Re-establishing a productive and functioning forest community would protect against 

erosion and subsequent exposure of the barrier layer by keeping the soil genesis and wind 

throw occurrences as predictable processes within the plant growth layer of the cover to 

percolate precipitation. 

The test plots recommended as a mitigation measure (and described in Section 3.9.3.1) to 

study the optimum depth of the plant growth layer should also include a study component 

to verify that tree roots would not extend downward into the barrier layer. The test plots 

could also be used to develop an appropriate seed or planting mix that would eventually 

result in the establishment of Sitka spruce-western hemlock forests. 

When vegetative cover is removed from an area, there is the potential for invasion of 

disturbed areas by noxious weeds or other invasive species. Weedy species are primarily 

a threat to newly cleared soils because the competition from the existing vegetation is 

reduced. In southeast Alaska, alders and fireweed are the native pioneer species and are 

often the first to become reestablished in an area. Although these species are indicators 

of disturbance, their presence is not detrimental to the successional process. However, 

the introduction of nonnative species might negatively affect the long-term species 

diversity and success of reclamation. Invasive species have not been as great of a 

problem in southeast Alaska as they have been in the lower 48, but species like Canada 

thistle (Cirsium arvense), Japanese knotweed (Polygonum cuspidatum), and foxtail 

barley (Hordeum jubatum) are becoming more widespread (Shephard 2002; ADF&G 

2002). More than 75 species of invasive species have been identified in the Juneau area, 

and have the potential to spread to the Greens Creek Mine and Admiralty Island. Two 

invasive species, reed canary grass (Phalaris arundinacea) and sow thistle (Sonchus 

arvensis) were found during project wetland and sensitive plant surveys of the existing 

and proposed disturbance areas (Bosworth, forthcoming). Previous and subsequent 

surveys found field mustard (Brassica rapa), Canada thistle, and narrow-leafed 

hawksbeard (Crepis tectorum). 

The invasion of weedy species can produce an obvious change in species diversity and 

adversely impact the ecological integrity of an area. An invasive species risk assessment 

was completed for the project by the Forest Service in November 2011 and revised 

November 2012 that identified the following mitigation measures to be implemented: 

 A survey of HGCMC activity areas and roads to determine existing conditions against 

which any future introductions may be recognized. 

 Assurance that all vehicles and heavy equipment transported to the project area are 

free of invasive plant propagules and contaminated soil. This will only be required of 

new equipment entering the Greens Creek activity area and will not include haul 

truck equipment presently located in the area, as these are regularly cleaned after each 

tailings delivery. 

 Use of erosion control materials that are weed seed free. Re-vegetation seed mixtures 

should be compliant with Tongass National Forest guidelines for re-vegetation 
Chapter 3. Affected Environment and Environmental Consequences

3-146 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

(Forest Service 2007a). Avoid use of hay or straw bales for erosion control. Use 

weed-free jute matting, synthetic sediment fence or other weed-free materials. 

 Use of imported rock material for reconstructing existing roads only, or as base 

material that will be buried under layers of local material to avoid introduction of 

invasive plants. 

 Eradication of existing and new high priority invasive plant populations in HGCMC 

activity areas and roads following Forest Service and NEPA guidelines for manual 

(pull/dig) and mechanical (mowing/weed whacking) treatments. Pesticide use 

permits will be approved by the Regional Forester or delegated line officer (Forest 

Service 1994) and treatments will follow NEPA guidelines. The District Botanist 

will receive a copy of the treatment reports as treatment occurs so data may be 

entered into the FACTS database. 

 Triennial survey monitoring of HGCMC activity areas and roads for early detection 

of new or expanded high priority invasive plant infestations for the life of the project, 

and for at least 3 years following closure of the sites. The District Botanist will 

receive a copy of each monitoring report for data entry into the National Resource 

Information System database. 

 Annual monitoring of high-priority treatment sites to facilitate adaptive management 

decisions. 

With implementation of these mitigation measures, the overall risk of high-priority 

invasive plant establishment as a result of the project would be moderate. 

3.10.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. After the TDF is 

fully built out in 2019, reclamation would begin as described in the 2003 EIS (Forest 

Service 2003). 

No new impacts to vegetation would occur under this alternative. 

3.10.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

existing TDF would be expanded. The expanded TDF and associated infrastructure 

would impact approximately 29 acres of upland vegetation, immediately adjacent to the 

existing TDF. These areas would undergo long-term changes in species composition and 

diversity. However, a portion of this area (reclamation material storage area, long-term 

tailings facility slopes, and road cuts and fills) would be subject to interim reclamation 

for soil stabilization. These areas would be revegetated in the short term, which would 

temporarily provide some species diversity. Upland vegetation that would be disturbed 

under Alternative B consists primarily of Sitka spruce-western hemlock forest (Bosworth 

2010). Approximately 128 acres of vegetation would be newly impacted under 

Alternative B consisting primarily of productive old growth (POG) (73 acres) and 

unproductive forest (55 acres). Impacts to wetland vegetation from Alternative B are 

discussed in Section 3.8.3.3. 
3.10 Vegetation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-147 

3.10.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Elimination of 

the quarry would slightly reduce the extent of vegetation disturbed compared to 

Alternative B. Approximately 126 acres of vegetation would be newly impacted under 

Mitigated Alternative B, consisting primarily of POG (64 acres) and unproductive forest 

(62 acres). Impacts to wetland vegetation from Mitigated Alternative B are discussed in 

Section 3.8.3.4. 

3.10.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF. Additionally, the A Road would be upgraded and additional 

facilities would be constructed, including a tailings water transport pipeline, rock quarry, 

water management ponds, and internal access roads. Alternative C would also extend the 

operating period of the mine by 30–50 years, but would allow reclamation to begin in 

some areas of the existing TDF footprint. Effects to vegetation would be more widely 

spread than in alternatives A and B resulting from the development of a new TDF and 

supporting infrastructure; however, they would occur within a condensed period of time 

(first three years) and then be focused on a single area (the new TDF).

Approximately 174 acres of vegetation would be newly impacted over the long term, 

primarily consisting of POG (114 acres) and unproductive forest (60 acres) including 

impacts to wetlands. Impacts to wetland vegetation from Alternative C are discussed in 

Section 3.8.3.5. 

3.10.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new TDF. Like alternatives B, Mitigated B, and C, Alternative D would extend the 

operating period of the mine by 30–50 years. The expansion of the existing TDF would 

be substantially smaller than under Alternative B, however the footprint of the new TDF 

would be similar in size to Alternative C. Effects to vegetation would be similar to or 

slightly greater than Alternative C, but more widespread than alternatives A and B, 

primarily resulting from development of a new TDF. 

Alternative D would have new long-term impacts to approximately 185 acres of 

vegetation, primarily consisting of POG (115 acres) and unproductive forest (70). 

Impacts to wetland vegetation from Alternative D are discussed in Section 3.8.3.6. 

3.10.4 Vegetation – Summary 

Vegetation within the immediate project site is currently dominated by Sitka sprucewestern hemlock forests interspersed with a mosaic of wetlands and meadows. No new 

impacts to vegetation would occur under Alternative A, which would include 
Chapter 3. Affected Environment and Environmental Consequences

3-148 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

continuation of mining until 2019 when project closure and reclamation will begin. 

Under alternatives B, Mitigated B, C, and D, impacts to vegetation would extend an 

additional 30–50 years, and would be similar in type and amount (128, 126, 174 and 

185 acres, respectively). Impacts to vegetation would be more widely spread under 

alternatives C and D, resulting from the development of a new TDF and supporting 

infrastructure. Closure, including vegetation reestablishment, would begin on the 

existing TDF in the near future under alternatives A and C. Under Alternative D, closure 

and vegetation reestablishment of the existing TDF would occur in approximately 10 

years (depending on how long cover placement requires) compared to Alternative B, 

where closure and reclamation would not occur until the end of mining in 30 to 50 years. 

Under all alternatives a weed management plan would be developed and implemented to 

reduce the potential for the establishment of invasive species. 

3.11 Wildlife ____________________________________ 

This section addresses the potential effects of the project to wildlife, including MIS, other 

species of concern, and their habitats. MIS and other species of concern potentially 

occurring in the project area were identified through consultation with the Forest Service, 

ADF&G, and USFWS; published literature, unpublished reports, other NEPA documents 

pertaining to the project area; and field surveys of the project area and other local 

knowledge. Table 3.11-1 provides a comprehensive list of these species and identifies 

species carried forward in the analysis based on known occurrences or the presence of 

suitable habitat in the project area. Species groups discussed in this section include 

furbearers, waterfowl and shorebirds, endemic mammals, marine mammals and 

migratory birds. Federally listed species, candidates for federal listing, and Forest 

Service Alaska Region sensitive species are addressed in Section 3.12, Threatened, 

Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare 

Plants. 

MIS are vertebrates or invertebrate species whose response to land management activities 

can be used to predict the likely response of other species with similar habitat 

requirements (Forest Service Manual [FSM] 2631.3). FSM direction requires the 

assessment of project effects to MIS and that Forest Plan requirements, goals, and 

objectives for these species are met at the project level (FSM 2621.3, 2621.4 and 2672.4). 

Thirteen wildlife species were identified as MIS in the Forest Plan (Forest Service 

2008a). 

Migratory birds are protected by the Migratory Bird Treaty Act (MBTA) and Landbird 

Conservation Plan, which require federal agencies to assess project actions that may 

affect avian species covered by these doctrines and their habitats. The MBTA outlines 

responsibilities of federal land management agencies relative to landbird conservation 

and a Memorandum of Understanding (MOU) between the Forest Service and the 

USFWS provides interim direction on implementation of the MBTA (Forest Service 

2008b). The Forest Service will collaborate with the USFWS, as needed, if project 

actions produce measurable impacts to avian resources (Executive Order 13186; Forest 

Service/USFWS MOU 2001). 
Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 3.11-1. Management Indicator Species and Other Species of Concern in the Vicinity of the Greens Cr

Common Name Scientific Name Habitat Association/Range 

Potential occurren

Greens Cre

Birds 

bald eagle Haliaeetus leucocephalus Associated with coastal areas; nests in old-growth trees. Yes, suitable habitat prVancouver Canada goose 

Branta canadensis fulva Associated with wetlands (both forested and non-forested) in 

estuary, riparian, and upland areas. 

Yes, suitable habitat pr

red-breasted sapsucker Sphyrapicus ruber Primary cavity excavators; use a variety of forested habitats 

but require the presence of snags. 

Yes, suitable habitat prduring 2010 wildlife sur

hairy woodpecker Picoides villosus Primary cavity excavator; use old-growth forest habitats with 

snags and dying trees for foraging and nesting. 

Yes, suitable habitat pr

brown creeper Certhia americana Associated with large-diameter old-growth trees. Yes, suitable habitat pr

Mammals 

brown bear Ursus arctos Use areas from sea level to the alpine. Yes, known to occur in Alexander Archipelago wolf 

Canis lupus ligoni Mainland and the larger islands south of Frederick Sound 

(MacDonald and Cook 2007) where its densities are closely tied to the population levels of their prey (primarily Sitka blacktailed deer). 

No, does not occur on 

black bear Ursus americanus Occurs throughout the mainland and on the islands south of 

Frederick Sound. 

No, does not occur on 

Sitka black-tailed deer Odocoileus hemionus 

sitkensis 

Occurs from shoreline to alpine; associated with old-growth forests. This species represents those that use lower elevation (below 800 feet elevation) productive old-growth 

forest habitats during the winter period. 

Yes, common on Admithe vicinity of the mine. 

mountain goat Oreamnus americana Cliffs, alpine and subalpine habitats. No, does not occur on 

though there is suitable 

marten Martes americana Coastal habitats, riparian areas, larger-sized old-growth 

forests. 

Yes, suitable habitat pr

river otter Lutra canadensis Coastal and freshwater aquatic environments. Yes, suitable habitat prred squirrel Tamiasciurus hudsonicus Occupies a wide variety of forest habitat; requires forests with 

cone-producing trees and cavities in trees and snags for nesting and denning. Likely introduced around 1950 and has successfully colonized Admiralty Island (MacDonald and Cook 2007). 

Yes, suitable habitat proccur in vicinity of the pindividuals were recordhabitat assessment in 2

Notes: 

a. Source: Boreal Partners in Flight Landbird Conservation Plan for Alaska Biogeographic Regions (BPIF 1999) and BPIF (2011). b. MIS = Tongass National Forest Management Indicator Species; SOC = other species of concern. c. Breeding = only has potential to occur during the spring/summer breeding season (dates vary by species); Migration = only has the poten

migration; Winter = only has the potential to occur in the project area during winter, outside of the breeding season.
Chapter 3. Affected Environment and Environmental Consequences

3-150 Greens Creek Mine Tailings DispTable 3.11-1. Management Indicator Species and Other Species of Concern in the Vicinity of the Greens Cr

Common Name Scientific Name Habitat Association/Range 

Potential occurren

Greens Cree

Migratory Birds 

marbled murrelet Brachyramphus 

marmoratus 

Associated with mature/old growth forests. Yes, suitable habitat pre

during 2010 wildlife surv

blue grouse Dendragapus obscurus Associated with spruce/hemlock/cedar forests of southeast 

Alaska as a primary or secondary habitat. 

Breeding, Winter 

western screech owl Otus kennicottii Breeding, Winter black swift Cypseloides niger 

(borealis) 

 Breeding 

Vaux’s swift Chaetura vauxi Migration Breeding rufous hummingbird Selashorus rufus Migration, Breeding red-breasted sapsucker Sphyrapicus ruber Breeding olive-sided flycatcher Contopus cooperi Breeding western wood-pewee Contopus sordidulus Breeding Hammond’s flycatcher Empidonax hammondii Breeding Pacific-slope flycatcher Empidonax difficilis Breeding Steller’s jay Cyanocitta stelleri Breeding, Winter northwestern crow Corvus caurinus Breeding, Winter chestnut-backed chickadee 

Poecile rufescens Breeding, Winter 

varied thrush Ixoreus naevius Migration, Breeding, WiTownsend’s warbler Dendroica townsendi Breeding blackpoll warbler Dendroica striata Migration MacGillivray’s warbler Oporornis tolmiei Breeding golden-crowned sparrow 

Zonotrichia atricapilla Breeding, Winter 

golden-crowned kinglet Regulus satrapa Breeding, Winter black swift Cypseloides niger 

(borealis) 

 Breeding 

American dipper Cinclus mexicanus Breeding Notes: 

a. Source: Boreal Partners in Flight Landbird Conservation Plan for Alaska Biogeographic Regions (BPIF 1999) and BPIF (2011). b. MIS = Tongass National Forest Management Indicator Species; SOC = other species of concern. c. Breeding = only has potential to occur during the spring/summer breeding season (dates vary by species); Migration = only has the poten

migration; Winter = only has the potential to occur in the project area during winter, outside of the breeding season.
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-151 

The Bald and Golden Eagle Protection Act of 1940, as amended, prohibits anyone, 

without a permit issued by the Secretary of the Interior, from “taking” eagles, including 

their parts, nests, or eggs. The definition of take includes disturbance and covers impacts 

that result from human-induced alterations initiated around an active and previously used 

nest site during a time when eagles are not present, should disturbance impact eagles or 

their habitat use upon returning to the nest site. 

3.11.1 Wildlife – Pre-mining Environment 

Prior to mining, the wildlife habitats in the vicinity of the 

mine were much like the existing vegetation elsewhere on 

Admiralty Island. The predominant vegetation type is 

hemlock-spruce forest, interspersed with a mosaic of nonforested plant communities, including peat wetlands, 

shrub wetlands, and sedge meadows (Forest Service 

2003). Coastal and nearshore marine habitats are present 

in Hawk Inlet and riparian and aquatic habitats occur 

along Cannery Creek, Greens Creek, Tributary Creek, 

and several smaller creeks (Further Creek, Franklin 

Creek, Proffett Creek, Althea Creek and CC Creek). 

These habitats supported a number of marine mammal, 

terrestrial mammal, avian, and fish species. 

Admiralty Island was designated as a National Monument 

in 1978 in part for its unique island ecology which included the highest density of nesting 

bald eagles, large numbers of Alaska brown bear, and the largest unspoiled coastal island 

ecosystem in North America (16 USC 431 note 43 FR 57009). In his proclamation, the 

island was described by President Carter as “an outdoor living laboratory for the study of 

bald eagle and Alaska brown bear.” A noted unusual aspect of the island’s ecology was 

that it possessed exceptional distributions of certain wildlife species, but, due to its 

separation from the mainland, excluded entirely a large number of other species 

indigenous to the general area. 

Prior to construction and operation of the Greens Creek Mine there was an existing level 

of human activity in the area. The Hawk Inlet marine terminal at the mouth of Cannery 

Creek previously served as a fish cannery facility. Hawk Inlet and Admiralty Island as a 

whole have been, and continue to be, used for subsistence activities and recreation 

including boating, fishing, wildlife viewing, and hunting. Commercial fishing is 

conducted in Hawk Inlet. A limited amount of mining outside of the Greens Creek 

watershed has also occurred. In the mid-1970s detailed mining exploration, including 

surface drilling, began in the Greens Creek area (Forest Service 1983). In the late 1970s 

an entirely helicopter-supported exploration program involving extensive underground 

drilling began. Thus, prior to development of the mine, wildlife in the vicinity were 

exposed to an existing level of localized disturbance. 

3.11.2 Wildlife – Baseline Conditions 

This section provides a more detailed description of existing wildlife resources in the 

vicinity of the mine site and impacts that have occurred to date. The study area for 

The resource analysis of 

wildlife is related to Issue 2 

impacts of wetlands and 

associated habitat values as 

well as Issue 3 impacts to 

fish streams. Wildlife also 

plays a role in defining 

Monument Resources 

(Issue 4). Measures of 

wildlife resources include 

acres of impacted habitat for 

selected MIS.
Chapter 3. Affected Environment and Environmental Consequences

3-152 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

wildlife includes a one-half-mile buffer around the proposed TDF expansion areas and 

the portion of the B Road extending from the existing lease boundary north to the TDF 

expansion under alternatives C and D, plus the adjacent waters of Hawk Inlet. This area 

extends beyond the limit of direct ground disturbance but is adequate to capture farther 

reaching effects to wildlife such as noise and the introduction and spread of invasive 

species. A larger spatial scale is used to describe effects for wider ranging species 

including deer (Wildlife Analysis Area [WAA]) and brown bears (Game Management 

Unit [GMU]). WAAs are geographical divisions created by the ADF&G to monitor and 

manage wildlife populations. GMUs are geographical areas defined by the ADF&G to 

manage wildlife populations. The project is in WAAs 3836 and 3837, and in GMU 4, 

which includes Admiralty, Baranof, Chichagof, Yakobi, Inian, Lemesurier, and Pleasant 

islands. 

The vegetation of southeast Alaska and the Tongass National Forest is dominated by 

temperate coastal rain forests at lower elevations (less than about 2,000 feet), with 

interspersed muskegs, other wetlands, and other nonforest types. At higher elevations, 

alpine vegetation, rock, glaciers, and snowfields dominate. Although many wildlife 

species in the Tongass National Forest are associated with more than one habitat type, 

most inhabit old-growth forests or prey on species that inhabit old-growth forests. 

Therefore, the following discussion in relation to wildlife focuses on the old-growth 

ecosystem. 

Old-growth forests in the Tongass National Forest can be classified as unproductive and 

productive. Productive old-growth is generally defined as old-growth capable of 

producing at least 20 cubic feet of wood fiber per acre per year, or having greater than 

8,000 board feet per acre. The Size-Density Model (SDM), which uses a combination of 

tree sizes and tree densities to classify forest structure (Caouette et al. 2000), is used by 

Forest Service managers and planners to map POG and assess impacts to wildlife and 

habitats in the Tongass National Forest. 

Table 3.11-2 displays the acres of POG5

, and other habitats within the study area. There 

are approximately 2,426 acres of POG in the study area, 95 percent of which are below 

800 feet in elevation. Productive old-growth is discussed based on the SDM, which is 

described in more detail the 2008 Tongass Forest Plan, but summarized below. The 

SDM, which was developed to better describe forest structure, ecosystem diversity, and 

wildlife habitat, separates POG into seven distinct classes: 

 SD-4H: Low productive older forest associated with wet, poorly drained land types. 

Canopy closure is variable and trees are generally small, old, and defective. 

 SD-4N: Low to moderately productive older upland forest. Canopy characteristics 

are variable and patchy with moderate canopy closure and relative coarse canopy 

texture. 

 

5

 Forest land on the Tongass is defined as productive or unproductive, distinguished in terms of their ability 

to produce wood. The distinction is primarily used in timber management; however, it is also useful for 

describing forest cover types for biodiversity and wildlife habitat because these categories describe forest 

structure. Productive forest land is defined as land capable of producing at least 20 cubic feet of wood fiber 

per acre per year or having greater than 8,000 board feet per acre of standing volume. Unproductive forest 

land is forest land that does not meet these thresholds. 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-153 

Table 3.11-2. Acres of Productive Old-growth Forest by Size-Density Model 

Classes and Other Habitats within the Study Area. 

Productive Old Growth by SDM Classes Acres 

Productive Old-Growth 

SD4H 607 

SD4N 121 

SD4S 421 

SD5H 265 

SD5N 139 

SD5S 307 

SD67 565 

Total Productive Old Growth 2,426 

Other Habitats 

Unproductive Forest 616 

Forested Muskeg 15 

Young-growth 22 

Non-forested 20 

Water 2 

Total Other 674 

Total 3,100 

 SD-4S: Highly productive younger upland forest. Stand volume is moderate but 

increasing. Canopy characteristics tend to be uniform with high canopy closure and 

fine texture. 

 SD-5H: Moderately productive older forest associated with wet, poorly drained land 

types. Canopy closure, texture, and structure tend to be variable and patchy. 

 SD-5N: Moderately productive older upland forest. Canopy traits tend to be variable 

with moderate canopy closure and coarse canopy texture. 

 SD-5S: Highly productive upland forest. Stand volume is high. Canopy 

characteristics tend to be uniform with moderate to high canopy closure. 

 SD-6/7: Highly productive forest associated with riparian areas, alluvial fans, 

colluvial toe slopes, karst geology, and wind protected uplands. Stand volume is 

high. Canopy closure is low to moderate and canopy texture is coarse. 

Resources used to derive information on baseline conditions include the following: 

 Greens Creek Tailings Final EIS (Forest Service 2003); 

 Greens Creek Mine Final EIS (Forest Service 1983); 

 Peer reviewed research; 

 NMFS stock assessments (Allen and Angliss 2010); and 

 Field studies conducted in support of this project (Kai Environmental Consulting 

2010a, b). 
Chapter 3. Affected Environment and Environmental Consequences

3-154 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

This section provides relevant life history information for the species potentially 

occurring in the vicinity of the mine site and highlights new information including 

information from recent field surveys that form the current project baseline. Note that if 

a species is not observed during a specific field survey, it does not necessarily indicate 

that the species does not use the area at all. 

Potential effects to wildlife associated with construction and operation of the mine 

addressed in the 1983 and 2003 EIS included habitat loss, disturbance and/or 

displacement due to mining activities, attraction of wildlife to mine facilities, and 

contamination due to contact with water discharged into Hawk Inlet. Effects that have 

occurred under current operations are summarized in the following discussion. 

Direct habitat loss has resulted from development of the Greens Creek Mine and 

associated processing facilities and infrastructure. Habitat removal has primarily 

consisted of spruce-hemlock forest with shoreline and muskeg habitats to a lesser extent. 

The 1983 and 2003 EISs concluded that terrestrial habitat loss would have a negligible 

impact to terrestrial species due to the availability of these habitats in the surrounding 

area. To date, most disturbance caused by construction and operation of the mine has 

been Sitka spruce-western hemlock forest with a smaller amount of disturbance to 

wetland communities (Forest Service 1983). Figure 3.10-1 depicts existing vegetation 

within the study area. Construction of the effluent discharge system disturbed a small 

amount of offshore habitat which was anticipated to quickly reestablish itself (Forest 

Service 1983). 

Disturbance from noise and human activity associated with mining operations and the 

ongoing exploration for additional ore reserves also has likely had an effect to terrestrial 

species, causing an indirect loss of habitat. Displacement was anticipated to occur in 

association with human activity in the vicinity of the dock at Young Bay, the Hawk Inlet 

marine terminal, the mill site, and the TDF, as well as continuous truck transport of 

concentrate from the mill to the Hawk Inlet marine terminal. The 1983 EIS noted that 

this loss is difficult, if not impossible, to quantify because species and even individuals 

differ in their tolerance to noise and human activity. 

The 1983 EIS concluded that some species, such as marten, bear, and deer, may 

permanently avoid the areas immediately adjacent to areas of high human activity, but 

due to the small footprint of the facility the presence of the mine and associated facilities 

would not create substantial physical or behavioral barriers to animal movements. 

Expansion of the TDF addressed in the 2003 EIS was not anticipated to result in 

additional indirect habitat loss because the expansion was located in the existing lease 

area. Species such as deer and brown bears are observed frequently in the vicinity of the 

mine site; therefore, it is apparent that some species have adapted to ongoing operations. 

Occurrence of wildlife in the vicinity of the mine site is described in more detail under 

the discussion for each species. 

Alternately, mining operations can result in the creation of artificial habitats (i.e., 

retention ponds) or involve human activities (i.e., garbage) that attract wildlife. These 

scenarios can be detrimental to wildlife and humans, particularly when species or 

individual animals become habituated and interactions result in injury or death. To 

minimize this effect, all food garbage is kept indoors until it is incinerated (daily) and 

littering or feeding of wildlife is prohibited. Hazing is employed when animals need to 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-155 

be deterred from project facilities. Despite these efforts there have been instances of 

negative interactions between humans and brown bears (see the discussion under brown 

bears below for additional information). 

The large barges and ships that transport the concentrate from the mine on a regular basis 

typically operate at low, constant speed and infrequent intervals. The crew shuttle, 

however, transits Stephens Passage with two daily roundtrips. Although the crew shuttle 

operates at a higher speed than the larger vessels, the shuttle follows a regular course. All 

project-related vessels operate in compliance with the Marine Mammal Protection Act 

(MMPA), Endangered Species Act (ESA), and NMFS guidelines for speed and 

approaching marine mammals and stay at least 100 yards from any marine mammal, 

which reduces the likelihood of disturbance and collisions. Therefore, vessel traffic is 

not likely to affect marine mammal distribution in Hawk Inlet, Young Bay, Stephens 

Passage, and Chatham Strait, particularly given that there is an existing level of vessel 

activity in these areas. 

Another issue identified after operation of the mine began was the potential risk of 

chemical and heavy metal accumulation in Hawk Inlet and resulting bioaccumulation in 

higher level organisms such as fish, shellfish, mammals, and birds could occur primarily 

through transfer of metals from prey items. Monitoring data indicate that there has been 

an increase in some metals in marine sediments at Outfall 002, which could accumulate 

in benthic organisms (see Section 3.7, Aquatic Resources). Adherence to the NPDES 

permit (which places restrictions on the types, quantities, and extent of effluent 

discharges that are allowed to be discharged to waters) limit the effects of the project on 

water quality. During a facility audit in 2009, it was noted that discharge monitoring 

reports have been submitted as required by the NPDES permit and all measured 

parameters were within permit limits. Instrumentation excursions and data recording 

interruptions were within allowable limits; excursions were thoroughly documented by 

HGCMC (SRK 2009). 

Fugitive dusts, resulting from road traffic, concentrate transportation, and diesel 

emissions from the mining operations at the portal and the TDF are emitted into the air 

and have the potential to accumulate over time in lichens and possibly other ecosystem 

components. Dust particles carried by the wind settle in the surrounding area. 

Subsequently the dust particles, or contaminants metabolized into plant tissues, may then 

be eaten by animals, which may then be eaten by other animals. Heavy metals can cause 

acute or chronic neurotoxic, carcinogenic, or reproductive effects to wildlife (AMAP 

2005). Some metals can bioaccumulate (concentrations increase within an organism over 

time as they continue to consume contaminated foods) or biomagnify (concentration 

increases through the food chain). Typically, heavy metals concentrations are most 

concentrated near the source, dissipating with distance. 

The Forest Service established a biomonitoring program on the Tongass National Forest 

which uses lichens to monitor air quality (Section 3.2.2, Air Quality – Baseline 

Conditions). Lichens are commonly used as sensitive receptors for air pollution because 

they are intimately tied to local conditions and airborne contaminants are absorbed easily 

and become concentrated in the lichen tissues (Dillman et al. 2007). They are also tied to 

many ecosystem functions including nutrient cycling, and provide food and nesting 

material for a variety of vertebrate and invertebrates. Lichen biomonitoring can be used 

to assess changes in contaminants over time, patterns of contaminant accumulation, and 
Chapter 3. Affected Environment and Environmental Consequences

3-156 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the need for additional monitoring for human health concerns (Dillman et al. 2007). 

Results of the lichen studies are discussed in Section 3.2.2. 

3.11.2.1 Management Indicator Species 

Brown Bear 

Admiralty Island supports one of the highest densities of brown bears in North America. 

The ADF&G estimates a population of 4,200 bears in GMU 4 (ADF&G 2000), with 

approximately 1,560 bears inhabiting Admiralty Island (Whitman 2003). Brown bears 

are the only large omnivore on Admiralty, Baranof, Chichagof, and the smaller adjacent 

islands. Brown bears are an important species from recreation and tourism, hunting, and 

cultural perspectives. GMU 4 is one of the most desirable hunting and bear viewing 

places in the world (ADF&G 2000). Currently for resident and non-resident hunters on 

Admiralty Island there is a bag limit of one bear every four regulatory years by 

registration permit only. In regulatory year 2005 (fall 2005 and spring 2006), there were 

a total of 120 hunter kills and 11 non-hunter kills (defense of life and property, illegal, 

and other human-caused sources of mortality) (Mooney 2007). The well-known Pack 

Creek Bear Viewing Area is located in Stan Price Game Sanctuary in the Seymor Canal 

on the east side of Admiralty Island. 

According to the ADF&G, the major reason the larger islands of GMU 4 can support 

such dense populations of bears is the presence of salmon streams that provide a readily 

accessible, efficient way for bears to lay on essential fat reserves. Brown bears are 

habitat generalists; however during the late summer use is typically concentrated along 

low elevation valley bottoms and salmon streams, with most use occurring within 500 

feet of streams (Schoen and Beier 1990; Titus and Beier 1999). During this time their 

efforts focus on consuming large quantities of fish in order to rebuild their body condition 

in preparation for winter. Pre-denning accumulation of energy stores and den site 

suitability are critical for successful winter denning (Schoen et al. 1989). 

Bears also use forests along streams for travel, loafing between fishing sessions, hiding, 

and escape cover from other bears and humans (Titus and Beier 1999). On Admiralty 

Island 83 day beds were located an average of 52 meters from streams (Schoen and Beier 

1990). Radio-telemetry data from a study on the northeast portion of Chichagof Island 

indicates that in a given year brown bears do not usually travel to more than one salmon 

spawning stream and they may visit the same stream section year after year (Titus and 

Beier 1999). 

Given the importance of riparian habitat to brown bears, the primary management issues 

affecting this species in GMU 4 are loss and alteration of riparian habitat and disturbance 

associated with human activities near these areas which can displace bears (ADF&G 

2000). Flynn et al. (2007) found bears, particularly females, in heavily altered 

watersheds (i.e., with more road building and timber harvest) tended to occur farther 

away from salmon streams than bears in watersheds with more intact streamside 

vegetation suggesting that bears are not making optimal use of available salmon 

resources in heavily altered landscapes. A study on the Kenai Peninsula reported that 

female brown bears with cubs tended to avoid areas used by other bears and by humans, 

apparently in an effort to increase offspring survival, and used less productive salmon 

spawning areas despite having high nutritional requirements (Suring et al. 2006). Thus 

even less productive streams may be important to brown bear population productivity 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-157 

(Wielgus and Bunnell 2001). Roads and other human developments can also be 

detrimental to bears because they increase the opportunity for human-induced mortality 

of bears through legal hunting, defense of life or property kills, and illegal killing. 

Additionally, poorly maintained or constructed roads can affect water quality and 

productivity of salmon streams. 

The Forest Plan includes a number of standards and guidelines for brown bears intended 

to minimize adverse impacts to brown bear habitat and reduce human/bear conflicts. 

Those that apply to the project include implementing bear-proof garbage disposal 

methods; locating mineral operational facilities more than one mile from important 

seasonal bear concentrations; and maintaining 500-foot forested buffers, where available, 

from Class I anadromous streams (Forest Service 2008b). Within the study area there are 

approximately 8,970 acres of forest within 500 feet of Class I streams in WAA 3836 and 

10,202 acres of forest within 500 feet of Class I streams in WAA 3837. Greens Creek, 

Zinc Creek, and the lower stretch of Tributary Creek are important salmon spawning 

areas. The study area also includes beach fringes and grass meadows where bears 

concentrate in late spring to forage on grasses, sedges, forbs, carrion, and available 

marine organisms. 

A radio-telemetry study conducted by the ADF&G between 1981 and 1989, which 

covered the period of mine construction and initial operations, indicated that in general 

home ranges and seasonal distributions of bears in the vicinity of the mine were not 

altered by construction. However, within their home ranges bears appeared to 

temporarily shift away from active construction, denning farther from the mine site after 

construction and shifting their use of foraging areas along Greens Creek and Zinc Creek 

to avoid construction (Schoen and Beier 1990). In contrast, some bears appeared to be 

habituating to helicopter and vehicle traffic near the Greens Creek Delta. The authors 

noted that the results of the study reflect the short-term effects of mine development and 

cannot be used to conclude that development of the mine will have minimal impacts to 

the local brown bear population. 

Bears are seen frequently on or near the Greens Creek Mine road system, throughout the 

Greens Creek drainage, and further north on the peninsula between Hawk Inlet and 

Young Bay (Forest Service 2003). Most observations (several per week) occur in May 

and June. The 2003 EIS reported four bear deaths associated with the mine (late 1970s, 

1992, 1993, 1999), two of which involved the shooting of aggressive bears and two were 

due to vehicle collisions (Forest Service 2003). Most recently in 2006, a juvenile female 

brown bear was killed by a larger bear in a work area adjacent to the underground mine. 

Bald Eagle 

Admiralty Island supports the highest documented density of breeding bald eagles in 

North America, with the majority of breeding birds remaining resident year-round 

(Stenhouse 2007). The bald eagle was selected as an MIS to represent species associated 

with beach, estuary fringe, and riparian habitats. Bald eagles typically nest in large trees 

in spruce-hemlock forest, and over 90 percent of the nests are within 500 feet of a 

saltwater beach. Nests are located in beach, estuary fringe, and riparian habitats. An 

aerial survey covering the shoreline areas in the vicinity of the mine site was conducted 

in July 2011 (D. Rudis, USFWS personal communication, 2011; S. Lewis, USFWS, 

personal communication 2011) which documented eagle nesting activity along the shore 
Chapter 3. Affected Environment and Environmental Consequences

3-158 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

in Hawk Inlet and along the coast. There are three bald eagle nests (all inactive in 2011) 

located within one-half mile of the existing TDF and one nest within one-half mile of the 

A Road (inactive in 2011). There are three nests (two active nests and one inactive nest) 

located within one-half mile of the new TDF area proposed under alternatives C and D; 

one of the active nests is approximately 900 feet west of the proposed quarry site. 

Bald eagles are especially sensitive to disturbance early in the breeding season. 

Activities associated with resource extraction, development, and recreation can result in 

reproductive failure or cause bald eagles to abandon their nests completely (Fraser et al. 

1985). Bald eagles are managed by the USFWS under the National Bald and Golden 

Eagle Protection Act and through the Bald Eagle Take Permit Program (USFWS 2009). 

Guidelines indicate that mining activities should not take place within 660 feet of a nest, 

unless other similar activities already occur within 1 mile of a nest, in which case the 

mining activity may take place closer to a nest, if other activities are tolerated at the 

proposed distance from the nest (USDI Fish and Wildlife Service 2007, p. 23). The CBJ 

Land Use Code (49.70.310[a]) prohibits development within 330 feet of an eagle nest on 

public lands. Further protection to bald eagles is afforded by Forest-wide standards and 

guidelines that require the maintenance of a 1,000-foot beach buffer along the shoreline 

(Forest Service 2008b). 

Bald eagles primarily forage on fish, including herring, flounder, pollock, and salmon. 

Thus, they are also susceptible to water quality impacts that adversely impact their prey 

populations. 

Sitka Black-tailed Deer 

Sitka black-tailed deer, an endemic subspecies of mule deer, are widely distributed 

throughout coastal southeast Alaska and are common in the study area. They represent 

species that use lower elevation (below 800 feet elevation) productive old-growth forest 

habitats during winter, and are an important subsistence and game species. Currently for 

resident and non-resident hunters on Admiralty Island there is a bag limit of four deer. In 

regulatory year 2007–2008 the estimated legal harvest from GMU 4 was 1,851 deer; 

illegal harvest during this period was 463 deer (Mooney 2009). Current federal 

subsistence regulations allow federally qualified subsistence users to harvest 6 deer in 

GMU 4. 

The quality, quantity, spatial distribution, and arrangement of winter range are considered 

the most limiting factors for the species in southeast Alaska (Forest Service 2008a). 

Good-quality winter range for deer includes areas with closed canopy forests, maritime 

influence, south facing slopes, and low average snow depth (Forest Service 2008a). 

Optimum winter deer habitat during deep-snow conditions includes forest stands with an 

overstory capable of intercepting snow to make available for deer an important 

understory of forage species including bunchberry (Cornus canadensis), five leaf 

bramble (Rubus pedatus), and Vaccinium species (Hanley et al. 1989; Kessler 1982). 

Based on deer habitat modeling conducted for the 2008 Forest Plan (see pages 3-265 

through 3-277 of the 2008 Forest Plan FEIS for details on the model) there are 40,603 

acres of deer winter range in WAA 3836 and 41,418 acres of winter range in WAA 3837. 

Deer winter habitat surveys were conducted in July 2010 and 2011 in the existing TDF 

area and the new TDF area to the north of the existing TDF, respectively (Kai 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-159 

Environmental Consulting 2010b, 2011b). The survey areas included abundant forage 

for black-tailed deer. Understory species including Vaccinium spp., bunchberry, and five 

leaf bramble were all ubiquitous, with some species more patchily distributed than others. 

The western and southern portions of the survey area (where a small portion of the TDF 

expansion would occur, but other facilities are proposed) have the highest quality winter 

habitat, based on forest cover and forage availability. 

Tree clearing may reduce the amount of available winter range for deer. The 2003 EIS 

concluded that because the current TDF expansion area would be accessible to deer if 

they crossed through areas of high human activity and because it was not connected to 

any other forest habitat, it likely was of low value to wintering deer particularly during 

periods of deep snow when deer movements would be restricted. Further, given the 

amount of similar surrounding forested lands, the impact of habitat loss was deemed 

minimal, becoming even less so upon reclamation (Forest Service 2003). 

The 2003 EIS noted that deer are frequently observed near mine facilities, and deer 

congregate along the Greens Creek road system, feeding on the reclamation grasses 

during spring, summer, and fall. Deer use of the mine site appears to drop in the winter 

when snow forces them to seek cover beneath the mature forest canopy. Deer/vehicle 

collisions along the road system occur approximately 3 to 5 times a year despite an 

observed speed limit and radio communication between drivers alerting them to animal 

sightings as traffic moves along the road system (Forest Service 2003). 

Marten 

Two distinct types of marten have been documented within the Alexander Archipelago, 

American marten (Martes americana) and coastal marten (M. caurina). Coastal marten 

is endemic to southeast Alaska and indigenous to Admiralty Island (Dawson et al. 2007). 

Marten are an indicator of species associated with productive old-growth forest. The 

marten is also an important furbearer in southeast Alaska. Currently in GMU 4 ADF&G 

permits unlimited trapping of marten. In the 2005–2006 season 2,231 marten were 

trapped in GMU 4 (Mooney 2007b). 

Larger-sized old-growth forests have the highest value for marten because they intercept 

snow; provide cover and denning sites; and provide habitat for their prey (Flynn et al. 

2004). Use of second growth 26–40 years in age has been documented in stands with 

abundant understory forage and small mammal populations (Flynn et al. 2004). Habitat 

requirements reflect a strong interaction between food, cover, climate, and predation, 

with forest cover being particularly important for travel, dens and resting sites, hunting, 

and avoiding predation and inclement weather (Flynn and Schumacher 1999, 2001). 

There are approximately 1,011 acres of high-volume productive old-growth in the study 

area SDM classes SD-5N, SD-5S, and SD-67 (summarized above in Section 3.11.2; see 

Forest Service 2008a for more detail). Marten occur year-round in the vicinity of Hawk 

Inlet, Greens Creek, and Young Bay. 

Primary threats to marten include habitat alteration, which could influence the 

distribution and availability of prey species, and fragmentation which could limit marten 

dispersal. Marten densities are higher in intact forests with less fragmentation (Hargis et 

al. 1999; Flynn et al. 2004), indicating that a large, contiguous block of old-growth is 

important for this species. Additionally, marten populations fluctuate widely in response 

to prey availability; recent research indicates that the abundance of long-tailed voles is 
Chapter 3. Affected Environment and Environmental Consequences

3-160 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the best predictor of marten abundance (Flynn and Schumacher 2001; Flynn et al. 2004). 

Marten are considered easy to trap, and local populations can be over-harvested (Forest 

Service 2008a), therefore development that increases trapper access has the potential to 

affect the local marten population. Protection for marten is provided for in the Forest 

Plan through its overall conservation strategy, including standards and guidelines for 

marten and endemic terrestrial mammals(Forest Service 2008b). 

Vancouver Canada Goose 

The Vancouver Canada goose is a primarily a non-migratory waterfowl species that 

occurs year-round throughout southeast Alaska (Hupp et al. 2010). However geese do 

move locally between nesting, brood rearing, molting, and wintering grounds. This 

species nests almost exclusively in forested habitats associated with beach fringe, estuary 

fringe, and riparian habitats. Hupp et al. (2010) documented nests in forests adjacent to 

muskegs such as those near to the proposed tailings expansion areas. During winter, 

marine grasses and salt marsh plants commonly found in intertidal areas are important 

forage resources, and Vancouver Canada geese exhibit strong fidelity, returning 

repeatedly to such winter sites (Fox 2008). This species was selected as an MIS because 

of its association with wetlands (both forested and non-forested) in the estuary, riparian, 

and upland areas of the forest. There are approximately 3,267 acres of wetlands in the 

study area, including bogs, fens, forested wetlands, and marshes, which provide potential 

habitat for the Vancouver Canada goose (Table 3.8-3). Protection under the Forest Plan 

is provided through standards and guidelines for waterfowl and shorebird habitats, 

wetlands, beaches, estuaries, and riparian areas (Forest Service 2008b). 

River Otter 

The river otter is an MIS, selected to represent species associated with coastal and 

freshwater aquatic environments and the immediately adjacent (within 100 to 500 feet) 

upland habitats. River otter are frequently observed in the drainages of Greens and Zinc 

creeks and along the shoreline (including nearshore marine areas) of Hawk Inlet and 

Young Bay and in the vicinity of the cannery (Forest Service 1983). River otter are also 

frequently seen near the pond associated with the Cannery Creek dam. Currently on 

Admiralty Island, ADF&G allows unlimited trapping of these species. Protection under 

the Forest Plan is provided through standards and guidelines for beaches, estuaries and 

riparian areas (Forest Service 2008b). 

Red Squirrel 

Red squirrels require forests with cone-producing trees and cavities in trees or snags. 

Spruce trees and mature/old-growth forests are considered to have the highest values for 

red squirrel habitat (Forest Service 2008b). Optimum conditions are believed to occur 

where patches of preferred habitat are greater than 30 acres. Red squirrels are thought to 

have been introduced to the northern end of Admiralty Island in the late 1940s or early 

1950s and appear to have successfully colonized the island (McDonald and Cook 2007). 

Two individual squirrels were documented in 2010 while conducting deer habitat 

assessment surveys in the vicinity of the existing TDF. Protection under the Forest Plan 

is provided through standards and guidelines for beaches, estuaries and riparian areas 

(Forest Service 2008b). 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-161 

Red-breasted Sapsucker, Hairy Woodpecker, Brown Creeper 

The red-breasted sapsucker, hairy woodpecker, and brown creeper were selected as MIS 

to represent old-growth associated and snag dependent species. Hairy woodpeckers and 

red-breasted sapsuckers are primary cavity excavators that require snags and dying trees 

for foraging and nesting. The brown creeper requires large diameter old-growth trees. 

These species are protected under the Forest Plan conservation strategy including reserve 

tree/cavity-nesting species standards and guidelines (Forest Service 2008b). 

The red-breasted sapsucker inhabits all of southeast Alaska during spring, summer, and 

fall but typically winters in the coastal portions of its breeding range. The hairy 

woodpecker is an uncommon, permanent resident throughout southeast Alaska. Both 

species have the potential to inhabit old-growth forest in the study area; however, the redbreasted sapsucker is typically associated with low volume POG (SD4H category) 

whereas the hairy woodpecker is typically associated with high volume old-growth 

(SD5S, SD5N, and SD67 categories). This species, and in particular the hairy 

woodpecker, appear to avoid forest edges (Kissling and Garton 2008). There are 

approximately 607 acres of SD4H, 307 acres of SD5S, 139 acres of SD5N, and 565 acres 

of SD67 forest in the study area (Table 3.11-2). A red-breasted sapsucker was observed 

during 2010 wildlife surveys in the existing TDF expansion site (Kai Environmental 

Consulting 2010). 

Brown creepers are considered uncommon, permanent residents throughout southeast 

Alaska. This species is also associated with high volume productive old-growth (SD5S, 

SD5N, and SD67 categories). Brown creepers are an interior forest species and have 

been shown to abandon sites that have been subjected to even light tree clearing (i.e., 

partial cut timber harvest) if it includes the removal of large, mature trees (Wiggins 

2005). 

3.11.2.2 Other Species of Concern 

Marbled Murrelet 

In March 2006, a status review for the marbled murrelet was initiated by the USFWS for 

the northern part of the species range to support ESA deliberations over the listing of the 

species as threatened in the southern part of its range (California, Oregon, and 

Washington; Piatt et al. 2007). Genetic analysis conducted as part of the review 

identified three distinct population segments (DPSs): one in the central and western 

Aleutian Islands; one ranging from the eastern Aleutians to northern California; and one 

in central California. Marbled murrelets are widely distributed across marine waters in 

southeast Alaska. 

Marbled murrelets spend the majority of their lives at sea, but travel inland up to 50 miles 

to nest in old-growth forest stands (Piatt et al. 2006). While at sea, murrelets remain 

close to nesting habitat during periods when inland flights are frequent, but otherwise are 

distributed in relation to prey availability. Marbled murrelets typically nest on mossylimbed branches of large, mature coniferous trees within stands of structurally complex, 

coastal old-growth forest (SD5N, SD5S, and SD67 categories; DeGange 1996; Kuletz et 

al. 1995; Ralph and Miller 1995). However, on some treeless islands in southeast Alaska 

marbled murrelets will lay eggs on bare talus slopes in mountainous areas (Piatt et al. 

2007). Only six nests have been found in southeast Alaska (Forest Service 2003). 
Chapter 3. Affected Environment and Environmental Consequences

3-162 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

There are approximately 1,011 acres of suitable marbled murrelet nesting habitat in the 

study area. One marbled murrelet was observed during 2010 wildlife surveys conducted 

in the existing TDF site (Kai Environmental Consulting 2010). Threats to the marbled 

murrelet include loss of forested nesting habitat and reductions in water quality which 

could impact forage species such as herring. Forest Plan standards and guidelines 

pertaining to marbled murrelets include maintaining a 600-foot radius no-cut buffer zone 

around identified murrelet nests (Forest Service 2008b). 

Waterfowl/Shorebirds 

A variety of waterfowl, seabirds, and wading birds occur in the vicinity of the study area 

depending on the season. The three primary areas of waterfowl/shorebird habitat include 

the estuary in upper Hawk Inlet; the mouth of Hawk Inlet, including Piledriver Cove, 

Hawk Point, and the Greens Creek/Zinc Creek Delta; and the southern portion of Young 

Bay (Forest Service 2003). Upper Hawk Inlet is used throughout the summer by many 

species of diving and dabbling ducks and is an important resting area for dabblers during 

fall and spring migrations. Shorebirds and gulls also use the estuary and associated mud 

flats. The mouth of Hawk Inlet provides year-round habitat for waterfowl and other 

birds. At the southern portion of Young Bay, in the vicinity of the dock for the Greens 

Creek Mine, is a waterfowl and shorebird migration concentration area. Migrating 

waterfowl use ponds and beaver impoundments in the study area for feeding, resting, and 

probably for breeding. 

A survey of the distribution and abundance of waterbirds in southeast Alaska conducted 

between 1997 and 2002 indicated that the most abundant species in nearshore waters 

during summer were gulls (Larus spp.), scoters (Melanitta spp.), and harlequin ducks 

(Histrionicus histrionicus) (Hodges et al. 2008). The most abundant species during 

winter were goldeneyes (Bucephala islandica and B. clangula), gulls, mallards (Anas 

platyrhynchos), scoters, harlequin ducks, buffleheads (Bucephala albeola), and 

mergansers (Mergus spp.). Any of these species may occur in the nearshore waters in the 

vicinity of the mine. Protection of these species is afforded under the Forest Plan 

standards and guidelines for waterfowl and shorebird habitats (Forest Service 2008b). 

The 2003 EIS does not specifically address impacts to waterfowl or shorebirds; however, 

the 1983 EIS concluded that construction and operation of the mine would have no 

substantial direct or indirect effects to these species (Forest Service 1983). These species 

could be impacted if expansion of the mine creates new habitats (i.e., new ponds) that 

attract them or removes or disturbs existing habitat, particularly during the breeding 

season. 

Marine Mammals 

Nine marine mammal species occur in or near Hawk Inlet, Young Bay, and Stephens 

Passage: Steller sea lion, northern sea otter, harbor seal, killer whale, gray whale, 

humpback whale, minke whale, harbor porpoise, and Dall’s porpoise. Of these the 

Steller sea lion and humpback whale are listed under the ESA. These species are 

discussed in Section 3.12.2, Threatened, Endangered, Candidate, and Forest Service 

Alaska Region Sensitive Species and Rare Plants – Baseline Conditions. 

Harbor seals are the most common marine mammal in the inside waters of southeast 

Alaska. Small groups frequently haul out at Hawk Point, approximately one mile from 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-163 

the Greens Creek Delta (USFWS 2003b). Harbor seals are also commonly seen foraging 

inside the inlet when salmon are running in Greens Creek and Zinc Creek; however they 

also feed on other species including cod, crab, and shrimp. The 2003 EIS concluded that 

harbor seals are unlikely to be near the Outfall 002 discharge site, with the exception of 

approximately two hours per day during slack tide. Killer whales are observed in Hawk 

Inlet and at Hawk Point in the vicinity of the harbor seal haul out (USFWS 2003b). 

Harbor and Dall’s porpoises occur in Chatham Strait and have been observed 

occasionally in the inlet where they may forage. Gray whales and minke whales occur in 

Chatham Strait but have not been observed in Hawk Inlet. The shallow sill at the mouth 

of Greens Creek may preclude larger marine mammals found elsewhere in Chatham 

Strait and Stephens Passage from using Hawk Inlet (Forest Service 1983). Threats to 

these species include entanglements in fishing gear, ship strikes, and coastal habitat 

pollution. The Forest Plan standards and guidelines for marine mammals provide for the 

protection and maintenance of harbor seal, Steller sea lion, and sea otter habitats 

including guidelines for approaching marine mammals and minimizing disturbance in the 

vicinity of rookeries and haul outs (Forest Service 2008b). 

Endemic Mammals 

The federal ESA defines endemic as “a species native and confined to a certain region; 

having comparatively restricted distribution.” Forest Plan standards and guidelines for 

endemic mammals direct the Forest to “maintain habitat to support viable populations 

and improve knowledge of habitat relationships of rare or endemic terrestrial mammals 

that may represent unique populations with restricted ranges.” Likewise, the National 

Forest Management Act directs that management prescriptions “shall preserve and 

enhance the diversity of plant and animal communities, including endemic(s).” 

In the Alexander Archipelago, many species are endemic to an island or a group of 

islands. The following species are endemic and occur on Admiralty Island (ISLES 

2009): 

 Admiralty Island beaver (Castor Canadensis phaeus): endemic to Admiralty Island; 

occurs in lakes, rivers, streams, and adjacent riparian habitats; 

 Coastal marten (discussed above): endemic to Admiralty and Kuiu islands; 

 Admiralty Island meadow vole (Microtus pennsylvanicus admiraltiae): endemic to 

Admiralty Island and meadow habitats; 

 Admiralty Island ermine (Mustela erminea salva): endemic to Admiralty Island; 

occurs in a wide range of habitats, but its distribution depends on small mammal 

abundance; 

 Alexander Archipelago mink (Mustela vison): endemic to Admiralty Island; 

associated with coastal marine, nearshore, and freshwater habitats; and 

 Insular dusky shrew (Sorex monticolus elassondon): restricted to the Alexander 

Archipelago and Haida Gwaii; forest, shrub, and meadow habitats. 

There remain many uncertainties about the extent of endemism in southeast Alaska 

because research to date has primarily focused on mammals. Due to their restricted 

ranges, specific habitat requirements, and sensitivity to human activity, endemics are 

extremely susceptible to extinction (Dawson et al. 2007). 

Mink are frequently observed in the drainages of Greens and Zinc creeks and along the 

shoreline of Hawk Inlet and Young Bay and in the vicinity of the cannery (Forest Service 
Chapter 3. Affected Environment and Environmental Consequences

3-164 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

1983). Beavers are regularly found on most streams and in some ponds in the vicinity of 

the Greens Creek facilities, including Greens Creek and along the A Road (Forest Service 

1983). Currently on Admiralty Island, ADF&G allows unlimited trapping of beaver, 

marten, and mink. 

Migratory Birds 

Executive Order 13186 (Responsibilities of Federal Agencies to Protect Migratory Birds) 

provides for the conservation of migratory birds and their habitats and requires the 

evaluation of the effects of federal actions on migratory birds, with an emphasis on 

species of concern. Birds protected under the MBTA include all common songbirds, 

waterfowl, shorebirds, hawks, owls, eagles, ravens, crows, native doves and pigeons, 

swifts, martins, swallows, and others, including their body parts (e.g., feathers, plumes), 

nests, and eggs. Admiralty Island is part of the Southeastern Biogeographic Region of 

Alaska (BPIF 1999). 

Approximately 236 species of birds occur regularly in Southeast Alaska. Roughly 160 

species are known or suspected to breed in Southeast Alaska (Armstrong 1995). 

Migratory birds that occur, but generally only winter in or migrate through Southeast 

Alaska, include species of seabirds, gulls, and shorebirds. Priority breeding landbird 

species identified in the Partners in Flight Landbird Conservation Plan (BPIF 1999, BPIF 

2011) are listed in Table 3.11-1. Of these 20 species, 14 species use 

hemlock/spruce/cedar forest as primary habitat for known or probable breeding (Table 

3.11-1); the remaining 5 use this forest as secondary habitat. Marbled murrelets, bald 

eagles, and goshawks are also protected by the MBTA but addressed separately above or 

in Section 3.12.2, Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants – Baseline Conditions. 

An MOU was entered into between the Forest Service and the USFWS to strengthen 

migratory bird conservation (Forest Service 2008b). The MOU identifies strategies that 

promote conservation to avoid or minimize adverse impacts on migratory birds through 

enhanced collaboration between the Forest Service and USFWS and in coordination with 

State of Alaska, Tribal, and local governments. The MOU requires that the Forest 

Service, within the NEPA process, evaluate the effects of agency actions on migratory 

birds, focusing first on species of management concern along with their priority habitat 

and key risk factors. This includes, to the extent practicable, evaluating and balancing 

the long-term benefits of projects against short- and long-term adverse effects, pursuing 

opportunities to restore or enhance habitat, and considering approaches to identify and 

minimize take. 

The main management issue for migratory birds in the southeastern Alaska 

Biogeographic Region is the harvest of coniferous forests, much of which has been highvolume, low-elevation forest. Timber harvest directly removes habitat and results in 

habitat fragmentation, which may reduce the suitability of remaining forest for species 

associated with interior forest conditions. Deciduous riparian forests are also important 

for many species. This habitat has been altered by road construction, mining, and other 

human activities. Many migratory bird species are likely to nest in the vicinity of the 

project area in forested, riparian, and coastal habitats. Protection under the Forest Plan is 

provided by beach fringe and riparian buffers and standards and guidelines for waterfowl, 

shorebirds, and reserve tree/cavity-nesting species. 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-165 

3.11.3 Wildlife – Environmental Consequences 

Impacts to wildlife are addressed in terms of acres of habitat disturbed, duration of 

impacts, and proximity of proposed activities in relation to important habitat or areas of 

concentrated use by various wildlife species. 

3.11.3.1 Effects Common to All Alternatives 

Under all alternatives, there would be some level of continued human activity occurring 

at the existing TDF, mine site, marine facility, outfall location, and along the B Road. 

Thus, the potential for direct mortality and disturbance of wildlife associated with 

ongoing operation and closure of the TDF would continue through the term of the lease. 

The large barges and ships that are used to haul the concentrate from the mine on a 

regular basis, as well as the crew shuttle transiting Young Bay are not likely to affect 

marine mammal distribution in Hawk Inlet, Young Bay, or Chatham Strait. The large 

barges and ships that transport the concentrate from the mine on a regular basis typically 

operate at low, constant speed and infrequent intervals. The crew shuttle, however, 

transits Stephens Passage with two daily roundtrips. Although the crew shuttle operates 

at a higher speed than the larger vessels, the shuttles follow a regular course. All projectrelated vessels operate in compliance with the MMPA, ESA, and NMFS guidelines for 

speed and approaching marine mammals and stay at least 100 yards from any marine 

mammal, which reduces the likelihood of disturbance and collisions. 

Under all alternatives, oil or fuel spills could occur from vessels at the marine terminal or 

at the dock in Young Bay. Spills could adversely impact marine mammal, waterfowl, 

and shorebird species foraging or moving through the shallow shoreline areas, 

particularly at the head of the inlet. Spill control plans and rapid response to spills would 

be the primary mitigation measures to avoid or minimize adverse spill effects to wildlife 

species in the marine environment. 

Surface water runoff from the TDF(s) would continue to be collected, treated, and 

discharged into Hawk Inlet under all alternatives. As described in more detail in 

Section 3.7, Aquatic Resources, discharge would continue to be required to meet Alaska 

WQS under all alternatives, thereby minimizing impacts to wildlife species in the marine 

environment. However, some heavy metals accumulation in marine sediments is 

anticipated. Bioaccumulation of these metals in higher trophic level marine mammals or 

birds has the potential to occur through transfer of metals from prey items though such 

impacts are unlikely due to the transient nature of these species in Hawk Inlet. The 

amount of discharge would remain consistent during operation, but at closure, with the 

suspension of mining activities, the volume of water treated and discharged would 

appreciably decrease, thereby reducing total metals loading from the discharge to the 

marine environment. Therefore, while the mine operates, the longer this slight risk exists 

(Forest Service 2003). 

Under all alternatives the potential effects of fugitive dust produced by TDF operation 

and closure activities would continue to some extent. Wildlife species can be adversely 

affected by fugitive dust if they become exposed to the contaminants (heavy metals) 

within it, which can cause effects ranging from acute to chronic including neurotoxic, 

carcinogenic, or reproductive effects (AMAP 2005). Dust particles may be transported 

into the environment by wind and deposited onto various habitats (vegetation, streams, 

and waterbodies). These particles, present on plants in the form of dust or metabolized 
Chapter 3. Affected Environment and Environmental Consequences

3-166 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

into tissue and enter the food chain when eaten by animals. The Tongass National Forest 

air quality biomonitoring program would continue to provide information about air 

quality in the vicinity of the mine. Currently, dust abatement measures to prevent wind 

erosion of the TDF include hydroseeding on undisturbed areas of the TDF and 

installation of wind breaks. Section 3.2 describes additional mitigation measures for 

fugitive dust. 

Under all alternatives interim and permanent revegetation measures would be employed 

in accordance with the mine reclamation plan (Appendix 14 of the GPO). This plan 

includes interim hydroseeding to establish an initial grass/forb cover. Upon final 

cessation of mining activities, disturbed areas would be revegetated to encourage a return 

to near-natural conditions consistent with Forest Plan standards and to maintain the 

character of the Monument. Revegetation would include a combination of natural 

regeneration and reseeding or transplanting. Natural regeneration is favored because it 

would allow the reestablishment of Admiralty Island genotype species, follow natural 

successional stages, and thus provide unique wildlife habitat during forest stand 

development. Monitoring would be conducted to ensure successful reestablishment of 

native coastal forest vegetation. Once established, vegetation would improve habitat 

quality for wildlife species using the mine site. 

Under all alternatives, some level of potential habitat for migratory birds could be 

impacted. Direct effects to migratory birds could result from disturbances that adversely 

affect individuals or young, including removing active bird nests or causing nest 

abandonment. Since some of these species are year-round residents, mine activities could 

also disturb and displace birds during the non-breeding season. Indirect effects result 

from the reduction of perching, foraging, and potential nesting habitat. Most of the 

migratory bird species would be affected by a reduction in POG. The magnitude of the 

effects would vary depending on the bird species, the amount of clearing proposed, and 

the season in which disturbance occurs. Migratory birds would be most susceptible to 

impacts from disturbance activities occurring in suitable nesting habitat during the 

nesting/fledging period, which generally begins in mid-April and ends about mid-July, 

when young birds have fledged. The species most likely to be negatively affected are 

those that primarily nest in hemlock/Sitka spruce/cedar forests: blue grouse, Western 

screech-owl, rufous humming bird, red-breasted sapsucker, Pacific-slope flycatcher, 

Steller’s jay, northwestern crow, chestnut-backed chickadee, golden-crowned kinglet, 

varied thrush, Townsend's warbler, blackpoll warbler, northern goshawk, and marbled 

murrelet. The amount of POG harvest proposed under the alternatives is a measure of the 

extent of potential effects. Effects to birds can be minimized by altering the season of 

activity, retaining snags, maintaining the integrity of breeding sites, considering key 

winter and migration areas, and minimizing pollution or detrimental alteration of habitats. 

The USFWS recommends time periods to avoid vegetation clearing in southeast Alaska 

to minimize impacts to migratory birds: April 15 to July 15 for forests and woodlands; 

May 1 through July 15 for shrub, march, pond, tundra, gravel, or other open habitats; 

May 1 to September 15 at seabird colonies; and April 10 to August 10 at raptor and raven 

cliffs (USDI 2006). 

Although these impacts are common to all alternatives, the duration of effects differs by 

alternative. Operation of the mine would continue until 2019 under Alternative A. 

However, all of the action alternatives would extend the operating period of the mine for 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-167 

an additional 30 to 50 years. Therefore, reclamation of the mine site and reductions in 

levels of human activity, water quality impacts, and fugitive dust emissions would occur 

more quickly under Alternative A than the action alternatives. 

3.11.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. The TDF would 

continue to be built out to the maximum footprint and height permitted in the 2003 EIS 

(Forest Service 2003). Much of this area has already been disturbed by ongoing mine 

operations, no additional vegetation (habitat) removal would occur that has not already 

been approved. After the TDF was fully built out in 2019, reclamation would begin as 

described in the 2003 EIS (Forest Service 2003). 

Management Indicator Species 

Brown Bear 

Under Alternative A there would be no decrease in brown bear buffers or additional 

disturbance near Class I salmon streams, because all development under this alternative 

would occur within the existing lease area. Therefore, Alternative A would not be 

expected to result in any additional habitat loss for brown bears or displace brown bears 

from the vicinity of the mine. Under Alternative A, diversion of flows would continue to 

slightly reduce spawning and rearing habitats and ultimately anadromous fish production 

in Tributary Creek. However, these impacts would be similar to current conditions, and 

no direct loss of stream habitat, and thus fish production, would occur under this 

alternative. Therefore, effects to brown bear food sources would be minor under 

Alternative A. 

Bald Eagle 

No bald eagle nests would be directly affected by implementing Alternative A. The 

project would adhere to the 660-foot management zone around eagle nest sites. 

Disturbance activities within this zone are restricted during the nesting season (March 1 

to May 31 and extending to August 31, if a nest is occupied). Water quality impacts 

potentially affecting bald eagle prey resources in the marine environment are not 

anticipated due to the continued treatment of contact water prior to discharge into Hawk 

Inlet and implementation of spill control/rapid response measures in the event of an oil or 

fuel spill (see Section 3.7.3.3). 

Black-tailed Deer 

The 2003 EIS concluded that the existing TDF provides low quality habitat for deer. 

Under Alternative A there would be no additional impact to black-tailed deer habitat. 

The existing levels of road use would continue under Alternative A, and therefore the risk 

of road kill of deer would also continue. Indirect impacts to the species’ local 

distribution and use of habitat in the vicinity of the mine may occur as a result of past and 

ongoing activity but would end once activities in the area cease. 

Marten 

Marten could occur in the forested areas in the vicinity of the mine and thus could be 

impacted by the removal of POG. No additional removal of POG would occur under 
Chapter 3. Affected Environment and Environmental Consequences

3-168 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Alternative A. Therefore, habitat loss would be expected to result in negligible impacts 

to this species as a result of existing development in areas that have already been 

disturbed. 

Vancouver Canada Goose 

A minor amount of wetland habitat has been disturbed in association with previously 

approved mining activity (Forest Service 2003). Wetland habitat exists adjacent to the 

existing TDF; however, no additional wetland impacts would occur under Alternative A. 

No shoreline or estuary habitat would be impacted by Alternative A. Although continued 

use of the TDF could disturb geese using the adjacent areas, Alternative A would have 

negligible effects to the Vancouver Canada goose. 

River Otter 

Potential impacts to river otter could occur if any project activities involve removal of 

old-growth forest along streams or in the beach buffer; loss of stream channel habitat; or 

adverse effects to water quality. Alternative A would not result in the removal of oldgrowth forest along streams, loss of stream channel habitat (through direct burial), nor 

would it increase existing impacts to water quality (see Section 3.7, Aquatic Resources). 

Therefore, Alternative A would not impact river otters. 

Red Squirrel 

No additional removal of POG would occur under Alternative A. Therefore, no 

additional impacts to this species are expected as a result of Alternative A. 

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper 

The red-breasted sapsucker, hairy woodpecker, and brown creeper could occur in the 

forested areas in the vicinity of the mine. No additional productive old-growth would be 

impacted by Alternative A. Therefore, no additional impacts to this species are expected 

as a result of Alternative A. 

Other Species of Concern 

Marbled Murrelet 

No additional forested habitat would be lost under Alternative A. It is unlikely that 

marbled murrelets use the forest in the current TDF area regularly for nesting due to the 

lack of structural attributes preferred by marbled murrelets (Forest Service 2003). 

However, one murrelet was observed flying over the existing TDF during 2010 wildlife 

surveys. Additionally, water quality impacts potentially affecting marbled murrelet prey 

resources in the marine environment are not anticipated due to the continued treatment of 

contact water discharged into Hawk Inlet and implementation of spill prevention and 

control measures (see Section 3.7.3.3). 

Waterfowl and Shorebirds 

Regional waterbird and shorebird distribution and abundance would not be affected by 

implementing Alternative A because no new disturbances would be authorized and 

ongoing mine-related activity would be limited to the vicinity of Tributary Creek. Most 

waterbird nesting activity in the study area appears to be associated with habitats within 

Hawk Inlet, with areas of concentrated use in the shallows at the head of the inlet and 

across the inlet at Hawk Point, away from project activity. Barge and crew shuttle traffic 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-169 

could disrupt flocks of waterbirds congregating in Hawk Inlet though there would be no 

change in the existing level of vessel activity. Water quality impacts potentially affecting 

waterfowl and shorebirds in the marine environment are not anticipated due to the 

treatment of contact water prior to discharge into Hawk Inlet and implementation of spill 

control/rapid response measures in the event of an oil or fuel spill (see Section 3.7.3.1). 

Marine Mammals 

Under Alternative A, exposure of marine mammals in Hawk Inlet and Young Bay to 

disturbance and noise associated with the marine terminal, barge and crew shuttle traffic, 

and the potential for fuel or oil spills would be unchanged from current operations until 

mining was completed in 2019. Given that mine operations would cease in 2019, these 

low-potential impacts would not occur over the long term. Marine mammals are transient 

within Hawk Inlet, therefore, the likelihood for bioaccumulation of metals due to the 

consumption of contaminated prey would remain extremely low. 

Endemic Species 

Endemic species occupy restricted ranges and therefore are especially susceptible to 

activities that result in habitat loss or fragmentation. Alternative A would not result in 

the authorization of any new disturbance. Additionally, existing beach buffers and 

riparian buffers in the vicinity of the mine would continue to provide habitat for these 

species. Therefore, Alternative A would result in negligible effects to endemic species. 

Migratory Birds 

There would be no additional impacts to migratory birds beyond those discussed in 

Section 3.11.3.1, Effects Common to All Alternatives. 

3.11.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. 

Alternative B includes previously permitted habitat change that would occur under 

Alternative A plus the disturbance of approximately 73 acres of productive old-growth, 

and 55 acres of unproductive forest. The TDF under this alternative would occur 

adjacent to the previously approved TDF, and would primarily be concentrated within the 

Tributary Creek area. Alternative B would extend the operating period of the mine by 

30–50 years and therefore impacts associated with habitat loss or disturbance would 

occur over the long term. 

Management Indicator Species 

Brown Bear 

Brown bears foraging along the lower reaches of Tributary Creek could occur in the 

vicinity of the proposed TDF expansion. Approximately 30 acres of forest within 500 

feet of Tributary Creek (the brown bear foraging buffer) would be newly impacted by 

Alternative B. Bears in this area would likely be at least temporarily displaced during 

initial construction of the TDF expansion. The presence of bears at the existing TDF area 

indicates that bears would be expected to habituate to the disturbance once construction is 

complete. However, this also means that there is increased potential for human-bear 

conflicts. 
Chapter 3. Affected Environment and Environmental Consequences

3-170 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Additionally, Alternative B would result in reductions in stream flow to Tributary Creek 

associated with expansion of the TDF (see sections 3.5.3.3 and 3.7.2 for additional 

discussion). This area provides rearing habitat for coho, and to a limited extent, 

spawning habitat for coho, chum, and pink salmon. Thus, reduced stream flow under 

Alternative B has the potential to reduce anadromous fish production, which provides an 

important food source for brown bears. It is anticipated that the reduction in anadromous 

fish production resulting from Alternative B would occur gradually over 30–50 years, 

and impacts would be long-term. To mitigate for the loss of salmon rearing and 

spawning habitat in Tributary Creek, HGCMC would repair the damaged, fish passage on 

Greens Creek. While increasing anadromous habitat on Greens Creek would indirectly 

benefit bears that feed on salmon, the loss of habitat in the Tributary Creek drainage 

would not be fully replaced. 

Bald Eagle 

Bald eagles could be affected by noise associated with the TDF expansion and ongoing 

operation of the mine. There are three bald eagle nest sites within one-half mile of the 

existing TDF, all of which were inactive in 2011. However, these nest sites and bald 

eagles using the general area are already exposed to an existing level of human 

disturbance. If nests in this area are found to be active prior to construction, including 

new nests established after 2011, the project would adhere to National Bald Eagle 

Management Guidelines, which include maintaining a 660-foot management zone around 

eagle nest sites (USFWS 2007). Disturbance activities within this zone are restricted 

during the nesting season (March 1 to May 31 and extending to August 31, if the nest is 

occupied). With continued operation for another 30–50 years, the chance of accidental 

spills to the marine environment and other water quality impacts associated with TDF 

discharge would continue. However, water quality impacts potentially affecting bald 

eagle prey resources in the marine environment are not anticipated under Alternative B 

due to the continued treatment of contact water prior to discharge into Hawk Inlet and 

implementation of spill control/rapid response measures in the event of an oil or fuel spill 

(see Section 3.7.3.3). Therefore, no adverse impacts to nesting bald eagles would occur 

under Alternative B. 

Black-tailed Deer 

Approximately 24 acres of deer winter range in WAA 3836 and 104 acres of deer winter 

range in WAA 3837 would be removed under Alternative B. This equates to less than 

1 percent of the existing winter range in these WAAs. Indirect impacts to the species’ 

local distribution and use of habitat in the vicinity of the mine could occur during 

construction, but given the frequency with which deer are observed in vicinity of the 

mine it is anticipated that they would return to the area, especially when short-term 

reclamation activities are implemented that result in new vegetation growth. Because the 

surrounding area provides winter range for deer and because the reduction in habitat loss 

would occur gradually over the extended operation period, Alternative B would not 

preclude deer from wintering in WAA 3836 or 3837. The existing levels of road use, and 

therefore the potential for road kill of deer, would occur under Alternative B but would 

be extended over the longer operating period.
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-171 

Marten 

Alternative B would result in the removal of 73 acres of productive old-growth 

(Table 3.11-3). Marten using this area could be displaced to areas where forest cover is 

maintained, but impacts would be localized. Therefore, no population level impacts 

would occur under Alternative B. 

Table 3.11-3. Existing and Estimated Productive Old Growth that would be Removed 

under Each Action Alternative within the Study Area. 

POG by SDM 

Class 

Existing 

(acres) 

Percent 

POG 

Action Alternatives 

Alternative 

B (acres) 

Mitigated 

Alternative B 

(acres) 

Alternative 

C (acres) 

Alternative 

D (acres) 

SD-4H 608 25% 31 22 53 46 

SD-4N 121 5% 9 9 0 1 

SD-4S 421 17% 3 3 0 1 

SD-5H 265 11% 0 3 31 30 

SD-5N 139 6% 0 1 0 1 

SD-5S 307 13% 0 0 7 7 

SD-6/7 565 23% 30 26 23 29 

Total POG (Acres) 2,426 100% 73 64 114 115 

Vancouver Canada Goose 

Potential impacts from Alternative B on Vancouver Canada geese would be associated 

primarily with disturbance from daily crew shuttle traffic in Young Bay and periodic 

barge traffic in Hawk Inlet, which would occur at existing levels but would be extended 

by 30–50 years. However, geese using these areas are already exposed to vessel activity 

and therefore would be expected to continue using the inlet during the operating period. 

Alternative B would remove 85 acres of wetland habitat, located within the Tributary 

Creek drainage, which could be used for nesting by this species (compared to more than 

3,000 acres in the wetland study area; see Table 3.8-1). This habitat loss would be 

expected to result in minor local impacts to this species, and would not be expected to 

affect populations given the amount of remaining available habitat. 

River Otter 

Alternative B would impact forested habitats within the Tributary Creek drainage. Otters 

using this area would be displaced from the immediate area of the tailings expansion site 

over the long term until forests were reestablished following mine closure. Additionally, 

approximately 4,000 feet of Class I and II streams would be directly lost due to TDF 

expansion, though changes would occur gradually over a 30–50 year period (see Section 

3.7.3.3). With continued operation for another 30–50 years, the chance of accidental 

spills to project area creeks (Zinc and Greens creek drainages) would be extended; 

however, water quality impacts potentially affecting river otters are not anticipated under 

Alternative B due to the implementation of spill control/rapid response measures (see 

Section 3.7.3.3). 
Chapter 3. Affected Environment and Environmental Consequences

3-172 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Red Squirrel 

Approximately 73 acres of POG spruce/hemlock forest would be cleared under 

Alternative B. Therefore, habitat loss would be expected to result in minor local impacts 

to this species, but would not be expected to affect populations given the amount of 

remaining available habitat. 

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper 

Approximately 73 acres of productive old-growth habitat would be removed. The 

additional loss of old-growth habitat from construction activities associated with 

expansion of the TDF would result in local habitat fragmentation which could potentially 

disrupt the movements of individual hairy woodpeckers, brown creepers, or red-breasted 

sapsuckers in the immediate vicinity of Tributary Creek. The disturbance/disruption 

would not be expected to affect populations of these species in the study area given the 

remaining available habitat. 

Other Species of Concern 

Marbled Murrelet 

Alternative B would result in the removal of suitable marbled murrelet habitat in addition 

to that which has already occurred under the approved operation. This would primarily 

occur along Tributary Creek for the expansion of the TDF. This includes approximately 

30 acres of coarse canopy structure (SD67 category; Table 3.11-3). Given that a murrelet 

was observed during 2010 wildlife surveys, it is recommended that dawn watch surveys 

be conducted prior to the commencement of any disturbance activities to confirm that 

murrelets are not actively nesting in or adjacent to the proposed tailings expansion area. 

If nesting murrelets were present at the time of construction, a 600-foot buffer of 

undisturbed forest would be maintained, where available, in accordance with Forest Plan 

Standards and Guidelines. Construction activities, if they coincide with this buffer, 

would be timed to occur outside of the nesting season (May 1 to August 15), to avoid 

disturbance to nesting murrelets. With continued operation for another 30–50 years, the 

chance of accidental spills to the marine environment and other water quality impacts 

associated with TDF discharge would continue. However, water quality impacts 

potentially affecting marbled murrelet prey resources in the marine environment are not 

anticipated under Alternative B due to the continued treatment of contact water prior to 

discharge into Hawk Inlet and implementation of spill control/rapid response measures in 

the event of an oil or fuel spill (see Section 3.7.3.3). With mitigation measures in place, 

Alternative B would have minor effects on the marbled murrelet. 

Waterfowl and Shorebirds 

Alternative B would not impact any waterfowl or shorebird concentrations areas. The 

extension of the operating period under Alternative B would extend time during which 

vessel activity associated with the mine would occur in Hawk Inlet and crew shuttle 

traffic in Young Bay, and thus it would be a potential source of disturbance to waterfowl 

and shorebirds at Hawk Point or in the vicinity of the marine terminal. However, because 

waterfowl are exposed to an existing level of human activity, extending the operating 

period of the mine would not be expected to appreciably increase the current level of 

human activity. With continued operation for another 30–50 years, the chance of 

accidental spills to the marine environment and other water quality impacts associated 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-173 

with TDF discharge would continue. However, water quality impacts potentially 

affecting waterfowl and shorebirds are not anticipated under Alternative B due to the 

continued treatment of contact water prior to discharge into Hawk Inlet and 

implementation of spill control/rapid response measures in the event of an oil or fuel spill 

(see Section 3.7.3.3). 

Marine Mammals 

Effects to marine mammals would be the same as under Alternative A though for an 

additional 30–50 years. Given that the operation period is longer than currently 

permitted, Alternative B would extend the time during which marine mammals could be 

exposed to metal concentrations in prey due to project-related discharges into Hawk Inlet, 

oil or fuel spills, and vessel/crew shuttle traffic. However, given the transient nature of 

these species in Hawk Inlet and Young Bay, Alternative B would result in minor impacts 

to these species. Additional information is provided for marine mammals listed as 

threatened or endangered in Section 3.12 and in the biological assessment (BA). 

Endemic Species 

Alternative B would result in a minor increase in habitat fragmentation resulting from the 

total disturbance of approximately 128 acres of vegetation adjacent to the existing TDF. 

Displacement from the project area or alterations in movement patterns resulting from 

human activity or habitat removal would be anticipated for small endemic mammals with 

limited movement capabilities in the immediate vicinity of the TDF expansion area under 

Alternative B. Existing beach buffers and riparian buffers in the vicinity of the mine 

would continue to provide habitat for these species. Given the availability of surrounding 

habitat, Alternative B would not be expected to result in the extirpation of any endemic 

species. 

Migratory Birds 

Alternative B would impact approximately 73 acres of productive and 55 acres of 

unproductive spruce/hemlock forest potentially used by priority migratory bird species. 

Initial clearing activities at the TDF expansion site have the potential to destroy nests or 

cause nest abandonment if the activities occur in suitable nesting habitat during the 

breeding/nesting period. Nesting typically begins in mid-April and ends about mid-July, 

when young birds have fledged, after which time nesting activities would not be directly 

affected. To reduce the potential for impacts to nesting migratory birds, ground 

disturbing activities and tree clearing should be conducted outside the nesting season in 

the region (late May through early July); see USFWS timing recommendations in Section 

3.11.3.1. Effects would be considered minor due to the amount of overall clearing and 

low potential for population-level impacts to migratory birds; surrounding habitat would 

remain functional and could maintain the species. 

3.11.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 
Chapter 3. Affected Environment and Environmental Consequences

3-174 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Under 

Mitigated Alternative B, facilities moved to the northern portion of the existing TDF 

would have similar impacts associated with habitat loss or disturbance. However, overall 

disturbance would be less than Alternative B (approximately 64 and 62 acres of 

productive and unproductive forest impacted, respectively). 

Management Indicator Species 

Brown Bear 

Brown bears foraging along the lower reaches of Tributary Creek could occur in the 

vicinity of the proposed TDF expansion. Approximately 29 acres of forest within 500 

feet of Tributary Creek (the brown bear foraging buffer) would be newly impacted by 

Mitigated Alternative B. Bears in this area would likely be at least temporarily displaced 

during initial construction of the TDF expansion. The presence of bears at the existing 

TDF area indicates that bears would be expected to habituate to the disturbance once 

construction is complete. However, this also means that there is increased potential for 

human-bear conflicts. 

Similar to the proposed action, Mitigated Alternative B would result in reductions in 

stream flow to Tributary Creek associated with expansion of the TDF (see sections 

3.5.3.3 and 3.7.2 for additional discussion). This area provides rearing habitat for coho, 

and to a limited extent, spawning habitat for coho, chum, and pink salmon. Thus, 

reduced stream flow under Alternative B has the potential to reduce anadromous fish 

production, which provides an important food source for brown bears. It is anticipated 

that the reduction in anadromous fish production resulting from Alternative B would 

occur gradually over 30–50 years, and impacts would be long term. To mitigate for the 

loss of salmon rearing and spawning habitat in Tributary Creek, HGCMC would repair 

the damaged, fish passage on Greens Creek. While increasing anadromous habitat on 

Greens Creek would indirectly benefit bears that feed on salmon, the loss of habitat in the 

Tributary Creek drainage would not be fully replaced. 

Bald Eagle 

Bald eagles could be affected by noise associated with the TDF expansion and ongoing 

operation of the mine. There are three bald eagle nest sites within one-half mile of the 

existing TDF, all of which were inactive in 2011. However, these nest sites and bald 

eagles using the general area are already exposed to an existing level of human 

disturbance. If nests in this area are found to be active prior to construction, including 

new nests established after 2011, the project would adhere to National Bald Eagle 

Management Guidelines, which include maintaining a 660-foot management zone around 

eagle nest sites (USFWS 2007). Disturbance activities within this zone are restricted 

during the nesting season (March 1 to May 31 and extending to August 31, if the nest is 

occupied). With continued operation for another 30–50 years, the chance of accidental 

spills to the marine environment and other water quality impacts associated with TDF 

discharge would continue. However, water quality impacts potentially affecting bald 

eagle prey resources in the marine environment are not anticipated under Mitigated 

Alternative B due to the continued treatment of contact water prior to discharge into 

Hawk Inlet and implementation of spill control/rapid response measures in the event of 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-175 

an oil or fuel spill (see Section 3.7.3.3). Therefore, no adverse impacts to nesting bald 

eagles would occur under Mitigated Alternative B. 

Black-tailed Deer 

Approximately 42 acres of deer winter range in WAA 3836 and 83 acres of deer winter 

range in WAA 3837 would be removed under Mitigated Alternative B. This equates to 

less than 1 percent of the existing winter range in these WAAs. Indirect impacts to the 

species’ local distribution and use of habitat in the vicinity of the mine could occur 

during construction, but given the frequency with which deer are observed in vicinity of 

the mine it is anticipated that they would return to the area, especially when short-term 

reclamation activities are implemented that result in new vegetation growth. Because the 

surrounding area provides winter range for deer and because the reduction in habitat loss 

would occur gradually over the extended operation period, Mitigated Alternative B would 

not preclude deer from wintering in WAA 3836 or 3837. The existing levels of road use, 

and therefore the potential for road kill of deer, would occur under Mitigated Alternative 

B but would be extended over the longer operating period.

Marten 

Mitigated Alternative B would result in the removal of 64 acres of productive old-growth 

(Table 3.11-3). Marten using this area could be displaced to areas where forest cover is 

maintained, but impacts would be localized. Therefore, no population level impacts 

would occur under Mitigated Alternative B. 

Vancouver Canada Goose 

Potential impacts from Mitigated Alternative B on Vancouver Canada geese would be 

associated primarily with disturbance from daily crew shuttle traffic in Young Bay and 

periodic barge traffic in Hawk Inlet, which would occur at existing levels but would be 

extended by 30–50 years. However, geese using these areas are already exposed to 

vessel activity and therefore would be expected to continue using the inlet during the 

operating period. Mitigated Alternative B would remove 77 acres of wetland habitat, 

located within the Tributary Creek and Cannery Creek drainages, which could be used for 

nesting by this species (compared to more than 3,000 acres in the wetland study area; see 

Table 3.8-1). This habitat loss would be expected to result in minor local impacts to this 

species, and would not be expected to affect populations given the amount of remaining 

available habitat. 

River Otter 

Mitigated Alternative B would impact forested habitats within the Tributary Creek 

drainage. Otters using this area would be displaced from the immediate area of the 

tailings expansion site over the long term until forests were reestablished following mine 

closure. Additionally, approximately 2,800 feet of Class I and II streams would be 

directly lost due to TDF expansion, though changes would occur gradually over a 30–50 

year period (see Section 3.7.3.3). With continued operation for another 30–50 years, the 

chance of accidental spills to project area creeks (Zinc and Greens creek drainages) 

would be extended; however, water quality impacts potentially affecting river otters are 

not anticipated under Mitigated Alternative B due to the implementation of spill 

control/rapid response measures (see Section 3.7.3.3). 
Chapter 3. Affected Environment and Environmental Consequences

3-176 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Red Squirrel 

Approximately 64 acres of POG spruce/hemlock forest would be cleared under Mitigated 

Alternative B. Therefore, habitat loss would be expected to result in minor local impacts 

to this species, but would not be expected to affect populations given the amount of 

remaining available habitat. 

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper 

Approximately 64 acres of productive old-growth habitat would be removed. The 

additional loss of old-growth habitat from construction activities associated with 

expansion of the TDF would result in local habitat fragmentation which could potentially 

disrupt the movements of individual hairy woodpeckers, brown creepers, or red-breasted 

sapsuckers in the immediate vicinity of Tributary Creek. The disturbance/disruption 

would not be expected to affect populations of these species in the study area given the 

remaining available habitat. 

Other Species of Concern 

Marbled Murrelet 

Mitigated Alternative B would result in the removal of suitable marbled murrelet habitat 

in addition to that which has already occurred under the approved operation. This would 

primarily occur along Tributary Creek for the expansion of the TDF. This includes 

approximately 26 acres of coarse canopy structure (SD67 category; Table 3.11-3). Given 

that a murrelet was observed during 2010 wildlife surveys, it is recommended that dawn 

watch surveys be conducted prior to the commencement of any disturbance activities to 

confirm that murrelets are not actively nesting in or adjacent to the proposed tailings 

expansion area. If nesting murrelets were present at the time of construction, a 600-foot 

buffer of undisturbed forest would be maintained, where available, in accordance with 

Forest Plan Standards and Guidelines. Construction activities, if they coincide with this 

buffer, would be timed to occur outside of the nesting season (May 1 to August 15), to 

avoid disturbance to nesting murrelets. With continued operation for another 30–50 

years, the chance of accidental spills to the marine environment and other water quality 

impacts associated with TDF discharge would continue. However, water quality impacts 

potentially affecting marbled murrelet prey resources in the marine environment are not 

anticipated under Mitigated Alternative B due to the continued treatment of contact water 

prior to discharge into Hawk Inlet and implementation of spill control/rapid response 

measures in the event of an oil or fuel spill (see Section 3.7.3.3). Mitigated Alternative B 

would have minor effects on the marbled murrelet. 

Waterfowl and Shorebirds 

Mitigated Alternative B would not impact any waterfowl or shorebird concentrations 

areas. The extension of the operating period under Mitigated Alternative B would extend 

time during which vessel activity associated with the mine would occur in Hawk Inlet 

and crew shuttle traffic in Young Bay, and thus it would be a potential source of 

disturbance to waterfowl and shorebirds at Hawk Point or in the vicinity of the marine 

terminal. However, because waterfowl are exposed to an existing level of human 

activity, extending the operating period of the mine would not be expected to appreciably 

increase the current level of human activity. With continued operation for another 30–50 

years, the chance of accidental spills to the marine environment and other water quality 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-177 

impacts associated with TDF discharge would continue. However, water quality impacts 

potentially affecting waterfowl and shorebirds are not anticipated under Mitigated 

Alternative B due to the continued treatment of contact water prior to discharge into 

Hawk Inlet and implementation of spill control/rapid response measures in the event of 

an oil or fuel spill (see Section 3.7.3.3). 

Marine Mammals 

Effects to marine mammals would be the same as under Alternative A though for an 

additional 30–50 years. Given that the operation period is longer than currently 

permitted, Mitigated Alternative B would extend the time during which marine mammals 

could be exposed to metal concentrations in prey due to project-related discharges into 

Hawk Inlet, oil or fuel spills, and vessel/crew shuttle traffic. However, given the 

transient nature of these species in Hawk Inlet and Young Bay, Mitigated Alternative B 

would result in minor impacts to these species. Additional information is provided for 

marine mammals listed as threatened or endangered in Section 3.12 and in the draft BA. 

Endemic Species 

Mitigated Alternative B would result in a minor increase in habitat fragmentation 

resulting from the total disturbance of approximately 126 acres of vegetation adjacent to 

the existing TDF. Displacement from the project area or alterations in movement 

patterns resulting from human activity or habitat removal would be anticipated for small 

endemic mammals with limited movement capabilities in the immediate vicinity of the 

TDF expansion area under Mitigated Alternative B. Existing beach buffers and riparian 

buffers in the vicinity of the mine would continue to provide habitat for these species. 

Given the availability of surrounding habitat, Mitigated Alternative B would not be 

expected to result in the extirpation of any endemic species. 

Migratory Birds 

Mitigated Alternative B would impact approximately 64 acres of productive and 62 acres 

of unproductive spruce/hemlock forest potentially used by priority migratory bird 

species. Initial clearing activities at the TDF expansion site have the potential to destroy 

nests or cause nest abandonment if the activities occur in suitable nesting habitat during 

the breeding/nesting period. Nesting typically begins in mid-April and ends about midJuly, when young birds have fledged, after which time nesting activities would not be 

directly affected. To reduce the potential for impacts to nesting migratory birds, ground 

disturbing activities and tree clearing should be conducted outside the nesting season in 

the region (late May through early July); see USFWS timing recommendations in Section 

3.11.3.1. Effects would be considered minor due to the amount of overall clearing and 

low potential for population-level impacts to migratory birds; surrounding habitat would 

remain functional and could maintain the species.

3.11.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located in a small drainage leading to Hawk Inlet. 

Additionally the B Road would be upgraded and additional facilities including a tailings 

water transport pipeline, rock quarry, water management ponds would be built. 

Alternative C would also extend the operating period of the mine by 30–50 years. Effects 

to wildlife would be more widely spread than in alternatives A and B due to the 
Chapter 3. Affected Environment and Environmental Consequences

3-178 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

development of a new TDF and supporting infrastructure. Activities associated with 

expanding the existing TDF would overlap with construction of the new TDF over the 

short term. After approximately 3 years, reclamation of the existing TDF could begin 

after which most activity would be focused in the vicinity of the new TDF. 

Management Indicator Species 

Brown Bear 

Brown bears foraging along the lower reaches of Tributary Creek could occur in the 

vicinity of the proposed TDF expansion. Approximately 0.5 acre of forest within 500 

feet of Tributary Creek (the brown bear foraging buffer) would be impacted by 

Alternative C. Bears in this area would likely be at least temporarily displaced during 

initial construction of the TDF. The presence of bears at the existing TDF indicates that 

bears would be expected to habituate to the disturbance once construction is complete. 

However, this also means that there is increased potential for human-bear conflicts. Even 

though the TDF to the north proposed under Alternative C does not coincide with a 

brown bear foraging buffer, the potential for increased human-bear conflicts is likely. 

Effects to brown bear food sources along Tributary Creek under Alternative C would be 

the same as under Alternative A. Diversion of flows would continue to slightly reduce 

spawning and rearing habitats and ultimately anadromous fish production in this Class I 

stream. Development of the north TDF under Alternative C would result in the burial of 

approximately 1,040 feet of stream determined to be resident fish bearing (see Section 

3.7.3.5 for additional discussion) and minor reductions in downstream flow. This would 

result in the permanent loss of anadromous fish rearing and spawning habitat, though 

overall stream channel loss would be only a small portion of stream channels within the 

Fowler Creek drainage. Therefore, effects to brown bear food sources would be minor 

under Alternative C. 

Bald Eagle 

Three bald eagle nest sites (all inactive in 2011) occur within one-half mile of the 

existing TDF area. Within the area of the new TDF area proposed under Alternative C, 

there are three nests (two active nests and one inactive nest) located within one-half mile 

of the proposed location; one of the active nests is approximately 900 feet west of the 

proposed quarry site. Nest sites and bald eagles using the area in the vicinity of the 

existing TDF are already exposed to an existing level of human disturbance; however 

those in the vicinity of the new TDF would be exposed to a new source of disturbance. If 

nests in this area are found to be active prior to construction, including new nests 

established after 2011, the project would adhere to National Bald Eagle Management 

Guidelines (USFWS 2007). For mine projects, guidelines include maintaining a 660-foot 

buffer around eagle nest sites (both active and alternate) that are visible from the location 

of mine activity (where no similar activities occur within 660 feet of the nest; a smaller 

buffer is acceptable if similar activities occur within 660 feet). Disturbance activities 

within this zone are restricted during the nesting season (March 1 to May 31, extending to 

August 31 if the nest is occupied). One nest (inactive in 2011) is within 660 feet of the A 

Road, where improvements would occur under Alternative C. All other nests are farther 

than 660 feet from any proposed activity. Implementation of these guidelines would 

reduce disturbance to bald eagles. Effects to the marine environment, and thus to bald 

eagle prey resources, under Alternative C would be the same as under Alternative B 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-179 

because all major project actions related to the marine environment (location, chemical 

concentrations, and amount and timing of discharge) would be essentially the same (see 

Section 3.7.3.5). Therefore, no adverse impacts to nesting bald eagles are anticipated 

under Alternative C. 

Black-tailed Deer 

Approximately 156 acres of deer winter range in WAA 3836 and 18 acres of deer winter 

range in WAA 3837 would be removed under Alternative C in association with 

development of the northern and expansion of the southern tailings expansion areas, 

respectively. This equates to less than 1 percent of the existing winter range in these 

WAAs. Under Alternative C, there would be additional road use associated with hauling 

tailings and thus an increased level of road traffic would be expected. Therefore, there is 

a potential for increased road kill of deer under Alternative C. Indirect impacts to the 

species’ local distribution and use of habitat in the vicinity of the TDF could occur during 

construction, but given the frequency with which deer are observed in the vicinity of the 

mining operations it is anticipated that they would return to the area, especially after 

short-term reclamation activities resulting in new vegetation growth. Because the 

surrounding area provides winter range for deer and the loss of winter range under 

Alternative C would occur gradually over the extended operating period, Alternative C 

would not preclude deer from wintering in WAA 3836 or 3837.

Marten 

Alternative C would result in the removal of 114 acres of productive old-growth 

associated with expansion of the existing TDF and development of the new TDF 

(Table 3.11-3). Marten using this area would be displaced to areas where forest cover is 

maintained, but impacts would be localized. Therefore, no population level impacts 

would occur under Alternative C. 

Vancouver Canada Goose 

As under Alternative B, potential impacts from Alternative C on Vancouver Canada 

geese would be associated primarily with disturbance from daily crew shuttle traffic in 

Young Bay and periodic barge traffic in Hawk Inlet, which would occur at existing levels 

but would be extended by 30–50 years. However, geese using this area are already 

exposed to vessel activity and therefore would be expected to continue using the inlet 

during the operating period. Expansion of the existing TDF under Alternative C would 

remove a total of 112 acres of wetland habitat (compared to more than 3,000 acres in the 

wetland study area; see Table 3.8-1), which could be used for nesting by this species. 

This habitat loss would be expected to result in minor local impacts to this species, and 

would not be expected to affect populations given the amount of remaining available 

habitat. 

River Otter 

Alternative C would impact a small amount of forested habitats along Tributary Creek in 

association with the existing TDF expansion area. Otters using this area would be 

permanently displaced from the immediate area of the tailings expansion site during the 

life of operations and until a mature forest was re-established. No stream habitat would 

be lost along Tributary Creek under Alternative C, although approximately 1,040 feet of 

Class II streams, and thus river otter habitat, would be lost due to development of the new 
Chapter 3. Affected Environment and Environmental Consequences

3-180 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

TDF in the Fowler Creek drainage (Table 3.7-8). These changes would occur gradually 

over a 30–50 year period (see Section 3.7.3.5). With continued mine operation for 

another 30–50 years, as under Alternative B, the chance of accidental spills to project 

area creeks would be extended. Under Alternative C, an additional potential spill risk 

would be the pipeline built to carry runoff from the new TDF to the existing water 

treatment facility, which would contain elevated metals and/or chemicals. Should the 

pipeline break, it could result in spillage entering Fowler Creek. However, water quality 

impacts potentially affecting river otters are not anticipated under Alternative C due to 

the implementation of spill control/rapid response measures (see Section 3.7.3.5). 

Red Squirrel 

Approximately 114 acres of POG spruce/hemlock forest would be cleared under 

Alternative C. Therefore, habitat loss and localized habitat fragmentation would be 

expected to result in minor local impacts to this species, and would not be expected to 

affect populations given the amount of remaining available habitat. 

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper 

Under Alternative C approximately 114 acres of old-growth habitat would be removed in 

association with expansion of the TDF and development of the new TDF. Alternative C 

would result in local habitat fragmentation, which could potentially disrupt the 

movements of individual hairy woodpeckers, brown creepers, or red-breasted sapsuckers 

in forested habitats along Tributary Creek in association with the existing TDF and the 

unnamed tributary of Fowler Creek in association with development of the new TDF, but 

would not be expected to affect populations of these species in the study area given the 

remaining available habitat. 

Other Species of Concern 

Marbled Murrelet 

Alternative C would remove approximately 114 acres of POG in association with the 

expansion of the existing TDF and the development of the new TDF. Of that amount, it 

is estimated that approximately 23 acres of coarse canopy structure (SD67 class) would 

be removed (Table 3.11-3). Surveys of the new TDF area did not document use by 

murrelets. One murrelet was observed flying over the existing TDF. Therefore it is 

recommend that dawn watch surveys be conducted prior to ground disturbing activities to 

ensure that disturbance to birds using the development areas is minimized. If nesting 

murrelets were present at the time of construction, a 600-foot buffer of undisturbed forest 

would be maintained, where available, in accordance with Forest Plan Standards and 

Guidelines. Construction activities, if they coincide with this buffer, would be timed to 

occur outside of the nesting season (May 1 to August 15), to avoid disturbance to nesting 

murrelets. Effects to the marine environment, and thus to marbled murrelet prey 

resources, under Alternative C would be the same as under Alternative B because all 

major project actions related to the marine environment (location, chemical 

concentrations, and amount and timing of discharge) would be essentially the same (see 

Section 3.7.3.5). Therefore, Alternative C would have minor impacts to the marbled 

murrelet. 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-181 

Waterfowl and Shorebirds 

Impacts to waterfowl and shorebirds under Alternative C would be the same as under 

Alternative B. 

Marine Mammals 

Effects to marine mammals under Alternative C would be the same as under 

Alternative B. 

Endemic Species 

Alternative C would increase habitat fragmentation in the vicinity of the existing and new 

TDF areas. The forest gap created by clearing for the northern tailings area would be 

smaller than under Alternative D. Displacement from the project area or alterations in 

movement patterns due to human activity or habitat removal, particularly in a previously 

undisturbed area, would be anticipated for small endemic mammals with limited 

movement capabilities in the immediate vicinity of the TDF expansion area and new TDF 

area under Alternative C. Existing beach buffers and riparian buffers in the vicinity of 

the mine would continue to provide habitat for these species. Given the availability of 

surrounding habitat, Alternative C would not be expected to result in the extirpation of 

any endemic species. 

Migratory Birds 

Alternative C would impact approximately 114 acres of productive and 60 acres of 

unproductive spruce/hemlock forest, and approximately 1 acre of non-forested habitat 

potentially used by priority migratory bird species. Initial clearing activities at the 

existing and new TDF areas have the potential to destroy nests or cause nest 

abandonment if the activities occur in suitable nesting habitat during the breeding/nesting 

period. Nesting typically begins in mid-April and ends about mid-July, when young 

birds have fledged, after which time nesting activities would not be directly affected. 

Effects would be considered low due to the amount of overall clearing and low potential 

for population-level impacts to migratory birds; surrounding habitat would remain 

functional and could maintain the species. 

3.11.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of a new TDF. Like alternatives B and C, Alternative D would extend the operating 

period of the mine by 30–50 years. The expansion of the existing TDF would be 

substantially smaller than Alternative B but larger than under Alternative C. The 

footprint of the new TDF would be similar in size to that build under Alternative C. 

Effects to wildlife habitat would be similar to Alternative C. Like Alternative C, wildlife 

impacts of this alternative would be more widespread than alternatives A and B due to 

development of a new TDF. Construction of the new TDF (and associated effects) would 

not occur for approximately 12 years. 

Management Indicator Species 

Brown Bear 

Impacts to brown bears under Alternative D would be similar to Alternative C, except 

that expansion of the southern tailings facility would impact approximately 0.5 more 
Chapter 3. Affected Environment and Environmental Consequences

3-182 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

acres of brown bears foraging habitat (forest within 500 feet of the creek) along the lower 

reaches of Tributary Creek. Bears in this area would likely be at least temporarily 

displaced during initial construction of the TDF. The presence of bears at the existing 

TDF indicates that bears would be expected to habituate to the disturbance once 

construction is complete. However, this also means that there is increased potential for 

human-bear conflicts. 

Additionally, Alternative D would result in a slightly reduced stream flow to a portion of 

Fowler Creek associated with development of the new TDF (see sections 3.5.3.6 and 

3.7.2 for additional discussion). This area provides rearing habitat for coho, and to a 

limited extent, spawning habitat for coho, chum, and pink salmon. Thus, reduced stream 

flow under Alternative D has the potential to reduce anadromous fish production by a 

small amount. Fish provide an important food source for brown bears. It is anticipated 

that the reduction in anadromous fish production resulting from Alternative D would 

occur gradually over 30–50 years, and impacts would be long-term. To mitigate for the 

loss of salmon rearing and spawning habitat, the operator is in discussion with the 

agencies regarding the suitability of mitigation, in the form of fish passage 

improvements, for the loss of habitat in Tributary Creek. These measures would also 

mitigate for impacts associated with a loss in fish production to brown bears. 

Bald Eagle 

Impacts to bald eagles under Alternative D would be the same as under Alternative C. 

Black-tailed Deer 

Impacts to black-tailed deer under Alternative D would be similar to Alternative C. 

Approximately 153 acres of deer winter range in WAA 3836 and 31 acres of deer winter 

range in WAA 3837 would be removed under Alternative D in association with 

development of the northern and expansion of the southern tailings expansion areas, 

respectively. This equates to less than 1 percent of the existing winter range in these 

WAAs. Similar to Alternative C, there would be additional road use associated with 

hauling tailings and thus an increased level of road traffic would be expected. Therefore, 

there is a potential for increased road kill of deer under Alternative D. Indirect impacts to 

the species’ local distribution and use of habitat in the vicinity of the TDFs could occur 

during construction, but given the frequency with which deer are observed in the vicinity 

of the mining operations it is anticipated that they would return to the area, especially 

following short-term reclamation activities resulting in new vegetation growth. Because 

the surrounding area provides winter range for deer and because reductions in winter 

range would occur over the extended operating period, Alternative D would not preclude 

deer from wintering in WAA 3836 and 3837. 

Marten 

Alternative D would result in the removal of 115 acres of productive old-growth 

associated with expansion of the existing TDF and development of the new TDF. Marten 

using this area would be displaced to areas where forest cover is maintained, but impacts 

would be localized. Therefore, no population level impacts would occur under 

Alternative D. 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-183 

Vancouver Canada Goose 

Impacts to Vancouver Canada geese under Alternative D would be similar to Alternative 

C, except that expansion of the existing TDF and development of the new TDF under 

Alternative D would remove a total of 121 acres of wetland habitat (compared to more 

than 3,000 acres in the wetland study area; see Table 3.8-1). This would reduce the 

amount of potential nesting habitat for this species. However, this habitat loss would be 

expected to result in minor local impacts to this species, and would not be expected to 

affect populations given the amount of remaining available habitat. 

River Otter 

Alternative D, like Alternative C, would impact forested habitats along Tributary Creek 

in association with the existing TDF and along the Unnamed Creek draining to north 

Hawk Inlet in association with development of the new TDF. Otters using this area 

would be permanently displaced from the immediate area of the TDF. No stream habitat 

would be lost along Tributary Creek under Alternative D, although approximately 1,044 

feet of Class II streams would be lost due to TDF development in the Fowler Creek 

drainage (Table 3.7-8). While the magnitude of these effects would be the same as under 

Alternative C, the duration of effects under Alternative D would be shorter because fill 

would begin 15 years later, reducing the period of habitat loss for river otters. The 

chance of accidental spills to project area creeks under Alternative D would be similar to 

Alternative C, but the period of time a spill could affect Fowler Creek would be less 

under Alternative D because construction of the new TDF would occur at a later time. 

However, water quality impacts potentially affecting river otters are not anticipated under 

Alternative D due to the implementation of spill control/rapid response measures (see 

Section 3.7.3.6). 

Red Squirrel 

Approximately 115 acres of POG spruce/hemlock forest would be cleared under 

Alternative D. Therefore, habitat loss and localized habitat fragmentation would be 

expected to result in minor local impacts to this species and would not be expected to 

affect populations given the amount of remaining available habitat. 

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper 

Under Alternative D approximately 115 acres of old-growth habitat would be removed in 

association with expansion of the existing TDF development of the new TDF. 

Alternative D would result in local habitat fragmentation, to a greater extent than the 

other alternatives, which could potentially disrupt the movements of individual hairy 

woodpeckers, brown creepers, or red-breasted sapsuckers in the immediate vicinity of 

Tributary Creek and Fowler Creek, but would not be expected to affect populations of 

these species in the study area given the remaining available habitat. 
Chapter 3. Affected Environment and Environmental Consequences

3-184 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Other Species of Concern 

Marbled Murrelet 

Alternative D would remove approximately 115 acres of POG in association with the 

expansion of the existing TDF and development of the new TDF. An estimated 29 acres 

of coarse canopy structure (SD67 category) would be removed. Surveys of the new TDF 

area did not document use by murrelets. One murrelet was observed flying over the 

existing TDF. Therefore it is recommend that dawn watch surveys be conducted prior to 

ground disturbing activities to ensure that disturbance to birds using the development 

areas is minimized. If nesting murrelets were present at the time of construction, a 600-

foot buffer of undisturbed forest would be maintained, where available, in accordance 

with Forest Plan Standards and Guidelines. Construction activities, if they coincide with 

this buffer, would be timed to occur outside of the nesting season (May 1 to August 15), 

to avoid disturbance to nesting murrelets. Impacts to the marine environment, and thus 

marbled murrelet prey, under Alternative D would be the same as under Alternative C. 

Therefore, Alternative D would have minor impacts to marbled murrelets. 

Waterfowl and Shorebirds 

Effects to waterfowl and shorebirds would be the same as under Alternative B. 

Marine Mammals 

Effects to marine mammals under Alternative D would be the same as under 

Alternative B. 

Endemic Species 

Alternative D would increase habitat fragmentation in the vicinity of the existing and new 

TDFs. Additional clearing would create a larger gap in the forest than Alternative C; 

though the forest is fragmented to some extent by the existing road. The effect on the 

area surrounding the proposed new TDF would not occur for approximately 10 years. 

Local movements by endemic species have the potential to be inhibited by habitat 

removal; however, given the availability of surrounding habitat. Alternative D would not 

be expected to result in the extirpation of any endemic species. Existing beach buffers 

and riparian buffers in the vicinity of the mine would continue to provide habitat for these 

species and forest both north and south of the proposed TDF would continue to provide 

travel corridors between inland areas and the shoreline. 

Migratory Birds 

Alternative D would impact approximately 115 acres of productive and 70 acres of 

unproductive spruce/hemlock forest, and approximately 1 acre of non-forested habitat 

potentially used by priority migratory bird species. Effects would be considered low due 

to the amount of overall clearing and low potential for population-level impacts to 

migratory birds; surrounding habitat would remain functional to maintain the species. To 

reduce the potential for impacts to nesting migratory birds, ground disturbing activities 

and tree clearing should be conducted outside the nesting season in the region (late May 

through early July). 
3.11 Wildlife 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-185 

3.11.4 Wildlife – Summary 

MIS, other species of concern, and their habitats would all be somewhat affected under 

any of the alternatives. Three MIS species are not known to occur on Admiralty Island 

(wolf, black bear, and mountain goat) even though habitat exists. 

Under all alternatives, there would be some level of continued human activity occurring 

at the existing TDF, mine site, marine facility, and along the access road. Thus, the 

potential for direct mortality and disturbance of wildlife associated with ongoing TDF 

operations would continue through the term of the lease. The large barges and ships that 

are used to deliver fuel and equipment and haul the concentrate from the mine, as well as 

the crew shuttle transiting Young Bay, would continue but are not likely to affect marine 

mammal distribution in Hawk Inlet, Young Bay, or Chatham Strait. Although these 

impacts are common to all alternatives, the duration of effects differs by alternative. 

Operation of the mine would continue until 2019 under Alternative A. However, all of 

the action alternatives would extend the operating period of the mine for an additional 30 

to 50 years. Therefore, reclamation of the mine site and reductions in levels of human 

activity, water quality impacts, and fugitive dust emissions would occur more quickly 

under Alternative A than under the action alternatives. 

Although many wildlife species in the Tongass National Forest are associated with more 

than one habitat type, most inhabit old growth forests or prey on species that inhabit old 

growth forests. Therefore the assessment of impacts of wildlife and wildlife habitat 

focuses on old growth ecosystem. Reduction in productive old-growth is somewhat 

similar across alternatives ranging from approximately 73 acres under Alternative B to 

115 acres under Alternative D. Slightly more high volume/coarse canopy forest SD-5N, 

SD-5S, and SD-67) would be removed under Alternative D (37 acres) followed by 

Alternative B (30 acres), Alternative C (30 acres), and Mitigated Alternative B (27 acres). 

The level of reduction would not be expected to affect populations of these species in the 

study area given the remaining available habitat. 

Protection to brown bear, bald eagle, Vancouver Canada goose, waterfowl, shorebirds, 

and river otter is afforded by Forest-wide standards and guidelines that require the 

maintenance of a 1,000-foot beach and estuary buffer along the shoreline, stream 

protection buffers, and maintenance of 500 foot-wide buffers along Class I anadromous 

streams where brown bears forage. Marine mammals are protected under the MMPA and 

Forest-wide standards and guidelines. Further protection for deer winter habitat, marten, 

forest-dwelling bird species such as the red breasted sapsucker, hair woodpecker, brown 

creeper, marbled murrelet, various migratory bird species, and endemics is provided for 

in the Forest Plan, standards and guidelines for reserve tree/cavity-nesting habitat, 

marbled murrelets, marten, and endemic terrestrial mammals, and the Forest Plan 

conservation strategy reserve system. Table 3.11-4 provides a summary of impacts from 

the project on MIS and other species of concern. 
Chapter 3. Affected Environment and Environmental Consequences

3-186 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.11-4. Summary of Level of Impacts from Each Alternative of the Project to 

Management Indicator Species and Other Species of Concern. 

Species 

Impact from Project* 

Alternative A Alternative B 

Mitigated 

Alternative B Alternative C Alternative D 

Management Indicator Species 

Brown bear Minor Minor Minor Minor Minor 

Bald eagle Negligible Minor Minor Minor Minor 

Sitka black-tailed deer Minor Minor Minor Minor Minor 

Marten Negligible Minor Minor Minor Minor 

Vancouver Canada 

goose Negligible Minor Minor Minor Minor 

River otter Negligible Minor Minor Minor Minor 

Red squirrel Negligible Minor Minor Minor Minor 

Red-breasted 

sapsucker, hairy 

woodpecker, brown 

creeper Negligible Minor Minor Minor Minor 

Other Species of Concern 

Marbled murrelet Minor Minor Minor Minor Minor 

Waterfowl/shorebirds Minor Minor Minor Minor Minor 

Marine mammals Minor Minor Minor Minor Minor 

Endemic mammals Negligible Minor Minor Minor Minor 

Migratory birds Negligible Minor Minor Minor Minor 

*Impact thresholds, consistent with Forest Service direction for assessing impacts (Forest Service 2009, p 

7-8) are as follows: 

Negligible: Individuals would not be affected, or the action would affect an individual but the change would 

be so small that it would not be of any measureable or perceptible consequence to the individual or 

population. Effects equate to a “no effect” determination for a threatened or endangered species, or a “no 

impact” determination for sensitive species. 

Minor: Individuals would be affected but the change would be small. Impacts would not be expected to 

have long-term effects on species or their habitats, or the natural processes sustaining them. Occasional 

responses to disturbances by some individuals would be expected, but without interference to reproduction, 

or other factors affecting population levels. Effects equate to a “not likely to adversely affect” determination 

for threatened and endangered species, or a “may impact individuals but not likely to cause a trend to 

federal listing or a loss of viability” determination for sensitive species. 

Moderate: Individuals would be noticeably affected. The effect could have some long-term consequences 

to individuals or habitat. Breeding animals of concern are present; animals are present during particularly 

vulnerable life-stages, such as migration or juvenile states; or interference with activities necessary for 

survival can be expected on an occasional basis. Frequent response to disturbance by some individuals 

could be expected, with some negative impacts to feeding, reproduction, or other factors affecting shortterm population levels. Effects equate to a “likely to adversely affect” determination for threatened and 

endangered species, or a “may impact individuals but not likely to cause a trend to federal listing or loss of 

viability” determination for sensitive species. 

Major: Populations would be affected with a long-term, vital consequence to individuals, populations, or 

habitat. Impacts on species, their habitats, of the natural processes sustaining them would be detectable. 

Effects equate to “likely to adversely affect” determination for threatened or endangered species, or “likely to 

result in a trend to federal listing or loss of viability” determination for sensitive species. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-187 

3.12 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and Rare 

Plants _____________________________________ 

This section addresses the potential effects of the 

project on federally listed threatened and endangered 

species, candidates for listing, Forest Service Alaska 

Region sensitive species, and rare plants and their 

habitats. A BA has been prepared for this project 

(Tetra Tech 2013) under separate cover, meeting the 

requirements of Section 7(a)(2) of the federal ESA of 

1973, as amended (16 USC 1531 et seq.), and the 

requirements of the National Forest Management Act 

(Section 36 CFR 219.19). 

The National Forest Management Act requires the 

Forest Service to manage habitat to maintain viable 

populations of existing native and desired nonnative 

vertebrate species in the planning area and ensures 

that its actions do not contribute to trends toward 

federal listing. The Forest Service must evaluate the 

effects of the project to threatened, endangered, and sensitive species as directed in FSM 

Chapter 2670.31 through 2672.43. 

Section 7 of the ESA requires that “[e]ach Federal agency shall, in consultation with and 

with the assistance of the Secretary, insure that any action authorized, funded, or carried 

out by such agency is not likely to jeopardize the continued existence of any endangered 

species or threatened species or result in the destruction or adverse modification of 

habitat of such species which is determined by the Secretary, after consultation as 

appropriate with affected States, to be critical (16 USC 35 Sections 1531-1544).” Marine 

mammals are also protected by the MMPA. The USFWS and NMFS share responsibility 

for implementing the ESA, with terrestrial species falling under the jurisdiction of the 

USFWS and marine mammals falling under the jurisdiction of NMFS. Candidate species 

are addressed as Forest Service Alaska Region Sensitive Species; however, an effects 

determination was not established for these species because they are not currently listed 

under the ESA. 

Threatened, endangered, and candidate species potentially occurring in the vicinity of the 

Greens Creek Mine were identified through ongoing consultation with the USFWS and 

the NMFS. Sensitive listed species potentially occurring in the project area were 

obtained from the most recent Forest Service Alaska Region sensitive species list (Forest 

Service 2009). Table 3.12-1 provides a comprehensive list of these species by managing 

agency, and identifies species carried forward in the analysis based on known 

occurrences or the presence of suitable habitat. The subsequent discussions of these 

species are abbreviated for this EIS but are presented in much greater detail in the BA 

(Tetra Tech 2013). Additional wildlife species of concern are addressed in Section 3.11, 

Wildlife. Aquatic resources are discussed in Section 3.7. 

The resource analysis of 

threatened and endangered 

species is related to Issue 2, 

impacts of wetlands and 

associated habitat values, as 

well as Issue 3, impacts to fish 

streams. Measures of impacts 

to threatened and endangered 

species include identifying the 

presence of threatened and 

endangered species as well as 

acres of impacted habitat for 

selected species.
Chapter 3. Affected Environment and Environmental Consequences

3-188 Greens Creek Mine Tailings DispTable 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species anand in the Vicinity of the Greens Creek Mine. 

Common Name 

Scientific Name Habitat Association/Range 

Potential Occurren

Greens Cre

Species under USFWS Jurisdiction 

Eskimo curlewNumenius borealis

Arctic tundra. No, outside of species

Short-tailed albatross Phoebastria albatrus

Winters in waters of the Bering Sea, Aleutian Islands, and Gulf of Alaska; breeds in Japan (USFWS 2008). 

No, outside of species

Spectacled eider Somateria fischeri

Coastal waters in northern and western Alaska (Peterson et al. 2000). 

No, outside of species

Steller’s eider Polysticta stelleri

Occurs in northern Alaska and Aleutian Islands (Fredrickson 2001). No, outside of species

Polar bear Ursus maritimus

Sea ice and coastlines of western Alaska and along the North Slope. 

No, outside of species

Pacific walrus Odobenus rosmarus divergens

Continental shelf waters of Bering and Chukchi Seas. No, outside of species

Species under NMFS Jurisdiction 

Blue whale Balaenoptera musculus

Off-shore (pelagic) marine waters of the Bering Sea, Chukchi Sea, North Pacific Ocean and/or Gulf of Alaska (ADFG 2008, 73 FR 19000). Critical habitat designated for North Pacific right whales in the Bering Sea and the Gulf of Alaska (73 FR 19000). 

No, very rarely observAlaska. 

Bowhead whale Blaena mysticetusFin whale Balaenoptera physalusNorthern Pacific right whale Eubalaena japonicaSources: Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (USFWS and NMFS 2011; updated A

Service Alaska Region Sensitive Species List (Forest Service 2009). Notes: 

a. FT = federally threatened; FE = federally endangered; P = Proposed for federal listing; C = candidate for federal listing; FS

Listed Species; FSR = Forest Service Rare Plant. 

b. DPS = distinct population segment. c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest Service Sensitive s

ESA candidate species are Forest Service Sensitive species. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region S

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species anand in the Vicinity of the Greens Creek Mine. 

Common Name 

Scientific Name Habitat Association/Range 

Potential Occurren

Greens Cre

Species under NMFS Jurisdiction (continued) 

Sei whale

Balaenoptera borealis 

Off-shore (pelagic) marine waters of the Bering Sea, Chukchi Sea, North Pacific Ocean and/or Gulf of Alaska (ADFG 2008, 73 FR 19000). Critical habitat designated for North Pacific right whales in the Bering Sea and the Gulf of Alaska (73 FR 19000). 

No, very rarely observAlaska. 

Sperm whale Physeter macrocephalusHumpback whale Megaptera novaeangliae

Common in the inside waters of the Alexander Archipelago and are regularly sighted in the Inside Passage and coastal waters of the southeast Alaska panhandle (NMFS 1991). 

Yes, occurs in Stephedocumented in the shwaters of Hawk Inlet. 

Bearded seal Erignathus barbatus

Sea-ice habitats in Bering Sea, Chukchi Sea, Beaufort Sea (ADFG 2008). 

No, outside species’ r

Ringed seal Phoca hispidaSpotted seal Phoca larghaNorthern sea otter, SW Alaska population Enhydra lutris kenyoni

Coastal marine habitats. No, population does n

Inlet. 

Steller sea lion – Eastern DPS b

Eumetopias jubatus

Marine and terrestrial areas in southeast Alaska (east of 144° west longitude). 

Yes, occurs in Hawk 

Steller sea lion – Western DPS bEumetopias jubatus

Marine and terrestrial areas in southeast Alaska (west of 144° west longitude). 

Yes, occurs in Hawk 

Sources: Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (USFWS and NMFS 2011; updated A

Service Alaska Region Sensitive Species List (Forest Service 2009). Notes: 

a. FT = federally threatened; FE = federally endangered; P = Proposed for federal listing; C = candidate for federal listing; FS

Listed Species; FSR = Forest Service Rare Plant. 

b. DPS = distinct population segment. c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest Service Sensitive s

ESA candidate species are Forest Service Sensitive species. 
Chapter 3. Affected Environment and Environmental Consequences

3-190 Greens Creek Mine Tailings DispTable 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species anand in the Vicinity of the Greens Creek Mine. 

Common Name 

Scientific Name Habitat Association/Range 

Potential Occurren

Greens Cre

Species under NMFS Jurisdiction (continued) 

Green sea turtle Chelonia mydas

Occur in the Gulf of Alaska and some species are found as far west as the Aleutian Islands. 

No, only rarely observAlaska. 

Loggerhead sea turtle Caretta carettaOlive Ridley sea turtle Lepidochelys olivaceaLeatherback sea turtle Dermochelys coriaceaChinook salmon (Six Runs) Onchorhynchus tshawytshca

Originating in freshwater habitats Washington and Oregon; migrate through the Gulf of Alaska. 

Possible, primarily ocwaters of southeast AService 2008a). Occsoutheast Alaska watdocumented, but infre

Sockeye salmon Onchorhynchus nerkaSteelhead (Six Runs) Onchorhynchus mykissChum Salmon Oncorhynchus ketaGreen sturgeon Acipenser medirostris

Spawns in the Sacramento River. No, only rarely occurs 

Alaska. 

Sources: Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (USFWS and NMFS 2011; updated A

Service Alaska Region Sensitive Species List (Forest Service 2009). Notes: 

a. FT = federally threatened; FE = federally endangered; P = Proposed for federal listing; C = candidate for federal listing; FS

Listed Species; FSR = Forest Service Rare Plant. 

b. DPS = distinct population segment. c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest Service Sensitive s

ESA candidate species are Forest Service Sensitive species. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region S

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS Table 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species anand in the Vicinity of the Greens Creek Mine. 

Common Name 

Scientific Name Habitat Association/Range 

Potential Occurrenc

Greens Cree

Forest Service, Alaska Region Designated Sensitive Species c

Queen Charlotte goshawk Accipiter gentilis laingi 

Mature/old growth forests. Yes, known to occur on 

and suitable habitat prenest found in June 201existing TDF, within the new TDF under alterna

Aleutian Tern Sterna aleutica

Nests on islands, shrub-tundra, grass or sedge meadows and freshwater and coastal marshes. 

No, no suitable habitat 

Black oystercatcher Haematopus bachmani

Rocky shorelines along the coast; forages in sheltered areas where low-sloping gravel or rock beaches with abundant prey occur. 

Yes, suitable shoreline 

Dusky Canada gooseBranta canadensis occidentalis

Nests primarily on the Copper River Delta of Alaska’s south 

central coast 

Yes, habitat is presentnest in the Tongass Naalthough they do occur 

Forest Service, Alaska Region Designated Sensitive Species and Rare Plantsc

Kittlitz’s murrelet Brachyramphus brevirostris

Breeds in the vicinity of glaciers and cirques in high-elevation alpine areas with little or no vegetative cover; northern Gulf of Alaska, and Bering Sea coast (Day et al. 1999). 

No, due to lack of suit

Yellow-billed loon Gavia adamsii

Nests near freshwater lakes in the arctic tundra and winters along the Alaskan coast to the Puget Sound (North 1994). 

Possible; not known tTongass National Forbeen documented wininside waters of south

Pacific herring, Southeast Alaska DPSb

Clupea pallasi 

Occurs in the marine waters in Southeast Alaska. Yes, occurs in Hawk 

Sources: Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (USFWS and NMFS 2011; updated A

Service Alaska Region Sensitive Species List (Forest Service 2009). Notes: 

a. FT = federally threatened; FE = federally endangered; P = Proposed for federal listing; C = candidate for federal listing; FS

Listed Species; FSR = Forest Service Rare Plant. 

b. DPS = distinct population segment. c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest Service Sensitive s

ESA candidate species are Forest Service Sensitive species. 
Chapter 3. Affected Environment and Environmental Consequences

3-192 Greens Creek Mine Tailings DispTable 3.12-1. Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species anand in the Vicinity of the Greens Creek Mine. 

Common Name 

Scientific Name Habitat Association/Range 

Potential Occurren

Greens Cre

Forest Service, Alaska Region Designated Sensitive Species and Rare Plantsc (continued) 

Moosewort fern Botrychium tumux

Sandy beaches, and maritime beaches, alpine/subalpine, welldrained gravelly areas. Occurs among rocks and gravel in alpine habitat on ridge approximately 1 mile north of Greens Creek Mine. 

No, due to lack of suit

Moonwort fern Botrychium yaaxudakiet

Occurs among maritime beaches, alpine/subalpine, well-drained gravelly areas rocks and gravel in alpine habitat, occurs on ridge approximately 1 mile north of Greens Creek Mine. 

No, due to lack of suit

Mountain lady’s slipper Cypripedium montanum

Upper beach meadow/forest ecotone; known to occur north of the mouth of Endicott River, in Haines area, Glacier Bay, the Stikine R., and Etolin Island. 

Yes, not documented surveys but potential 

Large yellow lady’s slipper Cypripedium parviflorum v. pubescens

Associated with peatlands. Yes, not documented 

surveys but potential 

Calder loveageLigusticum calderi

Subalpine meadows in areas considered to be glacial refugia; also associated with calcareous substrate. 

No, due to lack of suit

Alaska rein orchidPiperia unalascensis

Dry open sites, under tall shrubs in riparian zones, mesic meadows, and drier areas in coniferous and mixed evergreen forests from low elevation to subalpine. 

Yes, not documented surveys but suitable h

Kruckeberg’s swordfern Polystichum kruckebergii

Grows in sheltered cracks in the dunite rock of ultramafic outcrops. No, due to lack of suit

Henderson’s checkermallowSidalcea hendersonii

Meadow/forest ecotone of the estuary at the head of Howard Bay. No, due to lack of suit

Bog adder’s-mouth Malaxis paludosa

Swampy woods, on bare ground or amongst sedges and grasses, but prefers acidic Sphagnum bogs near streams 

Yes, documented in p

Sources: Endangered, Threatened, Proposed, Candidate, and Delisted Species in Alaska (USFWS and NMFS 2011; updated A

Service Alaska Region Sensitive Species List (Forest Service 2009). Notes: 

a. FT = federally threatened; FE = federally endangered; P = Proposed for federal listing; C = candidate for federal listing; FS

Listed Species; FSR = Forest Service Rare Plant. 

b. DPS = distinct population segment. c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest Service Sensitive s

ESA candidate species are Forest Service Sensitive species. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-193 

The Forest Plan requires that adverse effects to rare plants and populations be avoided, 

minimized, or mitigated during project planning to maintain known distributions 

throughout the Tongass National Forest (PLA1.III.C). Rare plants are determined by the 

Alaska Natural Heritage Program (AKNHP 2008), considering rarity within the state and 

the global distribution (Lipkin and Murray 1997) in addition to species considered rare on 

the Tongass National Forest. (The subsequent discussions of rare plants are abbreviated 

for this EIS but are presented in greater detail in the Botany resource report prepared for 

this project (Anderson 2012).) 

3.12.1 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and 

Rare Plants – Pre-mining Environment 

Prior to mining, the wildlife habitats in the vicinity of the mine were much like the 

existing vegetation elsewhere on Admiralty Island. They consisted primarily of hemlockspruce forest, interspersed with a mosaic of non-forested plant communities, including 

peat wetlands, shrub wetlands, and sedge meadows (Forest Service 2003). Coastal and 

nearshore marine habitats are present in Hawk Inlet and riparian and aquatic habitats 

occur along Cannery Creek, Tributary Creek, and several smaller creeks (Further Creek, 

Franklin Creek, Proffett Creek, Althea Creek and CC Creek). These habitats support a 

number of marine mammal, terrestrial mammal, avian, and fish species. 

Listed species addressed in the 1983 EIS for the Greens Creek Mine addressed the 

humpback whale (Megaptera novaeangliae) and two subspecies of peregrine falcon 

(Falco peregrinus anatum and F. p. tundrensis). Since that time, there have been 

changes in the ESA listing status of a number of species occurring in Alaska, including 

the delisting of the peregrine falcon. These changes are summarized below. The Forest 

Service Alaska Region sensitive species list was created in 1991 and therefore, species 

included on the current list (see Table 3.12-1) were not addressed in the 1983 EIS; 

however, some of these species were addressed in the 2003 EIS. 

Table 3.12-1 also lists the sensitive plant species known or suspected to occur on the 

Juneau Ranger District and Admiralty Island National Monument of the Tongass 

National Forest and one rare plant known to occur in the project area. Only three species, 

Cypripedium montanum, Cypripedium parviflorum var. pubescens, and Piperia 

unalascensis have the potential to occur in the study area due to the presence of suitable 

habitat. 

3.12.1.1 Species Not Addressed in Detail 

Many of the species listed in Table 3.12-1 may occur within the general vicinity of the 

project area (i.e., within southeast Alaska or in the Tongass National Forest); however, 

they would not occur in or near the project study area related to the TDF expansion 

alternatives. This includes all of the marine mammal species listed in Table 3.12-1 

except for the humpback whale and Steller sea lion; all of the sea turtle species; and all of 

the avian species except for the black oystercatcher, Queen Charlotte goshawk, and 

yellow-billed loon. The remaining species (blue, bowhead, right, fin, sei, and sperm 

whales; bearded, ringed and spotted seal; polar bear; Pacific walrus; green, leatherback, 

loggerhead, and olive Ridley sea turtles; Eskimo curlew; Aleutian tern; dusky Canada 
Chapter 3. Affected Environment and Environmental Consequences

3-194 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

goose; short-tailed albatross; spectacled eider; Steller’s eider; and Kittlitz’s murrelet) are 

discussed in more detail in the BA (Tetra Tech 2013). 

3.12.2 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and 

Rare Plants – Baseline Conditions 

This section provides a more detailed description of existing threatened and endangered 

species in the vicinity of the mine site and impacts that have occurred to date. The study 

area for threatened and endangered species includes a one-half-mile buffer around the 

TDF and the portion of the B Road extending from the existing lease boundary north to 

the new TDF proposed under alternatives C and D, plus the adjacent waters of Hawk 

Inlet. This area extends beyond the limit of direct ground disturbance but is adequate to 

capture farther reaching effects such as noise and the introduction and spread of weeds. 

Resources used to derive information on baseline conditions include the following: 

 Greens Creek Tailings Final EIS (Forest Service 2003); 

 Greens Creek Mine Final EIS (Forest Service 1983); 

 Peer-reviewed research (cited below where appropriate); 

 NMFS stock assessments (e.g., Allen and Angliss 2010); 

 Field studies conducted in support of this project (e.g., Kai Environmental Consulting 

2010a, b; 2011a, b); and 

 Botany Resource Report (Anderson 2012). 

As noted above, the peregrine falcon, which was federally listed as endangered during the 

preparation of the 1983 EIS, has been delisted. Other relevant changes in relation to 

species status since the inception of mining at Greens Creek have included the listing of 

the polar bear, Steller sea lion (both western and eastern DPS), short-tailed albatross, 

northern sea otter (southwest Alaska DPS), Steller’s eider, green, leatherback, loggerhead 

and olive Ridley sea turtles, and spectacled eider; and designation of the Kittlitz’s 

murrelet, Pacific walrus, yellow-billed loon, and Pacific herring as candidates for listing. 

Potential effects associated with construction and operation of the mine addressed in the 

1983 and 2003 EISs included habitat loss, disturbance and/or displacement due to mining 

activities and associated marine traffic, attraction of wildlife to mine facilities, and 

contamination due to contact with water discharged into Hawk Inlet. Effects that have 

occurred under current operations relative to wildlife, vegetation, and aquatic resources 

are discussed in more detail in sections 3.11, 3.10, and 3.7, respectively. 

Forest Service Natural Resource Information System records indicate 91 sensitive plant 

surveys have been conducted within the general Greens Creek Mine area. These include 

shorelines in Hawk Inlet and Young Bay, large areas of alpine and subalpine on ridges 

above the mine, and small scattered plots throughout the forest, meadows, and muskegs 

(1981–2011): 20 of these occurred in or near the immediate project area between 1981 

and 2004. Records of University of Alaska Museum of Natural History Herbarium 

(UAMNH 2011) through 2010 do not report any sensitive or rare plants for the project 

area. During surveys for Alaska Region sensitive plants (Bosworth 2010) one rare plant, 

Malaxis paludosa (bog adder’s-mouth) was found near the existing TDF site. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-195 

3.12.2.1 Determinations 

A determination was made to assess the effects of the project on threatened and 

endangered species or their critical habitat (50 CFR 402.14, FSM 2671.44), based on the 

physical and biological requirements of these species and considering the potential 

effects from implementing any of the action alternatives described in this EIS. 

Determinations were also made for Forest Service Sensitive species. 

A determination of “no effect” is rendered in regard to all threatened and endangered 

species with the exception of the humpback whale and Steller sea lion where a “not likely 

to adversely affect” call was made. The NMFS concurred with this determination and 

added that, given the limited scope of action impacts in marine waters as well as the 

required protections in place, this action would have, at most, an insignificant or 

discountable effect on humpback whales and Stellar sea lions species. In addition, six 

species listed as Forest Service Sensitive received a “may impact individuals but not 

likely to cause a trend to federal listing or a loss of viability” and include Queen 

Charlotte goshawk, black oystercatcher, and yellow-billed loon (also a Federal 

Candidate), and the three sensitive plant species (Cypripedium montanum, Cypripedium 

parviflorum var. pubescens, and Piperia unalascensis) with the remainder receiving a 

“no impact” determination. 

Regardless of the selected alternative, actions are not likely to jeopardize the continued 

existence of a listed species or result in the destruction or adverse modification of critical 

habitat in the project area. All project activities would be conducted in a manner 

consistent with the ESA and regulations. Table 3.12-2 provides a summary of the effects 

determination for threatened, endangered, and sensitive species. The effects analysis and 

discussion for the species listed in Table 3.12-1 may be found in the BA associated with 

the proposed Greens Creek Mine Expansion project. The BA (Tetra Tech 2013) is 

located in the project record. 

The effects determination for the rare plant Malaxis paludosa (bog adder’s-mouth) is 

documented in the botany resource report (Anderson 2012). In summary, the risk, 

consequence, and likelihood of adverse impacts to this rare plant is low for Alternative A, 

high for alternatives B and Mitigated B, and moderate for alternatives C and D. 
Chapter 3. Affected Environment and Environmental Consequences

3-196 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.12-2. Summary of Effects Determinations for the Project to Species that Occur in 

or near the Project Area. 

Common Name / 

Scientific Name Status 

Presence in Study Area a 

Effects Determination 

for Action 

Alternativesb Species Present 

Species 

Habitat Present

Species under USFWS Jurisdiction 

[None] 

Species under NMFS Jurisdiction 

Humpback whale 

Megaptera novaeangliae

Endangered Yes Yes Not likely to adversely 

affect 

Steller sea lion – Eastern DPS / 

Western DPS 

Eumetopias jubatus

Threatened / 

Endangered 

Yes Yes Not likely to adversely 

affect 

Chinook salmon—Puget Sound 

Onchorhynchus tshawytscha

Threatened No Yes No Effect 

Chinook salmon—Lower 

Columbia River 

Onchorhynchus tshawytscha

Threatened No Yes No Effect 

Chinook salmon—Upper 

Willamette River 

Onchorhynchus tshawytscha

Threatened No Yes No Effect 

Chinook salmon—Upper 

Columbia River – spring 

Onchorhynchus tshawytscha

Endangered No Yes No Effect 

Chinook salmon—Snake River–

spring/summer 

Onchorhynchus tshawytscha

Threatened No Yes No Effect 

Chinook salmon—Snake River–

fall run 

Onchorhynchus tshawytscha

Threatened No Yes No Effect 

Sockeye salmon—Snake River 

Onchorhynchus nerka 

Endangered No Yes No Effect 

Steelhead—Puget Sound 

Onchorhynchus mykiss

Endangered No Yes No Effect 

Steelhead—Upper Columbia 

River 

Onchorhynchus mykiss

Endangered No Yes No Effect 

Notes: 

a. “Yes” if the species is known or is likely to occur in the study area or in marine waters adjacent to the 

study area. 

“No” if the species has not been documented or is not likely to occur in the study area. 

b. Levels of influence are defined in the “Fish and Wildlife Resource Report.” Determinations are only 

required for listed and sensitive species. Determinations for threatened and endangered species 

include “no effect,” “not likely to adversely affect,” or “likely to adversely affect.” Determinations for 

sensitive species include "no impacts,” "beneficial impacts," "may impact individuals but not likely to 

cause a trend to federal listing or a loss of viability," or "likely to result in a trend to federal listing or 

loss of viability" (Bosch 2004). 

c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest 

Service Sensitive species; however, note that ESA candidate species are Forest Service Sensitive 

species. 

 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-197 

Table 3.12-2. Summary of Effects Determinations for the Project to Species that Occur in 

or near the Project Area. 

Common Name / 

Scientific Name Status 

Presence in Study Area a 

Effects Determination 

for Action 

Alternativesb Species 

Present 

Species 

Habitat Present 

Species under NMFS Jurisdiction (continued) 

Steelhead—Middle Columbia 

River 

Onchorhynchus mykiss

Threatened No Yes No Effect 

Steelhead—Lower Columbia 

River 

Onchorhynchus mykiss

Threatened No Yes No Effect 

Steelhead -—Snake River Basin

Onchorhynchus mykiss

Threatened No Yes No Effect 

Steelhead—Upper Willamette 

River 

Onchorhynchus mykiss

Threatened No Yes No Effect 

Chum salmon—Columbia River

Oncorhynchus keta 

Threatened No Yes No Effect 

Forest Service, Alaska Region Designated Sensitive Species c 

Queen Charlotte goshawk 

Accipiter gentilis laingi

Forest Service 

Sensitive 

Yes Yes May impact individuals 

but not likely to cause a 

trend to federal listing or 

a loss of viability. Black oystercatcher 

Haematopus bachmani

Forest Service 

Sensitive 

No Yes 

Yellow-billed loon 

Gavia adamsii

ESA 

Candidate; 

Forest Service 

Sensitive 

No Yes 

Pacific Herring, Southeast 

Alaska DPS 

Clupea pallasi

ESA 

Candidate; 

Forest Service 

Sensitive 

Yes Yes 

Mountain lady’s slipper 

Cypripedium montanum 

Forest Service 

Sensitive 

No Yes 

Notes: 

a. “Yes” if the species is known or is likely to occur in the study area or in marine waters adjacent to the 

study area. 

“No” if the species has not been documented or is not likely to occur in the study area. 

b. Levels of influence are defined in the “Fish and Wildlife Resource Report.” Determinations are only 

required for listed and sensitive species. Determinations for threatened and endangered species 

include “no effect,” “not likely to adversely affect,” or “likely to adversely affect.” Determinations for 

sensitive species include "no impacts,” "beneficial impacts," "may impact individuals but not likely to 

cause a trend to federal listing or a loss of viability," or "likely to result in a trend to federal listing or 

loss of viability" (Bosch 2004). 

c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest 

Service Sensitive species; however, note that ESA candidate species are Forest Service Sensitive 

species. 

 
Chapter 3. Affected Environment and Environmental Consequences

3-198 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.12-2. Summary of Effects Determinations for the Project to Species that Occur in 

or near the Project Area. 

Common Name / 

Scientific Name Status 

Presence in Study Area a 

Effects Determination 

for Action 

Alternativesb Species 

Present 

Species Habitat 

Present 

Forest Service, Alaska Region Designated Sensitive Species c (continued)

Large yellow lady’s slipper 

Cypripedium parviflorum var. 

pubescens

Forest Service 

Sensitive 

No Yes 

Alaska rein orchid 

Piperia unalascensis 

Forest Service 

Sensitive 

No Yes 

Bog adder’s-mouth 

Malaxis paludosa

Forest Service 

Rare 

Yes Yes Risk, consequence, and 

likelihood of adverse 

affects are low for 

Alternative A, high for 

alternatives B and 

Mitigated B; and 

moderate for alternatives 

C and D. 

Notes: 

a. “Yes” if the species is known or is likely to occur in the study area or in marine waters adjacent to the 

study area. 

“No” if the species has not been documented or is not likely to occur in the study area. 

b. Levels of influence are defined in the “Fish and Wildlife Resource Report.” Determinations are only 

required for listed and sensitive species. Determinations for threatened and endangered species 

include “no effect,” “not likely to adversely affect,” or “likely to adversely affect.” Determinations for 

sensitive species include "no impacts,” "beneficial impacts," "may impact individuals but not likely to 

cause a trend to federal listing or a loss of viability," or "likely to result in a trend to federal listing or 

loss of viability" (Bosch 2004). 

c. The “Forest Service, Alaska Region Designated Sensitive Species” portion of this table lists the Forest 

Service Sensitive species; however, note that ESA candidate species are Forest Service Sensitive 

species. 

3.12.3 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and 

Rare Plants – Affected Environment 

The status, distribution, ecology, and potential for occurrence within the project area for 

humpback whale, Steller sea lion, Queen Charlotte goshawk, black oystercatcher, yellowbilled loon, and Southeast Alaska DPS Pacific Herring are discussed in more detail 

below. The remainder of the species listed in Table 3.12-1 are assessed in more detail in 

the BA (Tetra Tech 2013). 

3.12.3.1 Humpback whale (Endangered) 

Humpback whales were listed as endangered under the Endangered Species Conservation 

Act, which preceded the creation of the ESA, on December 2, 1970 (USFWS 1970), and 

they have been listed under the ESA since its implementation in 1973. Critical habitat for 

this species has not been designated. 

Commercial whaling operations were the primary contributor to the decline in humpback 

whale populations (NMFS 1991). The primary ongoing threat to humpback whales is 

entanglement in fishing gear (NMFS 1991), especially drift gill-nets (Carretta et al. 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-199 

2007). Noise disturbance is also a threat (Carretta et al. 2007). Whales that use lowfrequency sounds may be at an increased risk for disturbance from anthropogenic noise. 

The eastern North Pacific stock is increasing in abundance, with a total annual take of 1.8 

per year, based on 2000 to 2004 data (Carretta et al. 2007). 

A recovery plan was prepared in 1991 by the humpback whale recovery team for NMFS 

(NMFS 1991). The goal of the plan is for this species to be “biologically successful,” 

meaning that humpback whales occupy all of their former range in sufficient numbers to 

buffer their populations against normal environmental fluctuations or anthropogenic 

environmental catastrophes. The plan states that the best estimator of biological success 

would be if the species is “numerically successful,” meaning that populations grow to 

levels where their population dynamic responses indicate density-dependent reductions in 

productivity. The plan defines “political success” as populations being abundant enough 

that the species can be downlisted or delisted. 

The local distribution of humpbacks in southeast Alaska is correlated with the density 

and seasonal availability of prey species, particularly small schooling fish (herring, 

capelin, juvenile walleye pollock, and Pacific sandlance) and euphausiids (small 

crustaceans). With the exception of capelin, all of these prey species occur in Hawk 

Inlet. Humpback whales occur throughout Chatham Strait and have been observed in 

Hawk Inlet, Young Bay, and Stephens Passage. 

3.12.3.2 Steller sea lion (Eastern DPS-Threatened / Western DPSEndangered) 

The Steller sea lion was emergency-listed as threatened under the ESA in April 1990 by 

NMFS due to rapid population declines (NMFS 1990). The final listing for this species 

as threatened was made in November 1990 (NMFS 1990). Critical habitat was 

designated in April 1993. Areas designated included rookeries and major haulouts in 

state and federal waters off Alaska, Washington, Oregon, and California; and three 

aquatic foraging habitats: one in the Gulf of Alaska and two in the Bering Sea-Aleutian 

Islands area (NMFS 1993). In June 1997, USFWS identified two distinct Steller sea lion 

population segments: one west of 144° W longitude, which was listed as endangered, and 

one east of 144° W longitude which remained listed as threatened (NMFS 1997). Steller 

sea lions are designated under the MMPA as depleted (NMFS 2011). 

Critical habitat for Steller sea lions has been designated and includes a 3,000-foot 

distance landward and seaward from major rookery and haul-out sites. It also includes a 

3,000-foot-elevation air zone above these terrestrial and aquatic zones. No critical habitat 

occurs near the project. 

The causes of the decline of Steller sea lions are not completely known (62 FR 24345). 

Decreases in prey availability due to environmental changes of human activity may be a 

factor. Abandonment of traditional rookeries and haulout sites may be associated with 

human disturbance. An assessment of incidental take of Steller sea lions during 

commercial fishing is being undertaken by NMFS. The significance of shark and killer 

whale predation on Steller sea lion pups is not known. Environmental pollutants and 

contaminants are also a concern (62 FR 24345). 

A recovery plan was released in 1992. The plan called for continuation of research and 

development of new programs to improve the understanding of sea lion management 
Chapter 3. Affected Environment and Environmental Consequences

3-200 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

needs, with an immediate objective of identifying actions that would halt the decline of 

the Steller sea lion population (NMFS 1992). A revised recovery plan was released in 

2008 (NMFS 2008). The goal of the plan is to restore sea lion populations to the point 

where they can eventually be delisted. 

The Eastern DPS is known to occur in Hawk Inlet, although there are areas of overlap 

between the range of the Western and Eastern DPSs of Steller sea lions in Lynn Canal, 

and intermigration between the populations has been documented (NMFS 2008). 

The nearest major haul out, or land site where sea lions rest and take refuge, to the project 

area is Benjamin Island, located approximately 45 miles north of Greens Creek Mine in 

Lynn Canal. However, sea lions have been observed hauled out on rock piles just north 

of the entrance of Hawk Inlet, in Chatham Strait. These rocks are used intermittently by 

up to two dozen Steller sea lions at a time (Forest Service 2003). Steller sea lions also 

gather on well-defined, traditionally used rookeries to pup and breed. The nearest 

rookery to the Greens Creek Mine is White Sisters, approximately 60 air miles from 

Sitka, Alaska. Hazy Island and Forester Island rookeries are located on the outer coast, 

approximately 120 and 150 miles from the mine site, respectively. 

3.12.3.3 Queen Charlotte goshawk (Forest Service Sensitive) 

The Queen Charlotte goshawk is of special concern to the State of Alaska and is on the 

Alaska Watch List of vulnerable and declining bird species in Alaska (Kirchhoff and 

Padula 2010). The USFWS was petitioned to list the northern goshawk in the western 

U.S. under the ESA. Twice the USFWS found the petition to be unwarranted; in 1996 

(61 Federal Register 28834) and in 1998 (63 Federal Register 35183). However, concern 

for the species’ viability in southeast Alaska remains high due to lack of information 

regarding goshawk population trends as well as reductions in the amount of mature and 

old-growth forests due to timber harvest (USFWS 2007). In 2007, in response to a courtordered remand on a petition to list the species, the USFWS updated a 1997 status review 

for the Queen Charlotte goshawk. Based on the best available information on biological 

vulnerability and threats to the species, the review concluded that British Columbia and 

Alaska each supported DPSs of goshawks for which listing as threatened or endangered 

was warranted for British Columbia, but not for Alaska. Conservation measures for this 

species include nest buffer and legacy forest structure standards and guidelines under the 

Forest Plan (Forest Service 2008a). 

The Queen Charlotte goshawk is a subspecies of northern goshawk. The year-round 

range of this subspecies is the islands and mainland of southeast Alaska, the Queen 

Charlotte Islands and Vancouver Island of British Columbia, and coastal mainland British 

Columbia west of the Coast Range (74 FR 56757). Goshawk habitat in southeast Alaska 

is generally considered to be mature (old-growth) forest stands. However, recent 

research in the Southwest and Pacific Northwest indicates that although goshawks prefer 

to place their nests in mature to old-growth forest types, they are much more adaptable 

than once thought. When these old-growth habitats are not available goshawks will also 

nest in maturing second-growth with sufficient structure or in smaller patches of trees, 

and forage in young forest as well as along edges and in openings (Bosakowski et al. 

1999; McClaren 2004; Boyce et al. 2006; Reynolds et al. 2006). Goshawks are also 

known to build and maintain multiple nests, only one of which is used for egg-laying in a 

given season (Squires and Reynolds 1997). 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-201 

There are three known goshawk nests on Admiralty Island. One is near Green Cove 

(approximately 15 miles east of the Greens Creek Mine), and one near the Distin Lake 

Trail (approximately 26 miles south of the Greens Creek Mine). Both of these nests were 

active in 2005, the last year they were monitored. More recently, a third active goshawk 

nest was discovered in June 2011 within the perimeter of the new TDF proposed under 

alternatives C and D (Kai Environmental Consulting Services 2011). In 1999 a goshawk 

was detected across Hawk Inlet from the proposed northern TDF; however, a nest was 

never discovered. 

Surveys for northern goshawks in the proposed expansion of the existing TDF 

(Alternative B) were conducted in June and July 2010 (Kai Environmental Consulting 

Services 2010a). No goshawks or their sign were documented. 

3.12.3.4 Black oystercatcher (Forest Service Sensitive) 

The black oystercatcher was added to the Alaska Region U.S. Forest Service sensitive 

species list in 2009, and is a priority shorebird species in southeast Alaska due to 

concerns with population size, breeding and nonbreeding threats, and nonbreeding 

distribution (Alaska Shorebird Group 2008). It is also a USFWS focal species and Bird 

of Conservation Concern, and is on the Audubon Society’s Watch List (Tessler et al. 

2007). 

Black oystercatchers are naturally rare, with a small global population; estimates range 

from 8,500 to 11,000 individuals rangewide (Goldstein et al. 2009). Habitat for black 

oystercatchers is rocky marine shorelines, where they forage for intertidal marine 

invertebrates, especially bivalves and other mollusks (Andres and Falxa 1995, Tessler et 

al. 2007). 

Black oystercatchers can be found in the Tongass National Forest (Goldstein et al. 2009). 

The population estimate for southeastern Alaska is 1,000 to 2,000 (Andres and Falxa 

1995). Severe declines of breeding pairs have occurred at Sitka Sound, approximately 80 

miles southwest of the project area (Goldstein et al. 2009). Northern southeast Alaska, 

which includes Admiralty Island, has 93 observations of black oystercatchers recorded 

between 1972 and 2003 (Tessler et al. 2007). Suitable habitat for black oystercatchers 

(rocky shorelines) is present in the vicinity of Hawk Inlet. 

3.12.3.5 Yellow-billed loon (Forest Service Sensitive / Federal Candidate) 

In March 2009, USFWS found that listing of the yellow-billed loon as threatened or 

endangered was warranted but precluded (74 FR 12932). A species action plan for the 

yellow-billed loon was released in November 2009 (USFWS 2009). The main threat to 

this species is illegal harvest, both in the U.S. and in Russia. Other possible, though 

likely insignificant threats, include commercial and subsistence fishing bycatch, 

environmental pollutants and contaminants, prey availability on wintering grounds, oil 

and gas development, and climate change (USFWS 2009). This species is also a Forest 

Service Sensitive-listed species. 

Yellow-billed loons are migratory, breeding in North America in the Arctic in northern 

Alaska, northern Northwest Territories, and Nunavut, and wintering along the coast of 

southwest Alaska, British Columbia, and in the Puget Sound. Nesting habitat is lowlying tundra near large lakes, usually near the coast (North 1994). These birds are 

usually solitary, but they may travel in groups during migration (USFWS 2010). 
Chapter 3. Affected Environment and Environmental Consequences

3-202 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

This species is not common and is distributed sparsely (North 1994; USFWS 2010), but it 

can be found throughout southeast Alaska during winter (October–March; North 1994, 

ALGW 2006). During a seabird survey in southeastern Alaska, only eight individuals 

were seen during winter, and one during summer along 15,600 miles of shoreline 

surveyed (Hodges et al. 2008). There are some records of this species on Admiralty 

Island (Dixon 1916). In the project area, this bird could be found in nearshore marine 

waters and inlets, such as Hawk Inlet (North 1994). 

3.12.3.6 Sensitive and Rare Plants 

Botanical surveys in the study areas proposed for development under all of the action 

alternatives were conducted in July and September 2010 and in July 2011. No sensitive 

plant species were found, although there is sphagnum bog, fen, and forested bog 

vegetation in the study area where these species potentially occur. Based on surveys, and 

the amount of potential habitat that could be disturbed, it was determined that the project 

may adversely impact individuals, but is not likely to result in a loss of viability in the 

study area, nor cause a trend toward federal listing. A separate biological evaluation for 

plants, including a Risk Assessment for Sensitive Plants, was developed and is available 

in the project record. 

Forest Service Natural Resource Information System records indicate 91 sensitive plant 

surveys have been conducted within the general Greens Creek Mine area. These include 

shorelines in Hawk Inlet and Young Bay, large areas of alpine and subalpine on ridges 

above the mine, and small scattered plots throughout the forest, meadows and muskegs 

(1981–2011): 20 of these occurred in or near the immediate project area between 1981 

and 2004. Records of University of Alaska Museum of Natural History Herbarium 

(UAMNH 2011) through 2010 do not report any sensitive or rare plants for the project 

area. During surveys for Alaska Region sensitive plants (Bosworth 2010) one rare plant, 

Malaxis paludosa (bog adder’s-mouth) was found near the existing TDF site. 

3.12.3.7 Pacific Herring, Southeast Alaska DPS (Forest Service Sensitive / 

Federal Candidate) 

NMFS received a petition to list the Lynn Canal stock of Pacific herring as threatened or 

endangered in 2007. NMFS rejected this petition on the grounds that the Lynn Canal 

stock was not determined to be a DPS during their review. However, NMFS initiated a 

status review for Southeast Alaska Pacific herring (a larger DPS of this species, and 

which also contains the Lynn Canal stock); this review ultimately resulted in this stock 

being designated as a candidate species under the ESA. 

Herring concentrate near the bottom (at 200 to 300 feet) off traditional spawning beaches 

in Lynn Canal during February and March. They then move into tidal shallows to 

commence spawning, which typically takes place over a 2- to 3-week period between late 

April and early May. After spawning, the adult herring return to deep-water areas in 

Lynn Canal, Stephens Passage, and the western shore of Douglas Island (Carlson 1980). 

Herring spawning typically takes place over nearshore habitat from mean higher high 

water to -40 feet, but typically +3 to -7 feet deep. 

Herring are one of the more abundant fishes along the coast of Alaska, although this 

abundance tends to be seasonal and varies tremendously from year to year. Pacific 

herring occur as juveniles within the marine waters of the study area; however, they are 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-203 

not known to spawn in this area (Monagle 2011). Important spawning areas are located 

north (e.g., Berners Bay and Auke Bay), as well as east of the project area (e.g., Oliver 

Inlet). 

3.12.4 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and 

Rare Plants – Environmental Consequences 

3.12.4.1 Effects Common to All Alternatives 

Under all alternatives, there would be some level of continued human activity occurring 

at the existing TDF, mine site, marine facility, and along the A and B roads. Thus, the 

potential for direct mortality and disturbance of wildlife associated with ongoing TDF 

operations would continue through the term of the lease. The large barges and ships that 

are used to haul the concentrate from the mine on a regular basis, as well as the crew 

shuttles, are not likely to affect marine mammal distribution in Young Bay, Hawk Inlet, 

or in Chatham Strait. While there have been no recorded humpback whale collisions 

with project-related vessels since the mine began operation in 1989, there is an existing 

potential for larger vessels (barges and ships used to haul concentrate in Hawk Inlet and 

Chatham Straight) and smaller vessels (crew shuttle operating from Young Bay through 

Stephens Passage) to collide with humpbacks. The potential for collision would continue 

for another 30–50 years under any action alternative. Increased sediment load in waters 

could increase the incidents of collisions with boats (NMFS 1991). Large vessels, such 

as the barges and ships used to haul the concentrate, typically operate at low, constant 

speeds and regular intervals. The crew shuttle transits Stephens Passage with two daily 

round trips. Although the crew shuttle operates at a higher speed than the larger vessels, 

the shuttles follow a regular course. The BA (Tetra Tech 2013) prepared for this EIS is 

summarized here and the following sections and includes adhering to the MMPA, ESA, 

and Forest Service Standards and Guidelines, NMFS regulations for approaching whales, 

and following the Alaska Marine Mammal Viewing Guidelines around other marine 

mammals such as harbor seals, sea lions, dolphins, and porpoise. All vessels are required 

to adhere to NMFS regulations governing the approach to humpback whales in Alaska 

(50 CFR 224.103(b)), which prohibit approaching within 100 yards of a humpback whale 

and require operating at a slow, safe speed when near a humpback whale. 

Under all alternatives, oil or fuel spills could occur as a result of vessel operations at the 

marine terminal in Hawk Inlet or at the dock in Young Bay. Spills could adversely 

impact threatened and endangered species foraging or moving through the shallow 

shoreline areas, particularly at the head of the inlet. Spill control plans and rapid 

response to spills would be the primary mitigation measures to avoid or minimize adverse 

spill effects to threatened and endangered species in the marine environment. 

Surface water runoff from the operation would continue to be collected, treated, and 

discharged into Hawk Inlet under all alternatives. As described in more detail in sections 

3.5, Water Resources – Surface Water, and 3.7, Aquatic Resources, discharge would be 

required to meet NPDES permit limits based upon Alaska WQS under all alternatives, 

thereby minimizing impacts to threatened and endangered species in the marine 

environment. However, some heavy metals accumulation in marine sediments is 

anticipated. In higher trophic level marine mammals or birds, bioaccumulation of heavy 
Chapter 3. Affected Environment and Environmental Consequences

3-204 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

metals has the potential to occur through transfer from prey though such impacts are 

unlikely due to the transient nature of these species in Hawk Inlet. The amount of 

discharge would remain consistent during operation, but at closure, with the suspension 

of mining activities, the volume of water treated and discharged would appreciably 

decrease, thereby reducing total metals discharge to the marine environment. However, 

due to the possibility of bioaccumulation, the longer the mine operates, the longer this 

slight risk exists (Forest Service 2003). Monitoring in Hawk Inlet will continue to be 

required by ADEC as long as there is a discharge. These requirements include 

monitoring of metals concentrations in sediments, water quality, and tissue within the 

mixing zone of the outfall. 

Humpback whale (Endangered) 

Impacts to humpback whales from the project could include collisions with watercraft, 

acoustic disturbance associated with continued boat use in the area, water pollution from 

spills of hazardous materials, and increased sediment load in waters which could increase 

the incidents of collisions with boats (NMFS 1991). Exposure of humpback whales to 

disturbance and noise associated with the Hawk Inlet marine terminal or the dock at 

Young Bay (crew shuttles) and the potential for fuel or oil spills would be unchanged 

from current levels. The project (regardless of the action alternative considered) would 

extend the time during which humpback whales could be potentially exposed to metal 

concentrations in prey due to project-related discharges into Hawk Inlet, oil or fuel spills, 

and vessel traffic. The extended operating period could lead to greater accumulations of 

metals in the marine environment. However, the NPDES permit (which places 

restrictions on the types, quantities, and extent of effluent discharges that are allowed to 

be discharged to waters) would limit the effects of the TDF discharge on water quality 

and vessels operations would be governed by regulations protecting humpback whales. 

Given the presence of this species in the marine waters affected by the project, the project 

(regardless of the action alternative considered) may have a minor effect on this species 

in Hawk Inlet, discharges of treated water under the NPDES permit would not be likely 

to adversely affect the humpback whale under any alternative. 

Steller sea lion (Eastern DPS-Threatened / Western DPS-Endangered) 

Impacts from the project to Steller sea lions could include noise and visual disturbance, 

injury or mortality, decreased fitness of adults if haul-outs are disturbed, decreased 

habitat quality due to pollutants and turbidity, disturbance to terrestrial haul-outs, and 

impacts to prey species. The intensity of exposure to disturbance and noise and the 

potential for fuel or oil spills would be unchanged from current operations; however, 

implementation of the project (regardless of the action alternative considered) would 

extend the time during which Steller sea lions are exposed to these impacts. The 

extended operating period due to TDF expansion alternatives would result in Stellar sea 

lions having the potential to continue to be exposed to noise and visual disturbance; 

metals in the marine environment; and hazards associated with vessel operations in Hawk 

Inlet, Young Bay, Chatham Straight, and Stephens Passage. However, the NPDES 

permit (which places restrictions on the types, quantities, and extent of effluent 

discharges that are allowed to be discharged to waters) would limit the effects of the 

project on water quality. Given the presence of this species in the marine waters affected 

by the project, the project (regardless of the action alternative considered) may have a 

minor effect on this species.
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-205 

Queen Charlotte goshawk (Forest Service Sensitive) 

An impact to Queen Charlotte goshawks from the project could include noise and visual 

disturbance. Individuals fleeing from a disturbance would use a greater amount of bodily 

energy reserves and lose foraging time. Raptors are particularly sensitive to disturbance 

during nesting and brooding. Incubating adults, when disturbed, could temporarily or 

permanently abandon nests, exposing eggs or chicks to predators and the elements, 

possibly resulting in mortality. Disturbance could also disrupt foraging and feeding of 

young, resulting in decreased chance of reproductive success. Large raptors such as 

goshawks generally breed later in life and have fewer clutches per season and fewer 

young per clutch than many other migratory birds; therefore, the loss of an egg, chick, or 

clutch due to disturbance would have a proportionately greater population-level impact 

than for other birds. Removal and degradation of productive old-growth would also 

reduce the amount of suitable nesting habitat for goshawks, including the potential loss of 

a nesting territory. An indirect effect associated with the loss of productive old-growth is 

the change in the abundance or makeup of available prey species. However, a range of 

habitats may provide suitable prey populations and be used by goshawks for foraging; 

therefore, no substantial alteration in goshawk prey is anticipated under any of the 

alternatives. 

Black oystercatcher (Forest Service Sensitive) 

An impact to this species from the project could include pollutants entering the water and 

washing up on their beach habitat; black oystercatchers were severely impacted by and 

are still recovering from the 1989 Exxon Valdez oil spill in Prince William Sound 

(Goldstein et al. 2009). Other potential impacts are noise and visual disturbance, which 

could flush birds from breeding and nesting grounds and increase energy expenditures 

and wakes from large ships. If personnel or vehicles use beaches, foraging habitat and 

prey populations could be affected, or nests destroyed. However, there are no large 

concentrations of black oystercatchers known to occur in Hawk Inlet; therefore, few 

individuals would be exposed to this risk and potential impacts would be minor.

Yellow-billed loon (Forest Service Sensitive / Federal Candidate) 

Yellow-billed loons may occur in the nearshore marine environment adjacent to the 

marine terminal in winter or during migration. Impacts to this species from the project 

could include: 

 noise and visual disturbance, which could cause birds to flush or move to a different 

area, using energy reserves and potentially causing them to utilize lower quality 

habitat, with the possible effect of lowering fitness; 

 effects on fresh- or salt-water habitats, for example siltation or pollution; 

 effects on water quality which could impact prey populations; and 

 increase of human presence in the area, which could cause increased illegal harvest, 

which at present levels is unsustainable and is one of the primary threats to this 

species (USFWS 2010).

Vessel traffic associated with the operation of the mine would not change in intensity, but 

would occur for a longer period, for another 30 to 50 years. In the event of a spill, the 

risk to yellow-billed loons would remain low because the birds typically occur at very 

low densities in southeast Alaska and therefore, few individuals would be at risk. 
Chapter 3. Affected Environment and Environmental Consequences

3-206 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Therefore, the project (regardless of the action alternative considered) may have a minor 

effect on this species. 

Sensitive Plants 

No sensitive plant species were found in the areas that would be impacted by the TDF 

alternatives, therefore no direct impacts to sensitive plant species would occur. However, 

moderate indirect impacts to habitats could occur from invasive species introduction and 

subsequent competition with native plants for habitat; and alteration in vegetation 

composition, hydraulic pattern, solar exposure, site characteristics, and organic litter 

composition. If any previously undiscovered sensitive plants are encountered at any time 

prior to or during construction and operations of the TDF under any alternative, they 

would be avoided to the extent possible and the Forest Service would be notified 

immediately to evaluate the population and recommend avoidance or mitigation 

measures. Adverse effects to rare plants vary between alternatives and are presented by 

alternative below. 

Pacific Herring, Southeast Alaska DPS (Forest Service Sensitive/ Federal 

Candidate) 

Impacts to Southeast Alaska DPS Pacific Herring from the TDF alternatives could 

include impacts due to the NPDES discharge and sedimentation into surface waters. 

These impacts could have both direct effects on herring, as well as indirect effects in the 

form of impacts to their prey base. Exposure to these risks would be unchanged from 

current levels; however, the action alternatives would extend the time frame in which 

these impacts could occur. Herring are not known to spawn in this area, but juveniles 

would be present (Monagle 2011); therefore, juveniles would be at risk of exposure to 

project-related water quality and sedimentation impacts. However, the NPDES permit 

(which places restrictions on the types, quantities, and extent of effluent discharges that 

are allowed to be discharged to waters) would limit the effects of TDF discharge on water 

quality. Therefore, impacts to Lynn Canal Pacific herring would be minor. 

3.12.4.2 Effects of Alternative A: No Action 

Effects under Alternative A would be the same as described in Section 3.12.4.1, Effects 

Common to all Alternatives. There would be some level of continued human activity 

occurring at the existing TDF, mine site, marine facility, and along the A and B roads. 

Thus, the potential for direct mortality and disturbance of wildlife associated with 

ongoing mine operations would continue for approximately three additional years. The 

consequences or likelihood of adverse effects to rare plants are low because no new rock 

quarries or material storage areas would be developed. 

3.12.4.3 Effects of Alternative B: Proposed Action 

Effects of Alternative B would be the same as described in Section 3.12.4.1, Effects 

Common to All Alternatives. Variations between the alternatives are due to differences 

in acres and types of habitat affected. There would be some level of continued human 

activity occurring at the existing TDF, mine site, marine facility, and along the A and B 

roads. Thus, the potential for direct mortality and disturbance of wildlife associated with 

ongoing mine operations would continue for approximately 30–50 additional years. 

Effects to Queen Charlotte goshawks are described for comparison between the 

alternatives. Queen Charlotte goshawks would be impacted by the removal and 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-207 

degradation of approximately 73 acres of productive old-growth, 30 acres of which are 

high volume/coarse canopy forest SD-5N, SD-5S, and SD-67 habitat under Alternative B. 

The level of reduction would not be expected to affect populations of these species in the 

study area given the remaining available habitat. No nests or sign of nesting activity 

were documented during the 2010 surveys in the vicinity of the existing mine and 

proposed expansion area under Alternative B. It is likely that the ongoing noise in the 

area precludes goshawks from actively nesting or foraging in the immediate vicinity of 

the mine. However, if a new goshawk nest were discovered in the vicinity of the existing 

TDF prior to implementation of Alternative B, Forest Service standards and guidelines 

for preserving nesting habitat and avoiding disturbance to nesting goshawks would apply 

through fledging of that year. The risk of adverse impacts to rare plants is high because 

Malaxis paludosa (bog adder’s-mouth) and its habitat are known to occur in the area 

proposed for expansion. 

3.12.4.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. 

Effects under Mitigated Alternative B would be the same as described in Section 

3.12.4.1, Effects Common to All Alternatives. There would be some level of continued 

human activity occurring at the existing TDF, mine site, marine facility, and along the A 

and B roads. Thus, the potential for direct mortality and disturbance of wildlife 

associated with ongoing TDF operations would continue for approximately 30–50 

additional years. Queen Charlotte goshawks would be impacted by the removal and 

degradation of approximately 64 acres of productive old-growth, 27 acres of which are 

high volume/coarse canopy forest SD-5N, SD-5S, and SD-67 habitat under Mitigated 

Alternative B. The level of reduction would not be expected to affect populations of 

these species in the study area given the remaining available habitat. No nests or sign of 

nesting activity were documented during the 2010 surveys in the vicinity of the existing 

mine and proposed expansion area under Mitigated Alternative B. It is likely that the 

ongoing noise in the area precludes goshawks from actively nesting or foraging in the 

immediate vicinity of the mine. Similar to Alternative B, if a new goshawk nest were 

discovered in the vicinity of the existing TDF prior to implementation of Alternative B, 

Forest Service standards and guidelines for preserving nesting habitat and avoiding 

disturbance to nesting goshawks would apply through fledging of that year. The risk of 

adverse impacts to rare plants is high because Malaxis paludosa (bog adder’s-mouth) and 

its habitat are known to occur in the area proposed for expansion. 

3.12.4.5 Effects of Alternative C: TDF Located Outside of Monument 

Effects under Alternative C would be the same as described in Section 3.12.4.1, Effects 

Common to All Alternatives. There would be some level of continued human activity 

occurring at the current TDF, mine site, marine facility, and along the A and B roads. 
Chapter 3. Affected Environment and Environmental Consequences

3-208 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Thus, the potential for direct mortality and disturbance of wildlife associated with 

ongoing mine operations would continue for approximately 3 years at the existing TDF 

and an additional 30–50 years at the new TDF. Queen Charlotte goshawks would be 

impacted by the removal and degradation of approximately 114 acres of productive oldgrowth, 30 acres of which are high volume/coarse canopy forest SD-5N, SD-5S, and SD67 habitat under Alternative C. Expanding operations would increase the scope of this 

disturbance somewhat. The active nest located in 2011 adjacent to the new TDF 

proposed under Alternative C may require a non-significant Forest Plan Amendment 

should that nest remain active at the time of construction (in the next 3–5 years under 

Alternative C). Currently, Forest Plan Standards and Guidelines will apply to reduce any 

disturbance during the nesting season. If Alternative C is selected, the ROD will include 

a significance analysis for the Forest Plan Amendment. The risk of adverse impacts to 

rare plants is moderate because Malaxis paludosa (bog adder’s-mouth) or its habitat may 

occur in the area proposed for expansion adjacent to the existing TDF or the alternative 

TDF site. 

3.12.4.6 Effects of Alternative D: Modified Proposed Action 

Effects under Alternative C would be the same as described in Section 3.12.4.1, Effects 

Common to All Alternatives. There would be some level of continued human activity 

occurring at the existing TDF, mine site, marine facility, and along the A and B roads. 

Thus, the potential for direct mortality and disturbance of wildlife associated with 

ongoing mine operations would continue for approximately 10 years at the existing TDF 

and an additional 40 years at the new TDF. Queen Charlotte goshawks would be 

impacted by the removal and degradation of approximately 115 acres of productive oldgrowth, 37 acres of which are high volume/coarse canopy forest SD-5N, SD-5S, and SD67 habitat under Alternative D. Expanding operations would increase the scope of this 

disturbance somewhat. The active nest located in 2011 adjacent to the new TDF 

proposed under Alternative D may require a non-significant Forest Plan Amendment 

should that nest remain active at the time of construction (12 years under Alternative D). 

Currently, Forest Plan Standards and Guidelines will apply to reduce any disturbance 

during the nesting season. If Alternative D is selected, the ROD will include a 

significance analysis for the Forest Plan Amendment. The risk of adverse impacts to rare 

plants is moderate because Malaxis paludosa (bog adder’s-mouth) or its habitat may 

occur in the area proposed for expansion adjacent to the existing TDF or the alternative 

TDF site. 

3.12.5 Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and 

Rare Plants – Summary 

Under all alternatives, there would be some level of continued human activity occurring 

at the existing TDF, mine site, marine facility, and along the access road. Thus, the 

potential for direct mortality and disturbance of marine and terrestrial wildlife and plant 

species and their habitat associated with ongoing mine operations would continue to 

some extent for all alternatives. The large barges and ships that are used to deliver fuel 

and equipment and haul the concentrate from the mine, as well as the crew shuttle 

transiting Young Bay would continue but are not likely to adversely affect marine 
3.12 Threatened, Endangered, Candidate, and Forest Service Alaska Region Sensitive Species and Rare Plants 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-209 

mammal distribution in Hawk Inlet, Young Bay, Stephens Passage, or Chatham Strait. 

Although these impacts are common to all alternatives, the duration of effects differs by 

alternative. Operation of the mine would continue until 2019 under Alternative A. 

However, all action alternatives would extend the operating period of the mine for an 

additional 30 to 50 years. Therefore, reclamation of the mine site and reductions in levels 

of human activity, water quality impacts, fugitive dust emissions, and marine traffic 

would occur more quickly under Alternative A than the action alternatives. 

Under all alternatives, oil or fuel spills could occur as a result of vessels at the marine 

terminal in Hawk Inlet or at the dock in Young Bay. Spills could adversely impact 

threatened and endangered species foraging or moving through the shallow shoreline 

areas, particularly at the head of the inlet. Spill control plans and rapid response to spills 

would be the primary mitigation measures to avoid or minimize adverse spill effects to 

threatened and endangered species in the marine environment. 

TDF seepage and surface water runoff would continue to be collected, treated, and 

discharged into Hawk Inlet under all alternatives. Discharge would continue to be 

required to meet Alaska WQS under all alternatives, thereby minimizing impacts to 

threatened and endangered species in the marine environment. However, some heavy 

metals accumulation in marine sediments is anticipated. In higher trophic level marine 

mammals or birds, bioaccumulation of heavy metals has the potential to occur through 

transfer from prey though such impacts are unlikely due to the transient nature of these 

species in Hawk Inlet. The amount of discharge would remain consistent during 

operation, but at closure, with the suspension of mining activities, the volume of water 

treated and discharged would appreciably decrease, thereby reducing total metals 

discharge to the marine environment. Therefore, the longer the mine operates, the longer 

this slight risk exists (Forest Service 2003). 

Reduction in productive old-growth may affect goshawk habitat across all action 

alternatives ranging from approximately 73 acres under Alternative B to 115 acres under 

Alternative D. Slightly more high volume/coarse canopy forest (SD-5N, SD-5S, and SD67) would be removed under Alternative D (37 acres) followed by Alternative B (30 

acres), Alternative C (30 acres), and Mitigated Alternative B (27 acres). The level of 

reduction would not be expected to affect populations of these species in the study area 

given the remaining available habitat. 

A BA was prepared for this EIS which analyzed potential impacts for all threatened and 

endangered species that have the potential to occur within or near the project. A 

determination of “no effect” is rendered in regard to all threatened and endangered 

species with the exception of the humpback whale and Steller sea lion where a “not likely 

to adversely affect” call was made. In addition, seven species listed as Forest Service 

Sensitive received a “may impact individuals but not likely to cause a trend to federal 

listing or a loss of viability” and include Queen Charlotte goshawk, black oystercatcher, 

yellow-billed loon (also a federal candidate), Southeast Alaska DPS Pacific herring, and 

the three sensitive plant species Cypripedium montanum, Cypripedium parviflorum var. 

pubescens, and Piperia unalascensis with the remainder receiving a “no impact” 

determination (Table 3.12-2). The risk, consequence, and likelihood of adverse affects to 

the rare plant Bog adder’s-mouth are low for Alternative A, high for alternatives B and 

Mitigated B; and moderate for alternatives C and D. 
Chapter 3. Affected Environment and Environmental Consequences

3-210 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

All activities proposed will adhere to the MMPA, ESA, and Forest Service Standards and 

Guidelines, NMFS regulations for approaching whales, and follow the Alaska Marine 

Mammal Viewing Guidelines around other marine mammals such as harbor seals, sea 

lions, dolphins, and porpoise, this includes maintaining a minimum approach distance of 

100 yards and traveling at a slow constant speed when near a humpback whale. BMPs 

would continue to apply for all activities in marine waters including Spill Prevention 

Control and Countermeasures and rapid response to spill plans. The Forest Plan provides 

standards and guidelines to maintain nesting habitat for the Queen Charlotte goshawk.

3.13 Land Use __________________________________ 

The Tongass National Forest Land Use Management Plan (Forest Service 2008a) 

provides direction for managing use of the national forest lands. The plan assigns land 

use designations (LUDs) to each part of the forest, which give general direction on the 

types of land uses and activities that can occur in each area, referred to as management 

prescriptions. The management prescriptions for each LUD list goals, objectives, and the 

desired condition for each LUD, as well as standards and guidelines for managing 

specific resources within the LUD. The plan also provides forest-wide standards and 

guidelines that apply to all LUDs. 

Figure 3.13-1 indicates the LUDs assigned to the study area. The northwestern portion of 

the existing tailings facility, the cannery site, the Young Bay landing dock, the A Road 

from the dock to the cannery, and a portion of the B Road from the cannery to the 

existing tailings area all lie within the Semi-Remote Recreation LUD. The remaining 

mine facilities are located within the Non-Wilderness National Monument LUD. The 

intent of the Semi-Remote Recreation LUD emphasizes predominantly natural or naturalappearing settings for semi-primitive recreation, but allows for mineral exploration and 

development. The Non-wilderness National Monument LUD also allows for 

development of mineral resources, as long as effects to non-mineral resources are 

minimized to the extent feasible and areas disturbed by mining are reclaimed to a nearnatural condition. The plan of operations for the mine must specify the activities to be 

conducted, the location and timing of those activities, and how the environment and 

resources of the area will be protected through compliance with federal and state 

requirements. 

Figure 3.13-1 also shows the extent of the inventoried roadless areas (IRAs) within the 

study area. Construction or reconstruction of roads is generally prohibited in IRAs, as is 

cutting or removal of timber. Paragraph (b)(3) (of the Roadless Rule) permits the 

construction and reconstruction of a road pursuant to rights granted in statute or treaty, or 

pursuant to reserved or outstanding rights. Such road construction must be conducted in 

a manner that minimizes effects on surface resources, prevents unnecessary surface 

disturbance, and complies with all applicable lease requirements, land and resource 

management plan direction, regulations, and laws. Mine-related roads must be reclaimed 

after completion of mining (36 CFR 294). Section 3.20 addresses IRAs in more detail. 
3.13 Land Use 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-211 

Figure 3.13-1. Land Use Designations. 
Chapter 3. Affected Environment and Environmental Consequences

3-212 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.13.1 Land Use – Pre-mining Environment 

The Greens Creek Mine is located within the watersheds 

of Greens, Zinc, Cannery, Tributary, and Fowler creeks 

on the northern portion of Admiralty Island. The mine 

lies partially within the Monument. Northern Admiralty 

Island and Hawk Inlet have historically been used by 

Tlingit individuals for subsistence activities (Section 

3.16, Subsistence, and Section 3.17, Cultural Resources). 

Commercial fishing and recreational activities, including 

sport fishing, hunting, and boating, have also occurred in 

the area (Section 3.15, Recreation). The area was first 

developed for commercial use in 1914 with construction 

of the Hawk Inlet Fish Cannery. Mining activities at the Greens Creek Mine site began 

in the mid-1970s when exploration work commenced, with full-scale development 

initiated in 1989. The mine has operated continuously for all but three of the years since 

1989. 

3.13.2 Land Use – Baseline Conditions 

Land use in the study area is similar to what it was during the pre-mining period, with the 

exception of the current mine facilities. The area is still used for recreation, commercial 

fishing, and subsistence activities, although recreational use of Hawk Inlet has increased 

since the 1980s (Kiesel 2011). There are several recreation cabins along Wheeler Creek 

and floating cabins in Hawk Inlet, which are described in Section 3.15, Recreation. Most 

of the recreation use occurs on the waters or shoreline of Hawk Inlet, but deer hunting is 

also a popular activity throughout the upland areas, except within the mine site. The 

historic cannery site has been restored and incorporated into the mine facilities, providing 

a cafeteria, housing, and offices for mine personnel. 

The Greens Creek Mine TDF currently occupies 49 acres of land leased from the Forest 

Service and 15 acres of private land. The private land consists of the former cannery site, 

including the floatplane dock and concentrate loading facility. The current approved 

TDF will disturb a total of 65 acres at final build-out, of which approximately 37 acres lie 

within the Monument. 

3.13.3 Land Use – Environmental Consequences 

3.13.3.1 Effects Common to All Alternatives 

Potential impacts to land use within the project area would include effects to recreation 

activities, subsistence uses, and commercial fishing, and disturbance of the immediate 

project site. Effects to recreation and subsistence activities are discussed in Sections 3.15 

and 3.16 respectively. Effects to commercial fishing would be limited to the effects on 

aquatic resources discussed in Section 3.7. 

Adverse impacts to land use under all of the alternatives would be the disturbance of 

additional acreage for development of the TDF. Table 3.13-1 compares the expected 

disturbance within and outside the Monument resulting from each alternative. 

Alterations to the vegetative cover are addressed in Section 3.10, Vegetation. After 

The resource analysis of 

land use is related to 

Issue 4, Monument related 

concerns. Measures of 

impacts to the Monument 

include acres of disturbance 

related to the construction 

and expansion of the TDF. 
3.13 Land Use 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-213 

completion of mining, the water treatment plant and electric lines would remain in place 

and the slopes of the TDF would remain at a 3:1 (H:V) slope under all of the alternatives. 

All other facilities would be decommissioned and removed, and surface contours 

conducive to revegetation or other post-mining use would be established. Disturbed 

areas will be reclaimed to one of three vegetation types, including upland meadows, 

upland forest, or wetlands. Natural re-vegetation would be the primary method of forest 

re-vegetation. Eventually, the area would be opened to the public for hunting and other 

public uses when most reclamation is complete, the lands are returned to the National 

Forest System and it is determined safe to do so. Once natural forest cover was reestablished, the LUD management prescriptions would be met under all of the 

alternatives, since revegetation would allow the project area to return to a near-natural 

condition. 

Table 3.13-1. Disturbance Inside and Outside the Monument by Alternative. 

 New Disturbance 

within/outside Monument

Total Disturbance within/outside 

Monument (acres)

Alternative A 0 / 0 37/27 

Alternative B 104/24 137/44 

Mitigated Alternative B 83/43 106/60 

Alternative C 18/156 42/182 

Alternative D 31/154 60/185 

3.13.3.2 Effects of Alternative A, No Action 

Under Alternative A the existing TDF would reach its currently approved size and 

configuration by year 2019. Alternative A would not authorize any new disturbances 

associated with tailings disposal and would result in fewer acres of disturbed land within 

the Monument than any of the other alternatives. After completion of mining, 

reclamation would restore the area to a near-natural condition. 

3.13.3.3 Effects of Alternative B, Proposed Action 

Alternative B would require expanding the TDF, reclamation material storage areas, 

quarries, water management ponds, roads; truck wheel wash facility; and ultimately 

relocating of the water treatment plant. The expanded TDF would be developed adjacent 

to the existing TDF, extending into the undeveloped lands to the south. After completion 

of mining in 30–50 years, reclamation efforts to restore the site to near-natural vegetative 

conditions would begin, with the regeneration of native forest cover expected to take an 

estimated 50 to 100 years. Under alternative B, the total new disturbance footprint would 

be 87 percent within the Monument. 

Material would be placed in the TDF in four phases, which would limit the area of 

disturbance to areas immediately ahead of tailings placement. Hydroseeding and other 

interim reclamation measures in the completed areas would reduce the amount of contrast 

with the surrounding landscape to the extent practical. 
Chapter 3. Affected Environment and Environmental Consequences

3-214 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.13.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Under 

Mitigated Alternative B, the total new disturbance footprint would be 68 percent within 

the Monument. 

3.13.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Under Alternative C a new TDF would be developed north of the A Road within the 

Semi-Remote Recreation LUD on the Juneau Ranger District as a means to minimize 

additional disturbance within the Monument. This alternative would have the adverse 

effect of extending the TDF to a portion of the forest that is currently undisturbed and 

open for public use. A rock quarry and reclamation materials stockpile would also need 

to be constructed for the new TDF and the A Road would be improved to accommodate 

the tailings transport. Tailings generated during the 3–5 years required for construction 

of the new TDF would be placed within the existing TDF and increasing the height of the 

existing TDF by approximately 3 feet. Under Alternative C, the total new disturbance 

footprint would be 3 percent within the Monument. 

As with the other alternatives, the area would be restored to a near-natural condition after 

completion of mining. 

3.13.3.6 Effects of Alternative D, Modified Proposed Action 

The effects of Alternative D would be similar to those of Alternative C in that 

construction of a new TDF north of the A Road would reduce disturbance of Monument 

lands, but would introduce tailings and construction activity to a previously undisturbed 

portion of the forest within the Semi-Remote Recreation LUD on the Juneau Ranger 

District. The existing TDF would be expanded to allow for an additional 10 years of 

tailings placement. Under Alternative D, the total new disturbance footprint would be 12 

percent within the Monument. 

The new TDF to the north would be constructed to accommodate tailings disposal for the 

remainder of the life of the mine. This alternative would have less adverse impacts to 

Monument lands than Alternative B and Mitigated Alternative B and more than 

Alternative C as shown in Table 3.13-1. 
3.14 Scenic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-215 

3.13.4 Land Use – Summary 

Land use outside the immediate project vicinity consists of recreation, subsistence 

activities and commercial fishing. Effects on these resources are discussed in sections 

3.15, 3.16, and 3.17, respectively. Land use within the immediate project site is currently 

dominated by the existing mine facilities, which will continue under Alternative A until 

2019 when project closure and reclamation will begin. Under the action alternatives, 

land use of the project vicinity would continue to be dominated by mining until the 

beginning of reclamation in 30–50 years. Any of the action alternatives would increase 

the extent of disturbed areas both within and outside the Monument. Of the action 

alternatives, Alternative B would disturb the largest amount of land within the Monument 

and Alternative C would have the least effect on Monument land. Alternative C would 

introduce a new land use north of the current mine site by constructing a new TDF to the 

area north of ‘A’ Road, dispersing the land use effects to a new part of the forest. Under 

Alternative D tailings would be placed within the existing TDF for the first 10 years of 

the project, after which it will be placed in the new TDF, and thus would also introduce a 

new land use in this area. All of the alternatives will meet the management prescriptions 

for the Semi-Remote Recreation and Non-Wilderness National Monument LUDs as long 

as the TDF disturbed areas are reclaimed to a near-natural condition. Given current 

reclamation technologies included in the reclamation plan, it is expected that all the TDF 

alternatives can be reclaimed to meet this goal. 

3.14 Scenic Resources ___________________________ 

3.14.1 Scenic Resources – Pre-mining Environment 

Prior to mining, the visual condition of the study area 

was predominantly natural in appearance, except for 

the presence of the historic cannery facility, which had 

been gutted by fire and was in disrepair. There were 

also several floating houses in Hawk Inlet and cabins 

along Wheeler Creek. The visual variety of the 

Admiralty Island shoreline and ridgelines was 

classified as distinctive, whereas much of the 

remaining landscape was classified as common variety 

class due to the relatively uniform expanses of 

coniferous forest. The cannery area was classified as 

minimal variety class due to the evidence of past human activities (Forest Service 1983). 

3.14.2 Scenic Resources – Baseline Conditions 

The following discussion of baseline conditions is based on new methodology and 

terminology adopted by the Forest Service in 1995, “Landscape Aesthetics, A Handbook 

for Scenery Management” and incorporated into the Tongass National Forest planning 

process with adoption of the 2008 Forest Plan. Since the discussion references the 1983 

and 2003 EIS documents, which were based on the former methodology, the outdated 

terminology is listed in parentheses where replaced by new terms. 

The analysis of scenic 

resources was not identified 

as a significant issue, however 

it is related to Issue 4, 

Monument related concerns. 

Measures of impacts to the 

Monument include changes to 

visual integrity.
Chapter 3. Affected Environment and Environmental Consequences

3-216 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.14.2.1 Landscape Character 

The Greens Creek Mine is situated within the Pacific Coastal Mountains Ecological 

Subregion of the United States. The landscape is dominated by rugged glaciated 

mountains with deep V-shaped and U-shaped valleys. The landscape is known for its 

meandering shorelines and islands, with numerous bays and coves. A system of seaways 

separates the many islands and provides a protected waterway for ferries and cruise ships. 

A relatively uniform canopy of Sitka spruce and western hemlock forest dominates the 

lower elevations, interrupted by pocket clearings of meadows, muskegs, and lakes. 

Higher elevations are dominated by low-growing alpine tundra vegetation, with high 

ridges and steep, rocky cliffs (Forest Service 1994). Human modifications are not highly 

visible within much of this subregion, which is predominantly natural in appearance. 

The landscape character as seen from Hawk Inlet is dominated by the densely forested 

ridges and valleys of the Greens Creek drainage and the level plains and foothills along 

the shoreline. High forested ridges and numerous bodies of water form a repetitive 

pattern in the landscape surrounding the mine site (Forest Service 2003). Figure 3.14-1 

illustrates the existing conditions as seen from Hawk Inlet looking towards the existing 

mine facilities. Figure 3.14-2 illustrates the existing character of the study area as seen 

from the northern portion of Hawk Inlet. 

The visual absorption capability is the ability of the landscape to accept human 

alterations without loss of character or scenic quality. Visual absorption capability is 

influenced by natural conditions such as soil color, vegetation patterns, and slope. The 

study area has a relatively low to moderate visual absorption capability. Its light-colored 

soils and relatively uniform forest cover make openings more apparent than areas with 

intermittent forest cover, but the area’s deep valleys and vegetation density make it easier 

to screen (or hide) facilities, thus giving the area a low to moderate visual absorption 

capability. 

3.14.2.2 Existing Scenic Integrity (Existing Visual Condition) 

The existing scenic integrity describes the degree of human disturbance specific to the 

study area and is measured on a scale from Very Low to Very High, in which Very High 

represents areas unaltered by human actions and Very Low represents areas of drastic 

landscape disturbance. Within the Hawk Inlet viewshed, the existing TDF and cannery 

site are the most dominant human alterations. Most of the other mine facilities are not 

visible from the inlet. The existing TDF creates a horizontal line devoid of vegetation, 

contrasting with the sloping topography. The light color of the soil and tailings material 

contrasts sharply with the deep green of the surrounding forest. The view from Hawk 

Inlet would be classified as a moderate Existing Scenic Integrity because the TDF is seen 

as a major, human-caused deviation in the view, but the TDF’s size relative to the 

surrounding shoreline and ridgelines allow it to remain subordinate to the view as a 

whole. 
Greens Creek Mine Tailings Disposal Facility Expansion EIS Figure 3.14-1. Existing View of Mine Facilities from Hawk Inlet. Figure 3.14-2. Existing View from Northern Portion of Hawk Inlet. 
Chapter 3. Affected Environment and Environmental Consequences

3-218 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.14.2.3 Site Visibility and Concern Level (Sensitivity Level) 

For purposes of the Scenic Resource analysis, Hawk Inlet is considered a Visual Priority 

Travel Route and Use Area (VPR), because the Forest Plan designates the inlet as a small 

boat route and identifies three small boat anchorages in the inlet (see Section 3.15, 

Recreation). Hawk Inlet and its shoreline are used by residents and non-residents of 

Alaska for recreational activities, such as fishing, hunting, boating, and wildlife viewing. 

There are also six privately-owned floating cabins on the inlet, used by local residents as 

a base for hunting, fishing, and other recreational activities. Chatham Strait is also 

considered a VPR due to the Alaska Marine Highway corridor. 

The existing TDF is situated within the foreground and middleground view from Hawk 

Inlet. The only VPR with a background view (over 4 miles) of the project area is from a 

small portion of Chatham Strait as one looks up the inlet. The region’s coniferous 

vegetation, however, reduces seasonal variation by maintaining the potential for 

vegetative screening throughout the year. 

The Forest Service rates the relative scenic importance of certain views, or the concern 

level, on a scale of 1 to 3 with 1 having the greatest sensitivity or level of concern. 

Concern levels are based on the visibility from VPRs, the distance zone of the view from 

the VPRs (foreground, middleground, or background), and the level of interest people are 

likely to have for scenery. The existing TDF would be rated as Level 1 (High Level of 

Concern) because of its location within the foreground and middleground view from the 

Hawk Inlet VPRs and use of the inlet by recreationists and tourists, many of whom visit 

the area for its scenic attributes and wildlife viewing. 

3.14.2.4 Scenic Attractiveness and Scenic Classes (Variety Class) 

The scenic attractiveness rating (Class A, B, or C) is determined by considering the 

inherent attributes and distinctiveness of the landscape, such as landform patterns and 

features, water features, vegetation patterns, land use, and cultural features. The 

Admiralty Island shoreline is considered Class A, or distinctive scenic attractiveness 

rating, because of the visual variety created by the meandering shoreline. Most of the 

remaining areas surrounding the mine would be considered Class B, or typical scenic 

attractiveness rating, because of the large, relatively uniform expanses of coniferous 

forest (Forest Service 1983). The existing TDF and cannery facility would be considered 

Class C because of the extent of human disturbance and the contrasts with natural forms 

and colors. 

The Forest Service classifies portions of the forest in terms of their scenic class as a way 

to measure the relative value of a particular landscape as scenery. The landscape’s scenic 

attractiveness and level of concern combine to determine its scenic class. The landscape 

as seen from Hawk Inlet would be considered a Scenic Class of 1 on a scale of 1 to 7 with 

1 being the highest, except for the existing TDF and cannery site, which would be a 

Scenic Class 2. The Class 1 rating is a result of the Class A and B attractiveness ratings 

combined with its visibility and high level of concern when viewed from the inlet’s 

VPRs. The Class 2 rating of the existing TDF and cannery site is a result of the Class C 

attractiveness rating combined with the visibility and high level of concern when viewed 

from Hawk Inlet. 
3.14 Scenic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-219 

3.14.3 Scenic Resources – Environmental 

Consequences 

The Forest Service establishes scenic integrity objectives (SIOs), formerly referred to as 

visual quality objectives, for maintaining scenic resources for each LUD. The SIOs are 

established relative to their visibility from VPRs, and thus activities that are visible in the 

foreground from VPRs must often meet a higher standard than activities in the 

middleground or background distance zones. 

Effects of the alternatives on scenic resource are evaluated in terms of their ability to 

conform to the SIOs for the Semi-Remote Recreation LUD and the Non-Wilderness 

National Monument LUDs. Lands within the Semi-Remote Recreation LUD are to be 

managed to meet the Moderate SIO as seen from all distance zones. Under the Moderate 

SIO, the landscape character may appear slightly altered, and resource activities are to be 

designed to remain visually subordinate to the characteristic landscape. Noticeable 

deviations to the landscape character are acceptable, but new form, line, color, or texture 

must remain visually subordinate. Exceptions for small areas of non-conforming 

developments, such as mining facilities, may be considered in this LUD on a case-bycase basis. 

SIOs for the Non-Wilderness National Monument LUDs range from High in remote areas 

to Very Low for lands developed for mining, provided site specific SIOs and 

rehabilitation objectives are identified in the mine’s Plan of Operations. The Very Low 

SIO is classified as a “heavily altered” landscape, where activities may strongly dominate 

the landscape character, but must have visual characteristics similar to those of natural 

occurrences within the surrounding area. Site-specific SIOs are to be identified in the 

Plan of Operations for mineral development areas (Forest Service 2008a). 

3.14.3.1 Effects Common to All Alternatives 

Since Hawk Inlet is a designated VPR, used for boating, fishing and other recreation 

activities, this section focuses primarily on views of the proposed alternatives from the 

inlet. Views from inland areas are considered, since dispersed recreation activities (such 

as deer hunting) occur throughout Admiralty Island. Views from the air are also of 

concern because hunters, cabin owners, and tourists often access the area by air. 

Under all of the alternatives, portions of the TDF would be visible from Hawk Inlet, as 

well as from the air and from some of the dispersed inland recreation areas. The 

visibility of the project area from Hawk Inlet and Chatham Strait was determined by 

preparing viewshed maps from a series of points along Hawk Inlet and one point within 

Chatham Strait at the mouth of Hawk Inlet. The results of the viewshed analysis indicate 

that the project area for the proposed expansion of the existing TDF would be visible for 

a distance of approximately 4.5 miles along the Hawk Inlet Small Boat Route, extending 

from the mouth of Hawk Inlet to a point approximately 1.7 miles north of the cannery site 

(Figure 3.14-3). In addition, a boat travelling up the center of Chatham Strait would have 

a limited view of the site for a distance of approximately 2 miles if one was looking 

directly up Hawk Inlet. The view from the center of Chatham Strait would be a 

background view, approximately 6 to 7 miles from the project area. Figure 3.14-2 shows 

the portions of Hawk Inlet with views of the proposed new TDF, consisting primarily of 

the head of the inlet and the area immediately to the south. 
Chapter 3. Affected Environment and Environmental Consequences

3-220 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.14-3. Viewshed Analysis Points with Views of Proposed Expansion of Existing 

TDF (Alternatives A–D). 
3.14 Scenic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-221 

Effects to the view as seen from Hawk Inlet resulting from each alternative were 

evaluated by selecting key viewpoints from which photo simulations were developed 

(figures 3.14-3 and 3.14-4). Viewpoints were selected by developing cross sections from 

a series of points within Hawk Inlet to identify locations with the most expansive view of 

the tailings facility. The simulations are shown on figures 3.14-5, 3.14-6, and 3.14-7. 

Each alternative would create additional contrast with the surrounding landscape by 

expanding contrasting light grey color, geometric forms, and finer texture of the TDF, as 

compared to the adjacent forest. The scenic integrity level resulting from all of the 

alternatives would remain classified as Moderate during operation, because the visual 

contrasts created by the facility would be visible as human-caused deviations from the 

surrounding forest, but the contrasts would remain subordinate within the overall view 

from Hawk Inlet. The scenic attractiveness of the TDF would remain a Class C due to 

the continued contrasts with natural forms and colors. The Scenic Class 2 would also be 

maintained under all the alternatives, a result of the Class C scenic attractiveness rating 

and the high level of concern and visibility from Hawk Inlet. 

After completion of the project all project buildings and infrastructure would be removed, 

except for some access roads, the water treatment facility and pipeline, and power lines. 

The TDF and associated disturbances would be reclaimed to one of three vegetation 

types, including upland meadows, upland forest, or wetlands. Natural forest regeneration 

will be the primary method of forest re-vegetation. The final contours of the TDF would 

be developed during construction at a slope of 3H:1V. As native species become 

established over time, the degree of contrast in color would gradually decrease. During 

the first 5 years after closure, the light green color of the herbaceous plant growth would 

reduce color contrasts, but the TDF would still be visible against the surrounding forest. 

Woody plants would be established within the next 10 years, which would further reduce 

color contrasts. The regeneration of spruce and hemlock during years 15 through 30 

would eliminate color contrasts, but the area would still be visible due to the younger age 

and lower canopy height of the forest cover. After approximately 30 years the 

revegetated facility would blend in with the surroundings, although the geometric form of 

the TDF would be visible as a contrast with the adjacent topography (Forest Service 

2003). Once the natural forest cover is established, the scenic integrity of the TDF would 

be classified as High because the only deviation from the surroundings would be the 

geometric form of the tailings pile. 

The Very Low SIO designated for the Non-Wilderness National Monument LUD would 

be met during project operation, since this SIO allows the landscape to appear “heavily 

altered.” The Moderate SIO for the Semi-Remote Recreation LUD would also be met 

during project operation because noticeable deviations to the landscape character are 

allowed within this LUD, are areas of non-conforming development, such as mines. 

After project completion, the Moderate SIO within the Semi-Remote Recreation LUD 

would continue to be met. 
Chapter 3. Affected Environment and Environmental Consequences

3-222 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.14-4. Viewshed Analysis Points with Views of Proposed New TDF 

(Alternatives C–D).
Greens Creek Mine Tailings Disposal Facility Expansion EIS Figure 3.14-5. Alternative A: Photo-Simulation from Hawk Inlet showing Approved TDF Expansion at Maximum Height Figure 3.14-6. Alternative B: Photo-Simulation from Hawk Inlet showing Alternative B TDF Expansion at Maximum HeiFigure 3.14-7. Alternative C: Photo-Simulation from Hawk Inlet showing Alternative C New TDF at Maximum Height be
Chapter 3. Affected Environment and Environmental Consequences

3-224 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The SIO within the Non-Wilderness National Monument LUD would likely be changed 

from Very Low to High once mining is completed and reclamation begins. The higher 

standard would be met after regeneration of native tree species, since the visual 

characteristics of the TDF would be similar to natural conditions in the surrounding 

forest. 

Mitigation measures required as part of these SIOs include selecting materials and colors 

that blend with the natural surroundings, designing rock sources to be minimally apparent 

as seen from VPRs, and keeping vegetation clearing to a minimum and within close 

proximity to the site. Maintaining vegetative screening between the tailings and ancillary 

facilities and Hawk Inlet would mitigate adverse scenic impacts. Mitigation measures 

within Non-Wilderness National Monument LUD call for the use of naturally established 

form, line, color, and texture. Deviations must be shaped and blended with the natural 

terrain so that elements such as unnatural edges, roads, landings, and structures do not 

dominate the composition. 

3.14.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. The TDF would 

continue to be built out to the maximum footprint and height permitted in the 2003 EIS 

(Forest Service 2003). After the TDF is fully built out to its final elevation (in 2019), 

reclamation is required to be initiated as described in the 2003 EIS and Waste 

Management Permit within three years (Forest Service 2003, Waste Management Permit 

0211-BA001). 

The existing TDF would reach its currently approved elevation of 363.7 feet, which 

would continue to be visible to recreationists in Hawk Inlet (Figure 3.14-5). Under 

Alternative A, the reclamation and natural revegetation process would begin in the year 

2019, earlier than with the other alternatives, with the forest cover reaching its mature 

height approximately 100 years after mine closure. 

3.14.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. 

Alternative B would be visible in the foreground and middleground view from much of 

Hawk Inlet, extending from the mouth of Hawk Inlet to a point approximately 4.5 miles 

north of the mouth. The sloping topography and vegetation along the shore would block 

views from much of the eastern side of Hawk Inlet, thus blocking much of the foreground 

view of the tailings. This alternative would require construction of a new access road, the 

West Road, between Hawk Inlet and the existing TDF. Although much of this road 

would be screened by the ridgeline to the west, portions of it would be visible from Hawk 

Inlet, particularly the portion between the cannery and the top of the ridge. 

The existing TDF under Alternative B would increase to a maximum of 403.8 feet (msl), 

40.1 feet higher than the approved TDF. The TDF would expand southward, increasing 

the width of the TDF as seen from Hawk Inlet by about 80 percent over the approved 

width. This alternative would maintain the view of disturbance within one location as 

seen from Hawk Inlet, compared to alternatives C and D. 
3.14 Scenic Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-225 

Figure 3.14-6 illustrates the TDF at its maximum height and width at the end of mine 

operations in 30–50 years. The TDF under Alternative B would create a strong contrast 

with the surrounding forest due to its grey color and finer texture. Although its horizontal 

form is similar to the surrounding ridgelines, the flat horizontal top of the TDF and 

straight sides would contrast with the rounded forms of the adjacent topography. The 

phased development and hydroseeding planned as part of the interim reclamation, 

however, would partially mitigate the extent of color contrasts shown in Figure 3.14-6. 

During Phase 1 (Years 1-10) much of the material would be placed within the existing 

tailings footprint. The height of the TDF would reach its maximum height of 403.8 feet 

during this phase. During Phase 2 (Years 11-20) and Phase 3 (Years 21-30), the TDF 

would be expanded to the south and reach the maximum height During Phase 4 (Years 

31–50) tailings would be placed at the site of the existing water treatment plant and 

Pond 7 on previously disturbed land. Tailings placed during previous phases will be 

revegetated, reducing color contrasts. 

A key mitigation measure specific to Alternative B would be to maintain, to the greatest 

extent possible, existing forest cover between Hawk Inlet and the expanded TDF. 

3.14.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. Under 

Mitigated Alternative B existing forest cover between Hawk Inlet and the expanded TDF 

would be the same as the proposed action and have similar visual impacts. 

3.14.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located approximately three miles north of the existing TDF. 

Additionally the A Road would be upgraded and additional facilities including a tailings 

water transport pipeline, rock quarry, ponds, and additional access road would be 

constructed. Alternative C would also extend the operating period of the mine by 30–50 

years. 

Under Alternative C, development of a new TDF north of the A Road would introduce 

adverse scenery impacts to the northern portion of Hawk Inlet (Figure 3.14-7). The new 

TDF would be approximately 330 feet in height at the end of mine life, visible from 

portions of the head of Hawk Inlet and potentially visible from some of the floating 

cabins. The northern TDF may also be slightly visible from the portion of Hawk Inlet 

south of the inlet’s head, near the abandoned Petrovich Mine cabin. The new TDF would 

contrast with the surrounding landscape due its grey color, geometric lines, and finer 

texture. The TDF would have steeply sloping sides, in comparison to the flat profile of 

the existing TDF, which would be similar to the forms of the adjacent topography. In 

addition, the upper portion of the north quarry proposed as part of Alternative C may be 

visible from the southern portions of Hawk Inlet. Alternative C would reduce the amount 
Chapter 3. Affected Environment and Environmental Consequences

3-226 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

of disturbance within the Monument as compared to Alternative B (Section 3.13.3.3, 

Effects of Alternative B, Proposed Action (Land Use)). 

Tailings generated during construction of the new TDF would be placed on the 

southeastern side of the existing TDF to a height of approximately 367 feet above sea 

level (Figure 3.14-8). These tailings would have minimal additional impact relative to 

Alternative A, since its maximum height would be only three feet over the approved 

height and they will be reclaimed as part of the existing TDF reclamation process once 

the new TDF is constructed. Alternative C would not require a new road west of the 

tailings as with alternatives B and D. Improvements to the existing A Road would not be 

visible from Hawk Inlet and thus only be visible to hunters or others recreating in upland 

areas. 

3.14.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new TDF to the north. Like alternatives B and C, Alternative D would extend the 

operating period of the mine by 30–50 years. The scenery effects of Alternative D would 

be similar to those for Alternative C in that a new area of disturbance would be created, 

introducing adverse impacts to the northern portion of Hawk Inlet. This alternative 

would result in less disturbance to the Monument than Alternative B, but more than under 

Alternative C (Section 3.13.3.5, Effects of Alternative C, New TDF Located Outside 

Monument (Land Use)). The new TDF to the north would be approximately four feet 

taller than under Alternative C, but would be smaller overall, with a narrower profile as 

seen from Hawk Inlet. As under Alternative C, the new rock quarry will be slightly 

visible from the southern portions of Hawk Inlet (Figure 3.14-9). 

Under this alternative the existing TDF would be expanded to the southeast to 

accommodate tailings for the first 10 years of the expansion project. The existing TDF 

would be increased in width by approximately 25 percent over the approved 

configuration and built up to a maximum height of 420.3 feet, 57 feet higher than the 

approved plan and 17 feet higher than Alternative B (Figure 3.14-10). Alternative D 

would require construction of a new road located between Hawk Inlet and the existing 

TDF. Much of this road would be screened by topography and vegetation, except for the 

portion between the marine terminal and the top of the ridge. As with Alternative B, 

leaving as much of the existing forest cover in place as possible would help mitigate 

effects to the view from Hawk Bay.
Greens Creek Mine Tailings Disposal Facility Expansion EIS Figure 3.14-8. Simulation of Alternative C South Tailings Disposal Facility. Figure 3.14-9. Simulation of Alternative D North Tailings Disposal Facility. Figure 3.14-10. Simulation of Alternative D South Tailings Disposal Facility. 
Chapter 3. Affected Environment and Environmental Consequences

3-228 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.14.4 Scenic Resources – Summary 

The TDF would be visible from portions of Hawk Inlet under all of the alternatives and 

will introduce contrasts with the adjacent forest in terms of form, line, color, and texture. 

The Forest Service SIOs will be met, however, since approved mining areas are to be 

managed to a Very Low SIO, or “heavily altered,” landscape within the Non-Wilderness 

National Monument LUD, and non-conforming developments such as mining facilities 

may be considered within the Semi-Remote Recreation LUD. The existing TDF 

associated with all of the alternatives would be visible from the southern portion (4.5-

mile stretch) of the Hawk Inlet Small Bout Route, primarily as a middleground view, as 

well as a small portion of Chatham Strait. The new TDF under alternatives C and D 

would introduce scenery effects to the northern portion of Hawk Inlet, visible primarily 

from the head of the inlet. Under Alternative D, tailings deposited in the existing TDF 

would be visible for the initial 20 years, after which it would be reclaimed and tailings 

deposited in the new TDF. After project completion, all project facilities would be 

removed and reclaimed under all the alternatives, except for the water treatment plant and 

power lines. Reclamation would begin in 2019 under Alternative A, compared to year 

2064 under the other alternatives. 

3.15 Recreation _________________________________ 

3.15.1 Recreation – Pre-mining Environment 

Hunting, saltwater fishing, and boating were the 

predominant recreation activities within the study area prior 

to mine development. Most of the recreation users were 

residents of Juneau, with a smaller portion from Hoonah 

and Angoon. During the summer months Hawk Inlet was 

frequented by sailboats, cabin cruisers, and commercial 

fishing boats. Wheeled aircraft used the beaches at Hawk 

Inlet and Young Bay for recreational access. There were 

also six private cabins each in Hawk Inlet and Wheeler 

Creek that contributed an estimated 110 to 150 user days to 

the area per year. An additional 110 to 150 user days were 

attributed to people using the inlet without direct cabin access, most likely owners of 

private sport boats or clients of charter boat or guide services. Commercial charter pilots 

reported 530 user days in the inlet by their clients. 

In 1980 there were 695 deer taken by 704 deer hunters over 3,090 hunter days in the area 

formerly identified by ADF&G as Subunit 4-11, which included Young Bay, Hawk Inlet, 

Mansfield Peninsula, Seymour Canal, and Glass Peninsula. In the same area and year, 

eight brown bears were taken. Within the immediate project area there was an average of 

3.2 bears taken from 1971 to 1975 and 1.0 bears taken from 1976 to 1980. Deer hunting 

data in the project area is not available. A limited amount of duck hunting occurred in 

Hawk Inlet prior to mining (Forest Service 1983). 

Historically, trapping was an important activity in the study area when it included cultural 

and subsistence trapping by native populations. Trapping gradually developed more of a 

The resource analysis of 

recreation was not 

identified as a significant 

issue; comments from the 

scoping process 

regarding areas used for 

recreational purposes are 

addressed in this section. 
3.15 Recreation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-229 

recreational emphasis in later years, with marten, river otter, and mink comprising the 

primary species (ADF&G 2006). Most trapping was facilitated by boat access (ADF&G 

2006). An estimated 10 river otters were taken annually from the northern portion of 

Admiralty Island (Forest Service 1983). 

3.15.2 Recreation – Baseline Conditions 

There is limited development of recreational facilities in the study area, except for 

approximately six privately owned, floating cabins in Hawk Inlet and 13 private cabins in 

the Wheeler Creek drainage, four of which are rented out as guest units. The Hawk Inlet 

floating cabins are distributed from the south end at Piledrivers Cove to the head of the 

inlet. Outside the study area there are three Forest Service cabins south of Young Bay 

(Admiralty Cove, North Young Lake, and South Young Lake). Hawk Inlet has been 

designated by the Forest Service as a dispersed recreation area and small boat route. 

There are three designated small boat anchorages in the inlet, one is located at the 

cannery site with the other two located near the head of the inlet. Young Bay also has a 

designated small boat anchorage near the existing ferry dock. 

Current patterns of recreation use in the study area are similar to those under pre-mining 

conditions; hunting, fishing, boating, and wildlife viewing are the primary activities and 

there is a limited amount of recreational trapping. Recreational use is not allowed within 

the project area and mine employees are prohibited from engaging in recreational 

activities in the adjacent areas, including Hawk Inlet and Wheeler Creek. Boats are the 

primary form of transport to the study area for recreational use, although aircraft also 

land on Hawk Inlet, Young Bay, and Wheeler Creek. Most of the aircraft are commercial 

pilots transporting hunters or anglers into the inlet for stays ranging from half-day fishing 

trips to multi-day hunting trips (Wright 2011). 

Recreation use within Hawk Inlet is estimated between 950 to 1,200 user days per year 

(user days are defined as recreational use by one individual at one recreation site during 

any portion of one 24-hour period). This figure does not include most of the deer hunters 

because hunting data is only available for the entire GMU. The Hawk Inlet cabins 

contribute an estimated 600 to 850 user days per year, and the primary air charter service 

brings approximately 20 deer hunters to the inlet for an estimated 80 user days (Kiesel 

2011). An additional 220 days are estimated from charter services and other boats seen 

in the inlet during the summer, typically one or two on a weekend day. People also 

occasionally kayak from Juneau to Young Bay and hike across the island to Hawk Inlet. 

Bear hunting is estimated at 40 user days per year (Johns 2011). According to a longtime cabin owner, recreational use of the inlet has increased substantially since premining days (Kiesel 2011). 

In addition, many people visit the northern portion of Admiralty Island outside of Hawk 

Inlet. The cabins on Wheeler Creek attract people into the area, contributing an estimated 

500 user days. Many private sport boats visit the island, particularly those areas within a 

day trip from Juneau, primarily north of Funter Bay. In 2010 there were six commercial 

guide services holding permits in subunits 4-10A and 4-10B, which extend from Angoon 

north to Funter Bay. These services brought a total of 76 groups and 348 clients to the 

area primarily during the summer for fishing, but some for bear hunting in the spring and 

fall. The Juneau Youth Services has also conducted a guided kayak trip around 

Admiralty Island during the past few summers for about 10 young people (Bradey 2011). 
Chapter 3. Affected Environment and Environmental Consequences

3-230 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Sport fishing is a popular activity in and around Hawk Inlet. Most of the fishing is for 

salmon, halibut, shrimp, and crab, and occurs primarily during the months of July and 

August. Approximately 94 percent of the 348 guide clients brought to northern 

Admiralty Island in 2010 were anglers, and most of those clients fished near the mouth of 

Hawk Inlet in subunit 4-10A, which extends from a point north of Greens Creek down to 

Wheeler Creek (King 2011). Private sport fishing boats are also seen in Hawk Inlet. 

Deer hunting occurs throughout northern Admiralty Island during the fall and winter 

months. Data on deer hunting is only available for all of GMU 4, which includes 

Chichagof, Baranof, Kruzof, and Admiralty islands. There were a total of 2,012 deer 

hunters in GMU 4 during the 2007–2008 regulatory year due to severe winter conditions 

(July 2007 through June 2008), numbers were down from an average of 3,434 hunters 

during the previous 3 years (Table 3.15-1). Average success rate also declined in this 

period to 45 percent from the 74 to 78 percent seen in previous years. Almost one-half 

(48 percent) of the hunters in 2007 were from communities within GMU 4, such as 

Hoonah, Angoon, and Sitka, and another half (49 percent) were Alaska residents from 

outside GMU 4. A small proportion of deer hunters (3 percent) were from outside the 

State of Alaska. All of the deer hunting occurs from August through January, with 49 

percent occurring in November. Approximately three quarters of the deer harvest in 

GMU 4 is transported by boat; most of the remaining harvested deer are transported by 

air or highway vehicle. 

Table 3.15-1. Game Management Unit 4 Deer Hunter Residency and Success, Regulatory 

Years 2003 through 2007. 

Regulatory 

Year 

Successful Hunters Unsuccessful Hunters 

Total Hunters 

Local 

Resident 

Nonlocal 

Resident 

Nonresident TotalLocal 

Resident

Nonlocal 

Resident

Nonresident Total

2003–2004 1,242 1,535 57 2,834 253 509 41 803 3,637 

2004–2005 1,064 1,347 82 2,493 283 544 43 87 3,363 

2005–2006 1,124 1,214 102 2,440 291 525 46 862 3,302 

2006–2007 1,157 1,151 92 2,400 244 382 50 676 3,076 

2007–2008 556 333 9 898 405 648 61 1,114 2,012 

Source: ADF&G 2009. 

Note: Local residents consist of residents of GMU 4, Nonlocal Residents are Alaska residents from outside 

GMU 4, and non-residents reside outside of Alaska. 

Admiralty Island, particularly Hawk Inlet, is known for its excellent brown bear hunting, 

which occurs mostly in September and May. Bear hunting data is only available for a 

subunit of GMU 4 consisting of Admiralty Island. During the regulatory years 2003 to 

2007 there were an average 150 bear hunters on Admiralty Island and 669 hunter days 

per year. The average harvest was 54 bears per year, resulting in a hunting effort of 13 

days per bear. Approximately 50 percent of the bear hunters were from outside Alaska, 

with 10 percent from GMU 4 and the remaining 40 percent from other parts of the State 

of Alaska (Table 3.15-2). A local bear guide reports that all of their clients are from 

outside Alaska (Johns 2011). Most of the hunters (92 percent) use boats to transport their 

harvest and aircraft are the second most common method. An estimated 90 percent of the 
3.15 Recreation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-231 

bear hunting in GMU 4 is “shoreline hunting” presumably because it is the easiest way to 

hunt. 

Table 3.15-2. Admiralty Island Brown Bear Hunting Effort by Residency, Regulatory Years 

2003 through 2007. 

Regulatory 

Year 

Hunters Days Hunted 

Total 

Harvest 

Effort 

(Days per 

bear) 

Nonresidents Residents Total Nonresidents Residents Total 

2003–2004 68 96 164 329 434 763 69 11 

2004–2005 97 67 164 370 287 657 58 11 

2005–2006 83 62 145 270 340 610 41 15 

2006–2007 58 85 143 214 550 764 42 18 

2007–2008 70 62 132 266 288 554 58 10 

Source: ADF&G 2009 

Note: Residents reside within Alaska and Non-residents reside outside of Alaska. 

Trapping for mink, marten, and river otter occurs in the Hawk Inlet area for both 

recreational and subsistence purposes. Trapping activities are minimal in Hawk Inlet 

compared to hunting and fishing. The most recent data for the otter and marten harvests 

in Hawk Inlet shows an average per year of six otters trapped from 1981 to 1997 and 

seven martens trapped between 1984 and 2001 (2003 EIS). Data for all of GMU 4 is 

available for the years 2001 through 2005, which indicates most (82 percent) of the 

trapping is by residents of GMU 4, with the remaining trappers coming from other parts 

of the State of Alaska. December saw the most trapping during these years with the 

remainder occurring in January and February. Transport of river otter harvest is almost 

entirely by boat. Marten harvest is transported primarily by boat and highway vehicles 

are the second most prevalent transportation method (ADF&G 2006). 

3.15.3 Recreation – Environmental Consequences 

Recreation effects are evaluated based on the compatibility of alternatives with Forest 

Service management prescriptions for the Semi-Remote Recreation and Non-Wilderness 

National Monument LUDs. Lands within the Semi-Remote Recreation LUD are to be 

managed for semi-primitive types of recreation and tourism in predominantly natural or 

natural-appearing settings. Enclaves of concentrated recreation developments are 

allowed, as are small-scale rustic recreation facilities such as cabins and docks and 

development of motorized off-highway vehicle routes. 

Standards and guidelines for the Non-Wilderness National Monument LUD call for a 

spectrum of wildland recreation opportunities that reflect the existing ecological, 

historical, and sociological conditions found within the Monument. Lands within this 

LUD should be managed for the established Recreational Opportunity Spectrum, except 

where closed to public use due to mining operations or other activities. Mineral 

development is allowed within both of the designated LUDs in the study area as long as 

effects are minimized to the extent feasible, disturbed areas are reclaimed to a nearnatural condition, and forest wide standards and guidelines are implemented. Within the 
Chapter 3. Affected Environment and Environmental Consequences

3-232 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Non-Wilderness National Monument LUD, public recreation use in mining areas is to be 

managed in accordance with the Plan of Operations. If mining results in a change in the 

recreation setting after closure, the area is to be managed to the new setting in accordance 

with the appropriate Recreational Opportunity Spectrum guidelines. 

3.15.3.1 Effects Common to All Alternatives 

The primary effects of the alternatives would be on recreation and tourism activities 

within Hawk Inlet, since the inlet experiences the most concentrated use and is a 

designated VPR. Temporary increases in air and boat traffic within Hawk Inlet or 

Chatham Strait would occur during the construction process, under all action alternatives. 

Indirect effects on hunting and fishing could potentially result from effects on sport 

fisheries or game species, particularly from the risk of fuel and other hazardous substance 

spills. Sections 3.7 and 3.11 discuss effects on aquatic resources and wildlife 

respectively. Indirect effects to recreation from project employees are not expected 

because there would be no increase in employees under any of the alternatives and 

employees are prohibited from hunting or fishing while they are working at the mine or 

staying at the on-site camp. No unauthorized vehicles or firearms are permitted at the 

mine. These restrictions have been in place since the mine began operations and appear 

to be effective in preventing increased recreation pressure according to several local 

cabin owners (Kiesel 2011; Reinwand 2011; Brendt 2011). 

The primary adverse impact of all of the alternatives on recreation would be the view of 

additional tailings to boaters and anglers using Hawk Inlet and to hunters using 

surrounding upland areas. The facility will not be visible from the Wheeler Creek cabins. 

Section 3.14, Scenic Resources, describes these effects in greater detail. All of the 

alternatives meet the standards and guidelines of the Semi-Remote Recreation and NonWilderness National Monument LUDs because semi-primitive recreation would be able 

to continue outside the mine site. In the long term, after project completion, the area’s 

natural-appearing setting would be gradually restored as native vegetation reestablishes 

itself and the project site is reopened for hunting and other semi-primitive recreation. 

3.15.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceases, 

disturbed sites are reclaimed, and human activity in the area is reduced. The TDF would 

continue to be built out to the maximum footprint and height permitted in the 2003 EIS 

(Forest Service 2003). After the TDF is fully built out in 2019, reclamation would begin 

as described in the 2003 EIS (Forest Service 2003). 

The only effect to recreation would be the visibility of the facility to people recreating in 

Hawk Inlet, discussed in Section 3.14, Scenic Resources. After closure of the facility, the 

area would be reclaimed and reopened for public use. 

3.15.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. 

Alternative B would have less effects to recreation compared to alternatives C and D, 

because the existing TDF facilities would be expanded in an area currently closed to 
3.15 Recreation 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-233 

hunting and other recreation. The expanded TDF would be visible from the southern 

portion of Hawk Inlet small boat route for a distance of approximately 4.5 miles. The 

TDF will also be visible from a small portion of Chatham Bay, but as a background view. 

These effects would be phased over the 30-year operational period, with interim 

reclamation reducing some of the contrast created by the expanded TDF. None of the 

privately owned cabins in the inlet would have views of the TDF. Most of the new 

disturbances associated with the TDF (87 percent) would be located within the 

Monument. 

3.15.3.4 Effects of Mitigated Alternative B 

Mitigated Alternative B would have the least effects to recreation of all of the action 

alternatives, because the existing TDF facilities would be expanded in an area currently 

closed to hunting and other recreation. Under Mitigated Alternative B, the expansion of 

the TDF would result in about 2 million cubic yards of tailings and waste rock being 

placed in the northeast corner of the existing TDF. About 68 percent of the newly 

disturbed areas would occur within the Monument. Approximately half of the material 

would be placed in the initial phase of the expansion with the remaining volume being 

placed in the final phase. In addition, the reclamation material storage area and quarry to 

the south of the TDF would be relocated out of the Monument. The result would be a 

new reclamation material storage area located near the junction of the A and B roads; 

moving the quarry out of the Monument would require deepening the quarry at the north 

end of the existing TDF. 

3.15.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located approximately three miles north of the existing 

facility in the Fowler Creek drainage. 

To accommodate tailings generated during construction of the new TDF, the existing 

TDF would be expanded to an elevation of nearly 367 feet above sea level. All new 

tailings during the construction period would be placed within the existing TDF. 

Developing a new TDF north of the A Road would reduce the amount of land available 

for deer hunting and other dispersed recreation, since this area is currently open to the 

public. Under this alternative disruption of additional land within the Monument would 

be minimized as compared to Alternative B, about 3 percent of newly disturbed areas 

would be within the Monument. 

The new TDF would be visible from the northern portion of Hawk Inlet, including some 

of the floating cabins. Additional tailings placed at the existing TDF during construction 

would be visible from the southern portion of the inlet. This alternative would have the 

effect of distributing the visual impacts as seen by those using Hawk Bay between two 

locations, compared to one area of disturbance under alternatives A and B. 

3.15.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new TDF to the north. Like alternatives B and C, Alternative D would extend the 

operating period of the mine by 30–50 years. The expansion of the existing TDF would 

be substantially smaller than Alternative B, however the footprint of the northern TDF is 

relative in size to Alternative C. 
Chapter 3. Affected Environment and Environmental Consequences

3-234 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The effects of Alternative D would be similar to those of Alternative C in that a new TDF 

north of the A Road would close off an area currently open to the public. Similar to 

Alternative C, this alternative would have the effect of distributing the visual impacts 

between two locations and introducing adverse visual impacts to the northern portion of 

Hawk Inlet. The new TDF would likely be visible from the floating cabins. Under 

Alternative D the effects of the new TDF would not occur for another 10 years of 

production. Tailings would be placed within the existing TDF during the first 10 years of 

operation, after which the new TDF would begin operation. Compared to the other 

alternatives, tailings placed in the existing TDF would have a taller profile under 

Alternative D, reaching a height of nearly 57 feet over the approved height of the existing 

TDF than the TDF proposed under Alternative B. The new TDF would have a smaller 

profile, compared to Alternative C, as seen from Hawk Inlet. Under Alternative D, 

disruption of additional land within the Monument would be reduced as compared to 

Alternative B, but greater than Alternative C, about 13 percent of newly disturbed areas 

would be within the Monument. 

3.15.4 Recreation – Summary 

All of the alternatives would meet the standards and guidelines of the Semi-Remote 

Recreation and Non-Wilderness National Monument LUDs because semi-primitive 

recreation would continue outside the mine site. Within the mine site, the area would be 

reclaimed and restored to a near-natural condition after project completion and would be 

re-opened for public recreation. The alternatives differ in terms of their visibility to 

recreationists in Hawk Inlet (see Section 3.14), as well as the extent and location of new 

disturbed areas. There would be no additional acres disturbed as a result of Alternative 

A. Areas of disturbance associated with Alternative B would be located adjacent to the 

existing TDF, which is currently closed to recreation, whereas alternatives C and D 

would result in disturbance to the area north of the A Road, which is currently open to 

public use. Alternative C would affect the least amount of acres within the National 

Monument, whereas Alternative B would affect the largest number of acres within the 

Monument. 

3.16 Subsistence ________________________________ 

The purpose of this section is to describe subsistence 

uses in the Greens Creek Mine area and to assess 

potential impacts on subsistence related to the 

proposed expansion of the TDF at Greens Creek 

Mine. A more detailed description of subsistence 

uses and practices is in Appendix G. Subsistence 

uses are central to the customs and traditions of 

indigenous cultural groups in Alaska, including the 

Alaska Natives of Southeast Alaska. Subsistence 

customs and traditions encompass processing, 

sharing, redistribution networks, and cooperative and individual hunting, fishing, 

gathering, and ceremonial activities. Both federal and state regulations define 

subsistence uses to include the customary and traditional uses of wild renewable 

resources for food, shelter, fuel, clothing, and other uses (ANILCA, Title VIII, Section 

The resource analysis of 

subsistence use was not 

identified as a significant issue; 

comments from the scoping 

process regarding areas used 

for subsistence purposes are 

addressed in this section. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-235 

803, and Alaska Statute 16.05.940[33]). The Alaska Federation of Natives not only 

views subsistence as the traditional hunting, fishing, and gathering of wild resources, but 

also recognizes the spiritual and cultural importance of subsistence in forming Native 

peoples’ worldview and maintaining ties to their ancient cultures (Alaska Federation of 

Natives 2005). 

Subsistence fishing and hunting are traditional activities that help transmit cultural 

knowledge between generations, maintain the connection of people to their land and 

environment, and support healthy diet and nutrition in rural communities in Alaska. The 

ADF&G estimates that the annual wild food harvest in rural areas of Southeast Alaska is 

approximately 5 million pounds, or 178 pounds per person per year (Wolfe 2000). 

Subsistence harvest levels vary widely from one community to the next. Sharing of 

subsistence foods is common in rural Alaska and can exceed 80 percent of households 

giving or receiving resources (ADF&G 2011). The term harvest and its variants – 

harvesters and harvested – are used as the inclusive term to characterize the broad 

spectrum of subsistence activities, including hunting, fishing, and gathering. 

The combination of subsistence and 

commercial-wage activities can help provide 

the economic basis for the way of life so highly 

valued in rural communities (Wolfe and Walker 

1985). The importance of the mixed economy 

to the subsistence lifestyle in Angoon in the 

past was noted by George and Bosworth (1988: 

35) who stated “commercial fishing income is, 

in fact, an important element of the Angoon 

‘mixed’ economy, which greatly depends on a 

relatively secure cash flow and a productive 

subsistence resource base.” In 1985, 116 

commercial fishing permits were issued to 

residents of Angoon, a number that peaked in 

the early 1990s (CFEC 2012). Commercial 

fishing from Angoon has decreased 

substantially over the intervening years with only 3 commercial fishing permits issued to 

Angoon residents in 2011 (CFEC 2012). 

The lack of employment opportunities and unemployment rate in Angoon were concerns 

voiced during subsistence hearings and during government-to-government consultation 

with the Native Village of Angoon. While income from regular employment can be used 

to subsidize subsistence activities, people of Angoon have voiced concerns over the loss 

of subsistence opportunities, these and other residents rely on subsistence to supplement 

their diets throughout the year. A reduction in subsistence activities is not only a concern 

because of the potential loss of ties to a historical cultural activity but also the impact to a 

healthy diet and contributions to residents’ overall well-being. 

Alaska and the federal government regulate subsistence hunting and fishing in the State 

of Alaska under a dual management system. The federal government recognizes 

subsistence priorities for rural residents on federal public lands, while Alaska considers 

all residents to have an equal right to participate in subsistence hunting and fishing when 

Subsistence is part of a rural 

economic system, wherein families 

invest money into small-scale, 

efficient technologies to harvest wild 

foods Fishing and hunting for 

subsistence resources provide a 

reliable economic base for rural 

regions. Subsistence is not oriented 

toward commercial market 

production, but is focused toward 

meeting the self-limiting needs of 

families and small communities. 
Chapter 3. Affected Environment and Environmental Consequences

3-236 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

resource abundance and harvestable surpluses are sufficient to meet the demand for all 

subsistence and other uses. 

The responsibilities of federal land managers in regard to subsistence resources is defined 

under Section 810 of Alaska National Interest Lands Conservation Act (ANILCA), which 

is discussed in greater Appendix B. The Alaska Board of Fisheries and the Alaska Board 

of Game have adopted regulations enforced by the State of Alaska for subsistence fishing 

and hunting on all State of Alaska lands and waters, and lands conveyed to Alaska Native 

Claims Settlement Act groups. State law is based on Alaska Statute 16 and Title 5 of the 

Alaska Administrative Code (AAC) (05 AAC 01, 02, 85, 92, and 99) and regulates state 

subsistence uses. Under Alaska law, when there is sufficient harvestable surplus to 

provide for all subsistence and other uses, all Alaskan residents qualify as eligible 

subsistence users. 

The State of Alaska distinguishes subsistence harvests from personal use, sport, or 

commercial harvests based on where the harvest occurs, not where the harvester resides 

(as is the case under federal law). More specifically, state law provides for subsistence 

hunting and fishing regulations in areas outside the boundaries of “nonsubsistence areas,” 

as defined in state regulations (5 AAC 99.015). According to these regulations, a 

nonsubsistence area is “an area or community where dependence upon subsistence is not 

a principal characteristic of the economy, culture, and way of life of the area of 

community” (5 AAC 99.016). 

Activities permitted in these nonsubsistence areas include general hunting and personal 

use, sport, guided sport, and commercial fishing. There is no subsistence priority in these 

areas; therefore, no subsistence hunting or fishing regulations manage the harvest of 

resources. Nonsubsistence areas in Alaska include the areas around Anchorage, 

Matanuska-Susitna Valley, Kenai, Fairbanks, Juneau, Ketchikan, and Valdez (Wolfe 

2000). 

3.16.1 Subsistence – Pre-mining Environment 

This section addresses the subsistence environment before the development of the Greens 

Creeks Mine in 1976. Prior to European contact, the study area was inhabited by Tlingit 

Indians; many of their descendants continue to reside in southeast Alaska communities, 

including the study communities of Angoon and Hoonah. In 1946, Goldschmidt and 

Haas (1998) documented the traditional Angoon territory as part of Tlingit and Haida 

land claims. Angoon residents’ traditional territory included the shores of Chatham Strait 

on Admiralty Island from Point Marsden south to Chapin Bay, and on Chichagof and 

Baranof islands from Basket Bay south to Gut Bay (Goldschmidt and Haas 1998: 67). 

Just as they had documented the traditional territory of Angoon, Goldschmidt and Haas 

(1998) documented the traditional Hoonah territory in 1946 as part of Native land claims. 

Hoonah’s traditional territory included the area along Chatham Strait from Point Howard 

westward to Cape Fairweather; Chichagof Island from Point Augusta west to Point Urey; 

and all the islands in Icy Straits and Cross Sound (Goldschmidt and Haas 1998: 53). 

Later studies, primarily by ADF&G, documented more contemporary subsistence uses of 

the study area and are described below. The rural communities that participate in 

subsistence activities in the study area that would likely be most affected by the proposed 

project include Angoon, Hoonah, and Tenakee Springs. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-237 

3.16.2 Subsistence – Baseline Conditions 

3.16.2.1 Study Area 

The proposed Greens Creek Mine TDF expansion is located within Hawk Inlet on lands 

managed by the Forest Service and the Monument. Because the project is located within 

federal lands, federal subsistence regulations apply and only harvests by rural residents in 

these areas are considered subsistence harvests. Nonrural residents (e.g., Juneau area 

residents) are not allowed to hunt or fish on these lands under federal subsistence 

regulations. Nonrural residents may harvest fish and game on these federal lands; 

however these harvests occur under state regulations. Because the entire project lies in 

the State of Alaska defined Juneau nonsubsistence area boundary, all harvests of wildlife 

and fish near the project area by nonrural residents are considered sport or personal use 

harvests from the perspective of ADF&G regulations and are not addressed in this 

section. Federal subsistence regulations apply and were considered in the analysis. 

Important subsistence resources harvested by residents of Angoon, Hoonah, and Tenakee 

Springs include deer, salmon, halibut, seal, waterfowl, marine invertebrates, berries, and 

plants. Due to their island locations and lack of major road development, much of these 

communities’ use areas, including Hawk Inlet, are accessed using skiffs or boats with 

some hiking further inland for resources not readily found along the coast. 

3.16.2.2 Angoon 

Angoon is located on the west coast of Admiralty Island approximately 44 miles to the 

south of Hawk Inlet and has a population of 459 residents, 76 percent of which are 

Alaska Native (U.S. Census Bureau 2011a). 

Figure 3.16-1 shows the subsistence use areas of Angoon residents for the time periods of 

pre-1988 (TRUCS 1988) and 1991-1995 (ADF&G 1997). During the most recent study 

(1991-1995), Angoon residents did not report use areas within Hawk Inlet. 

In all study years, fish provide approximately half of the total subsistence harvest, and 

land mammals account for roughly one quarter to one third of the total harvest, with 

marine mammals, marine invertebrates, and vegetation accounting for the remaining 

harvests. Individual resources that contribute a large amount to Angoon’s total harvest 

based on the most representative study year (1996) include salmon (36 percent), deer (23 

percent), halibut (18 percent), harbor seal (four percent), chiton (four percent), and butter 

clams (four percent). 

Angoon’s seasonal round of harvest activity is based on the research conducted by 

George and Bosworth (1988) (Figure 3.16-2). At the peak of summer, residents are 

engaged in fishing activities, particularly for salmon but also other species such as 

halibut, cod, and other marine fish. 
Chapter 3. Affected Environment and Environmental Consequences

3-238 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.16-1. Angoon Subsistence Use Areas. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-239 

Resource Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec 

Fish 

King Salmon 

Chum 

Salmon 

 

Coho Salmon 

Pink Salmon 

Red Salmon 

Halibut 

Dolly Varden 

Cod 

Herring 

Herring Eggs 

Flounder 

Sole 

Snapper 

Sculpin 

Mammals 

Deer 

Black Bear 

Furbearers 

Seal 

Birds 

Geese 

Ducks 

Grouse 

Bird Eggs 

Shellfish 

Dungeness 

Crab 

 

Tanner Crab 

King Crab 

Clam 

Cockle 

Gumboot 

Sea Urchin 

Sea 

Cucumber 

 

Plants 

Blueberry 

Salmonberry 

Thimbleberry 

Seaweed 

Occasional Harvest Effort. Primary Harvest Effort 

Source: Adapted from George and Bosworth 1988 

Stephen R. Braund & Associates 2011

Figure 3.16-2. Angoon Seasonal Round of Harvest Activities. 
Chapter 3. Affected Environment and Environmental Consequences

3-240 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.16.2.3 Hoonah 

Hoonah is located on the northeast shore of Chichagof Island, approximately 28 miles 

west of Hawk Inlet, and has a population of 760 people, 53 percent of whom are Alaska 

Natives (U.S. Census Bureau 2011). 

Figure 3.16-3 shows the subsistence use areas of Hoonah residents for the time periods of 

pre-1986 (Schroeder and Kookesh 1990), pre-1988 (TRUCS 1988) and 1991-1995 

(ADF&G 1997). Hoonah use areas (pre-1986 and pre-1988) were for the time period 

community residents had been living in Hoonah. For both studies, their terrestrial 

subsistence use areas included the northern portion and western coastline of Chichagof 

Island, Yakobi Island, and northwest coastline of Admiralty Island near Hawk Inlet 

(Figure 3.16-3). During the most recent study (1991–1995), Hoonah residents reported 

use areas at the entrance of Hawk Inlet but not within the Inlet. 

Individual resources that accounted for the majority of harvests, as recorded during the 

1996 study year, included salmon (30 percent), deer (20 percent), a variety of marine 

invertebrates (16 percent), halibut (eight percent), and harbor seal (six percent). Hoonah 

residents harvested between 34 and 237 harbor seals annually over a period of 12 study 

years. 

Hoonah’s seasonal round of harvest activity is based on the research conducted by 

Schroeder and Kookesh (1990) (Figure 3.16-4). While some species of fish are available 

year-round (e.g., halibut, snapper, and king salmon), the majority of fishing begins in 

June and continues through the summer into fall. During this time, halibut, salmon, and 

several species of cod are harvested. Residents also harvest plants during the summer 

months. Although available year-round, the majority of crabs are taken during the 

summer when they move to shallow waters. Late July and August signal the beginning 

of berry harvests and deer, seal, black bear, and goat hunting. Late fall harvest activities 

include waterfowl, spruce grouse, moose, and cranberry harvesting as well as continued 

fishing and marine invertebrate harvesting. Furbearer harvests occur during the winter. 

Fishing and marine invertebrate harvesting are also winter activities. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-241 

Figure 3.16-3. Hoonah Subsistence Use Areas. 
Chapter 3. Affected Environment and Environmental Consequences

3-242 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Resource Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec 

Fish 

Pacific cod 

Black cod 

Ling cod 

Dolly varden 

Flounder (sole) 

Halibut 

Herring eggs 

Pacific herring 

Hooligan 

Irish lords 

Other rockfish 

Red snapper 

Chum salmon 

Coho salmon 

King salmon 

Pink salmon 

Sockeye 

salmon 

 

Surf smelt 

Cutthroat trout 

Steelhead 

Birds 

Sandhill crane 

Ducks 

Geese 

Spruce grouse 

Willow ptarm. 

Seagull eggs 

Waterfowl 

eggs 

 

Intertidal 

Abalone 

Clams 

Dungeness 

crab 

King crab 

Tanner crab 

Black gumboot 

Red gumboot 

Blue mussels 

Octopus 

Sea cucumber 

Shrimp 

Black seaweed 

Sea ribbon 

Garden 

seaweed 

 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-243 

Resource Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec

Mammals 

Black bear 

Deer 

Land otter 

Marten 

Mink 

Moose 

Mountain goat 

Harbor/hair 

seal 

Weasel 

Ermine 

Berries 

Blueberry 

Highbush cran. 

Lowbush cran. 

Grey current 

Elderberry 

Goose Berry 

Black 

huckleberry 

 

Red 

huckleberry 

 

Jacob berry 

Nagoon berry 

Raspberry 

Salmonberry 

Soapberry 

Strawberry 

Plants 

Devil’s club 

Ferns 

Firewood 

Goose tongue 

Hemlock bark 

Hudson Bay 

tea 

Indian rice 

Sourdock 

Spruce roots 

Wild celery 

Wild parsley 

Wild sweet 

potato 

 

Source: Adapted from Schroeder and Kookesh 1990. 

Stephen R. Braund & Associates 2011.

Figure 3.16-4. Hoonah Seasonal Round of Harvest Activities. 
Chapter 3. Affected Environment and Environmental Consequences

3-244 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.16.2.4 Tenakee Springs 

Tenakee Springs is located along the eastern coast of Chichagof Island approximately 28 

miles southwest of Hawk Inlet and has a population of 131 residents, one percent of 

whom are Alaska Native (U.S. Census Bureau 2011). Pre-1988 use areas documented 

during the TRUCS project show Tenakee Springs residents’ subsistence use areas 

encompassed the entire Tenakee Inlet and surrounding lands, portions of Peril Strait, and 

coastline areas around Baranof, Pleasant, Douglas, and Admiralty islands (Figure 3.16-5). 

Tenakee Springs use areas on Admiralty Island are located along much of the island’s 

western and southern coastline including Hawk Inlet; Tenakee Springs residents reported 

deer hunting along Hawk Inlet’s coastline. 

ADF&G (2011) considers the 1987 study year data to be the most representative Tenakee 

Springs study years. During the two study years, fish accounted for between 40 and 45 

percent of the total harvest; land mammals between 26 and 41 percent; marine 

invertebrates between 13 and 24 percent; and the remaining resource categories 

contributed no more than five percent individually. Based on the most representative 

study year (1987), individual resources that contribute a large amount to Tenakee 

Springs’ total harvest include deer (41 percent), salmon (15 percent), halibut (14 percent), 

Dungeness crab (five percent), clams (four percent), and Dolly Varden (four percent). 

Tenakee Springs seasonal round of harvest activity was documented by Leghorn and 

Kookesh (1987) (Figure 3.16-6). Similar to other study communities, several resources 

are harvested throughout the year with peaks in harvest effort during certain months; fish 

and marine invertebrates are the primary resources harvested throughout the year. 

3.16.3 Environmental Consequences 

3.16.3.1 Effects Common to All Alternatives 

Based on existing data as described in Section 3.16.2, the communities of Angoon, 

Hoonah, and Tenakee Springs have documented use of the Hawk Inlet area for 

subsistence purposes. Subsistence users’ access to use areas would not be expected to be 

impacted except for a potential loss of deer winter range near the new TDF location at 

Fowler Creek (see Alternative C and D discussion). Current policy by the applicant 

prohibits hunting and fishing from mine employees while working at the site and thus 

extending the duration of the mine would not have an effect on competition for 

subsistence resources. Sections 3.7, Aquatic Resources and Section 3.11, Wildlife, note 

that effects on certain subsistence resources (e.g., deer, salmon, non-salmon fish, marine 

invertebrates) could potentially occur due to habitat loss, fuel and other hazardous 

material spills, heavy metals accumulation, or fugitive dust dispersal. Depending on the 

magnitude of these potential impacts, subsistence resource abundance, health, and 

availability for species that are harvested within Hawk Inlet could be affected. Existing 

mitigation plans such as spill control plans, treatment of surface water runoff, dust 

abatement measures, and mine reclamation plans, if implemented properly, should 

eliminate or minimize these effects. Considering the availability of similar habitat in the 

area and the practices and measures required to reduce impacts to subsistence resources, 

any of these impacts would be of limited extent and duration and would not result in 

substantial or prolonged restriction of subsistence resources or uses under any alternative. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-245 

Figure 3.16-5. Tenakee Springs Subsistence Use Area. 
Chapter 3. Affected Environment and Environmental Consequences

3-246 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Resource Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec 

Mammals 

Deer 

Seal 

Land otter 

Mink 

Weasel 

Marten 

Intertidal and Other Gathered Resources 

Clams and 

cockles 

Mussels 

Sea urchins 

Chiton 

Scallops 

Octopus 

Shrimp 

Herring eggs 

Crabs 

Kelp 

Sea weed 

Berries 

Wild rhubarb 

Indian celery 

Ferns 

Roots 

Hudson Bay tea 

Goose tongue 

Beach 

asparagus 

 

Mushrooms 

Firewood 

Fish 

King salmon 

Sockeye 

salmon 

 

Chum salmon 

Pink salmon 

Coho salmon 

Halibut 

Cod 

Bass 

Dolly varden 

Herring 

Red snapper 

Birds 

Ducks 

Canada goose 

Source: Adapted from Leghorn and Kookesh 1987. 

Stephen R. Braund & Associates 2011. 

Figure 3.16-6. Tenakee Springs Seasonal Round of Harvest Activities. 
3.16 Subsistence 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-247 

3.16.3.2 Effects of Alternative A, No Action 

Under Alternative A, current mining activities would continue under existing permits 

until approximately 2019. Subsistence uses would not be affected beyond any potential 

impacts that may already occur under the No Action Alternative. The 2003 EIS for the 

project, which also addressed an expanded TDF, identified the impacts of the project as 

negligible to subsistence uses (Forest Service 2003: 4-53). Of all alternatives, Alternative 

A would have the least prolonged impact on subsistence resources as the proposed 

duration is three years compared to 30-50 years for the action alternatives. 

3.16.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, the existing TDF would be expanded to accommodate an additional 

30–50 years of tailings. Alternative B would require expanding the existing TDF 

southward, increasing the facilities lease area. Alternative B would have minimal impact 

on subsistence uses of all the action alternatives because any potential impact would 

occur within an already developed area. The expanded TDF and associated proposed 

components under Alternative B are co-located nearest to the existing TDF versus the 

other action alternatives, which include development of a new TDF in previously 

undisturbed area where subsistence resources, particularly deer, may be taken. 

Documented uses of Hawk Inlet for deer hunting occurred in pre-1985 (ADF&G 1986) 

and pre-1988 (TRUCS 1988) time periods, however, the 1991–1995 (ADF&G 1997) data 

do not show subsistence uses within Hawk Inlet. Effects to aquatic resources, including 

subsistence resources such as freshwater fish, would also be the least under Alternative B 

(see Section 3.7). There would not be a significant possibility of a significant restriction 

on subsistence resources or uses under this alternative. 

3.16.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. No aspects of 

Mitigated Alternative B would impact subsistence use in the project area. 

3.16.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Under Alternative C, the lifespan of the mine would extend 30-50 years, with a three-year 

expansion of the existing TDF and the construction of a new TDF, approximately three 

miles north of the existing TDF. Alternative C would have greater impacts on 

subsistence uses than alternatives A and B due to the new TDF and resulting effects on 

aquatic resources and removal of approximately 174 acres of deer winter range (potential 

hunting area) near Fowler Creek. Documented uses of Hawk Inlet for deer hunting 

occurred in pre-1985 (ADF&G 1986) and pre-1988 (TRUCS 1988) time periods, 

however, the 1991–1995 (ADF&G 1997) data do not show subsistence uses within Hawk 

Inlet. There would not be a significant possibility of a significant restriction on 

subsistence resources or uses under this alternative. 
Chapter 3. Affected Environment and Environmental Consequences

3-248 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.16.3.6 Effects of Alternative D, Modified Proposed Action 

Similar to Alternative C, Alternative D would extend the lifespan of the mine 30–50 

years, with expansion of the existing TDF and construction of a new TDF located in the 

Fowler Creek area. In this alternative, the existing TDF would be expanded to 

accommodate for an additional 10 years of use; followed by a new TDF and upgraded 

haul road three miles north of the existing TDF. Alternative D impacts on subsistence 

would be the same as Alternative C due to the new TDF and resulting effects on aquatic 

resources and removal of a deer winter range near Fowler Creek. Documented uses of 

Hawk Inlet for deer hunting occurred in pre-1985 (ADF&G 1986) and pre-1988 (TRUCS 

1988) time periods, however, the 1991–1995 (ADF&G 1997) data do not show 

subsistence uses within Hawk Inlet. There would not be a significant possibility of a 

significant restriction on subsistence resources or uses under this alternative. 

3.16.4 Subsistence – Summary 

Alternative A would have the least impact on subsistence uses due to the limited new 

construction and shorter project timeline ending in 2019. Alternative B would have the 

least impact on subsistence uses of all action alternatives due to the co-location of new 

project components with existing components. Alternatives C and D would have the 

same impact on subsistence uses and the impacts would be greater than alternatives A 

and B due to construction of a new TDF would result in removal of deer winter range 

near Fowler Creek and some impacts on fish. The time period of impacts under 

alternatives C and D would be longer than the other alternatives. Considering the 

availability of similar habitat in the area and the practices and measures to reduce impacts 

to subsistence resources, effects under any alternative would not result in a significant 

possibility of a significant restriction on subsistence resources or uses under any 

alternative. 

3.17 Cultural Resources __________________________ 

The purpose of this section is to describe cultural resources 

in the area of Greens Creek Mine, describe impacts on 

cultural resources resulting from mine activities to date, 

and to assess potential impacts on cultural resources 

related to the proposed expansion of the TDF at Greens 

Creek Mine. The following discussion identifies reported 

cultural resources within the study area and the potential 

for unknown or undocumented cultural resources that may 

be affected by the proposed undertaking. More details are 

provided in Appendix H. 

This section includes a discussion of cultural resources that have been, or could be, found 

in the vicinity of the proposed TDF expansions. Cultural resources include sites and 

materials of prehistoric Native American, historic Euro-American, and historic Tlingit 

origin (e.g., traditional cabin sites, camp sites, burial grounds, traditional subsistence 

harvest sites, middens, and other traditional land use areas, landscapes, and place names). 

Residents in nearby communities such as Hoonah and Angoon are descendants of the 

original Tlingit inhabitants and have cultural ties to the sites and the lands in which they 

The resource analysis of 

cultural resources was not 

identified as a significant 

issue; comments from the 

scoping process regarding 

cultural resources are 

addressed in this section. 
3.17 Cultural Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-249 

are found. A key assumption for the cultural resources analysis is that cultural resources 

in the study area are assumed to be eligible for the National Register of Historic Places 

(NRHP) unless otherwise specified. 

The cultural resources analysis relies on: 

1. Alaska Heritage Resource Survey files located at the Alaska Department of 

Natural Resources (ADNR), Office of History and Archaeology (ADNR, 

OHA 2011); 

2. An assessment of available literature regarding cultural resources in the proposed 

project area including the Forest Service’s Section 106 review for the project 

(Gilliam 2012); and 

3. The application of existing laws and regulations regarding the assessment of 

effects on cultural resources caused by an undertaking. 

The relevant regulations for the evaluation of effects to cultural resources are the NEPA 

and Section 106 of the National Historic Preservation Act (NHPA) and its implementing 

regulations 36 CFR 800. 

3.17.1 Cultural Resources – Pre-mining Environment 

3.17.1.1 Prehistoric Environment (Before 12,500 years ago to A.D. 1740)

The earliest human occupation of Southeast Alaska dates to the end of the Pleistocene 

epoch, about 11,700 years ago. Regional deglaciation in southeast Alaska was probably 

complete by 13,900 years ago, creating a relatively stable coastal environment with sea 

levels several meters lower than they are now (Mann and Streveler 2008). The 

Paleomarine people in Southeast Alaska at this time relied on a “coastal-marine” 

economy based on hunting sea mammals and fishing, probably from boats (Davis 

1990:197). There is little other evidence to indicate settlement patterns, seasonal rounds, 

or other elements of culture at the time. 

About 6,000 years ago, glaciers in southeast Alaska re-advanced and the relative sea level 

began to rise (Mann and Streveler 2008). These changes in the environment, called the 

Neoglacial period for its cooler, wetter weather and glacier growth, correspond with 

changes in the culture of the people living in southeast Alaska. Starting around 4,500 

years ago, the microblades and unifacial tools of the Paleomarine Tradition began to be 

replaced by ground stone technology. This period of change is referred to as the 

Transitional stage, indicating that the Paleomarine Tradition was in the process of being 

replaced by another tradition. Communities formed at favorable locations for shellfish 

harvests, marked by accumulations of discarded shells called middens. Ground slate 

tools may be associated with a shift to the harvest of marine mammals such as seal, sea 

lion, and sea otters. Studies of human skeletons from the period indicate that up to 90 

percent of the diet was derived from marine resources (Ames and Maschner 1999). The 

periodic glacial advances and retreats caused by changes in climate beginning in the 

Transitional stage may have presented new challenges for people living in coastal 

Southeast Alaska into historic times. Oral history recounts villages being crushed under 

the ice of advancing glaciers (Connor, Streveler, Post, Monteith and Howell 2009). 

However, by about 3,000 years ago, people had adapted to the changing environment and 

their cultures diversified during the Northwest Coast stage. 
Chapter 3. Affected Environment and Environmental Consequences

3-250 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

The Northwest Coast Stage is characterized by ground stone and bone tools and a 

subsistence economy that emphasized the near-shore and intertidal resources such as fish 

and mollusks as evidenced by the occurrence of shell middens. Winter settlements 

became larger, subsistence camps more specialized, and fortified locations were built as 

this stage progressed. The Northwest Coast stage consisted of early, middle, and late 

phases, and ended in historic times with cultural groups like the Eyak and Tlingit (Davis 

1990:199-200). 

3.17.1.2 Ethnohistory 

The area at the north end of Admiralty Island, including the Mansfield Peninsula, was 

used by numerous Alaska Native groups including the Hoonah, Angoon, and Auk people. 

Interviews indicate that the Mansfield Peninsula belonged to the Wooshkeetaan clan, 

while the territory beyond Hawk Inlet belonged to the Angoon people (Sealaska 1998). 

Within Hawk Inlet, a number of cabins in the vicinity of the Hawk Inlet Cannery were 

reported to have been used by Whooshkeetaan although those structures, including two 

smokehouses south of Hawk Inlet, are gone. The cabins were used while hunting deer, 

brown bear, and mink and fishing for chum and Chinook salmon. 

Young Bay, on the east side of northern Admiralty Island, is the traditional territory of 

the Auk and was called Weineidiyán. The area was a popular place for people to fish and 

was used by people from Douglas Island; reports indicate that the L’eeneidi claim Young 

Bay. Bears were known to be common in the area which made it difficult to use. A log 

cabin and smokehouse were located near a stream east of Young Bay (Sealaska 1998).

Native allotment claims have been filed for land at the mouth of Greens Creek arising 

from the claim use and seasonal occupancy of the area from 1910 to the mid-1920s. The 

properties had more recent casual use while one of the owners was employed at the Hawk 

Inlet Cannery. 

The Hawk Inlet Cannery (JUN-092) was built in 1910 by the Hawk Fish Company as the 

industry was becoming highly mechanized and dependable markets were being 

developed, using fish traps as the predominant harvest method. The facility was taken 

over by P.E. Harris in 1916, whose company operated it until 1975 when the name was 

changed to Peter Pan Seafoods, Inc. In 1976 the cannery was purchased by the 

Dillingham Indian Corporation. In May 1976, the facility burned. The remaining 

buildings are leased by Hecla Mining Company. Orth (1967) reports the Hawk Inlet 

cannery had a summer population of 500 (the year is unspecified). 

During an interview of George Jim Sr., Mr. Jim indicated that it was his clan that gave 

the Hawk Inlet Cannery permission to build because they promised jobs for the people. 

He further stated that food caches were built in the vicinity of the cannery in case winter 

storms came and prevented the people from transporting their subsistence food to Auke 

Bay and forced people to stay in Hawk Inlet for the winter. He stated that people died 

while putting up food for the winter and had to be buried right where they died because 

they had no time to take them to Auke Bay for burial (Jim 1982). 

Past interviews conducted to document use in the region referred to the use of the 

overland route including stories of relatives that used it when they went up Hawk Inlet 

and packed across the land to get on a canoe cached on the other side; from there they 

rowed across to Auke Bay (Gamble 1982; Jim 1982). 
3.17 Cultural Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-251 

3.17.1.3 Historic Environment (After A.D. 1740) 

The historical period for southeast Alaska began with several expeditions on behalf of the 

Spanish, English, Russians, and French to explore the northern Pacific coast. The first 

European explorer to reach the region, Alexei Chirikof, sighted the Fairweather Coast in 

1741, claiming Alaska to Russia by right of discovery. Subsequent explorations by 

James Cook starting in 1778 expanded European awareness of Alaskan geography and 

human populations, and piqued interest in the abundance and profitability of natural 

resources. European interest first focused on the sea otter populations, whose pelts were 

a highly sought after commodity in Chinese, European, and Russian markets. Russia, 

England, Spain, France, and the United States would soon compete for these resources. 

The Russian American Company’s management policies resulted in the near extinction of 

the sea otter and increased resentment among the Tlingit of Southeast Alaska. 

Resentment grew and eventually spurred violence, resulting in Tlingit attacks in 1802 

which destroyed the Russian post at Old Sitka and in 1805 which destroyed the Russian 

outpost at Yakutat. 

The Russians reoccupied Sitka in 1804, strengthening their hold on Southeast Alaska. 

Large-scale harvesting of sea otters in Tlingit areas ended in the 1820s, and after 1841, 

the Russians relied primarily on trade with Tlingit middlemen for land peltry. Tlingit 

trade networks continued to increase in scope during the early nineteenth century, as did 

their control of trade to the interior. Russian profits in the fur trade were declining, 

however, and Russia was concerned about its ability to hold Alaska against the British. 

To prevent this, Alaska was sold to the United States in 1867. 

The Alaska Purchase brought a major influx of Euroamericans to Tlingit territory 

between 1867 and 1870. Army forts at Sitka, Wrangell, and Tongass brought soldiers, 

speculators, and camp followers to these trading posts, which became bases for 

prospectors, miners, and tourists. Fundamental changes to Tlingit culture came as early 

as the 1870s when commercial fishing, canneries and the tourist industry developed, 

integrating the Tlingit into the wage-based American economy (de Laguna 1990:224). 

Commercial activities in the region at the end of the nineteenth century and beginning of 

the twentieth century included fishing, whaling, minerals exploration, timber harvest, fur 

farming, and tourism (Bower, Iwamoto, and McCallum 2003:9). In 1878, profitable 

salmon canneries were constructed near Klawock and Sitka, marking the onset of the 

commercial fishing industry that would eventually construct 134 canneries in Southeast 

Alaska (Bower, Iwamoto, and McCallum 2003:8). The Hawk Inlet Cannery is discussed 

above. 

Other commercial opportunities including trapping and mining continued to attract 

homesteaders, migrant workers, and profit seekers to the region during the first half of the 

twentieth century. Mink, marten, beaver, muskrat, and fox were all harvested for fur 

(Bower et al. 2003:10). Gold was extracted from the Alaska Empire Mine beginning in 

1919 near Hawk Inlet, and in 1926 there were 96 claims in the vicinity, though 

production slowed steadily until only a crew of five was employed there in 1946. In 

1973 the Pan Joint Venture began exploring for base metals in Southeast Alaska, and 

from 1974 to 1976 geologic studies revealed high base metal deposits on Admiralty 

Island. Noranda, Inc. assumed responsibilities for field operations in 1976 and began the 

initial work at Greens Creek (Bower et al. 2003:9). 
Chapter 3. Affected Environment and Environmental Consequences

3-252 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.17.2 Cultural Resources – Baseline Conditions 

Based on a review of available information in the study area, 10 documented cultural 

resource sites are located in an area bounded by the head of Hawk Inlet to the north, the 

southwest corner of Young Bay to the east, Chatham Strait to the west, and as far south 

as the mouth of Hawk Inlet. Site types in the area include mining sites with 

accompanying built environment resources, early twentieth century homestead claims 

cabins, prehistoric shell middens, a reported petroglyph/pictograph, the Hawk Inlet 

Cannery, and the Hawk Inlet Overland Route (which was documented as part of the 

Section 106 survey for this project). Sites also include areas of traditional use for 

subsistence resource gathering. 

Six sites have been evaluated for inclusion on the NRHP; three sites, including the Hawk 

Inlet Cannery (JUN-00092), the Hawk Inlet Overland Route (JUN-01137), and the 

Young Bay Midden site (JUN-00091), have been determined eligible for the NRHP. 

Fowler Creek Homestead (JUN-00918), Jacobsen’s Cabin (JUN-00236), and the Greens 

Creek Midden site (JUN-00090) were all determined to be ineligible for inclusion on the 

NRHP. The Piledriver Cove Pictograph/Petroglyph (JUN-00045), Soldier’s Additional 

Homestead Claim (JUN-00237), Greens Creek Cabin (JUN-00238), and Alaska Empire 

Mine and Dock Site (JUN-00689) have not been evaluated for eligibility to the NRHP. 

Cultural resource investigations of note in the study area include an archaeological 

impact assessment (Carlson 1981) conducted prior to the development of an 

Environmental Assessment (Forest Service 1982) for the Noranda Mining Project at 

Greens Creek. Two midden sites (JUN-00090 and JUN-00091), three historic cabins 

(JUN-00236; JUN-00237; JUN-00238), and a historic cannery (JUN-00092) located 

within the study area were initially recorded by Carlson (1981); the middens were later 

more fully investigated by Davis (1990). In 1983, the Hawk Inlet Cannery (JUN-00092) 

was documented and determined to be eligible for the NRHP (Johannsen 1983). 

The Forest Service has also recently conducted cultural resource investigations as part of 

this project in the potential TDF and rock quarry areas associated with Alternatives C and 

D (Gilliam 2012). While no cultural resources were identified in the surveyed areas, the 

Forest Service did identify the Hawk Inlet Overland Route (JUN-01137) within the area 

of potential effect. In the Section 106 report, the Hawk Inlet area is also identified as 

sacred to the Angoon Community Association. The Section 106 report notes that the area 

is considered sacred because of its proximity to the Hawk Inlet Overland Route (a 

traditional transportation route), the traditional use of the area by Angoon residents for 

subsistence activities, and the presence of the Hawk Inlet Cannery (a place where many 

residents of Angoon grew up and learned subsistence traditions). 

3.17.3 Cultural Resources – Environmental 

Consequences 

3.17.3.1 Effects Common to All Alternatives 

An adverse effect to a cultural resource occurs when an undertaking may alter, directly or 

indirectly, any of the characteristics of a cultural resource that could qualify the property 

for the inclusion in NRHP in a manner that would diminish the property’s integrity 

(location, design, setting, materials, workmanship, feeling, association) and/or association 
3.17 Cultural Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-253 

(i.e., association with an important event or person [Criteria A and B], style of 

architecture [Criterion C], or information potential [Criterion D]) thus rendering it 

ineligible for the NRHP. Effects to cultural resources also include those impacts that 

result from the action later in time or further removed in distance but still reasonably 

foreseeable such as increased access to and close proximity of project components to 

culturally sensitive areas. 

Examples of direct effects to cultural resources from ongoing or proposed activities could 

include physical destruction of or damage to all or part of the resource, removal of the 

resource from its original location, change of the character of the resource’s use or of 

physical features which in the resource’s setting that contribute to its historic 

significance, change in access to traditional use sites by traditional users, or loss of 

cultural identity with a resource. Indirect effects to cultural resources from the proposed 

project could include impacts caused by increased access to and close proximity of 

project components to cultural resources. This could result in a greater vulnerability of 

unidentified cultural resources to damage caused by project personnel and equipment 

construction and operation. 

Consultation with the State Historic Preservation Officer (SHPO) has been initiated and 

will continue through development of the EIS. Review comments provided by the SHPO 

have been incorporated into this document. This project is located in areas that are 

primarily low sensitivity zones for the presence of cultural resources as identified in the 

Third Amended Programmatic Agreement Among the USDA Forest Service, Alaska 

Region, the Advisory Council on Historic Preservation and the Alaska State Historic 

Preservation Officer Regarding Heritage Program Management on National Forest in 

Alaska (Gilliam 2012; USDA 2010). This cultural resource EIS analysis relies on Forest 

Service field observations from project archaeological surveys for the Section 106 

process in addition to the assessment of sensitivity zones described in the programmatic 

agreement as the primary factor for determining potential impacts on undocumented 

cultural resources. Previously documented sites within 0.5 miles of project alternatives 

were also included in the analysis of potential effects. 

The A Road connecting the crew ferry dock and to the facilities at the cannery crosses the 

Hawk Inlet Overland Route (JUN-01137); however, this portion of the road that crosses 

the route would not be adversely affected by any of the alternatives. In determining the 

Hawk Inlet Overland Route as eligible, the Forest Service also determined that existing 

conditions (including use of the road crossing the route) do not negatively affect the 

integrity of the property such that it is unable to convey its significance under Criterion 

A. Thus, the project would have no adverse effect on the route (Gilliam 2012). The 

Forest Service determined that no historic properties would be adversely affected by any 

of the proposed alternatives, resulting in a determination of “No Adverse Effect.” The 

SHPO concurred with the Forest Service’s finding (Bittner 2012). 

3.17.3.2 Effects of Alternative A, No Action 

Under Alternative A, current mining activities would continue under existing permits. 

Tailings would continue to be disposed at the existing TDF until 2019 at which point the 

TDF will have reached capacity. Continued use of the Greens Creek Mine, and TDF 

until 2019 may result in direct and indirect effects on cultural resources as a result of 

material spills, fuel spills or discharge of water from the current underground drainage 
Chapter 3. Affected Environment and Environmental Consequences

3-254 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

system. Risk of project personnel visiting a site and causing damage or disturbance to its 

historic context would continue throughout the life of the project. Currently, appropriate 

identification efforts have already been conducted for the current project, and it is likely 

that no additional sites will be found in this area; two previously identified sites (Hawk 

Inlet Cannery and Jacobsen’s Cabin) are within 0.5 miles of the existing site although the 

Jacobsen Cabin has been previously determined ineligible for the NRHP. Alternative A 

would have the least potential for impacts on cultural resources due to lack of 

construction activities and shortened project timeline that extends only through 2019. 

3.17.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B the existing TDF would be expanded to allow for approximately 

30-50 years of continued production at the current production rates. Alternative B would 

require expanding the existing TDF southward, increasing the facilities lease area. 

No previously identified sites are located within the proposed footprint of project 

components under this alternative; however three sites (Hawk Inlet Cannery, Jacobsen’s 

Cabin, and Soldier’s Additional Homestead Claim) are located within 0.5 miles and could 

experience indirect effects. As discussed above, the Jacobsen’s Cabin has been 

previously determined ineligible for the NRHP. Undocumented cultural resources within 

the proposed TDF expansion and associated structures could be affected due to the 

expansion of the existing TDF. Although Alternative B (128 acres) would have the least 

estimated amount of new disturbance compared to the disturbances under alternatives C 

(174 acres) and D (185 acres), the potential for disturbance to undocumented cultural 

resources would be greater under Alternative B. This assessment is based on Forest 

Service field observations that indicated that Alternative B is closer to fresh water and 

closer to the coast, which increases the potential for encountering undocumented cultural 

resources. Applying the Forest Service programmatic agreement sensitivity zone criteria, 

Alternative B also has more project components on land lower than 100 feet in elevation 

(high sensitivity) and is close to the anadromous stream of Tributary Creek (high 

sensitivity). Additionally, compared to the no action alternative, the length of time for 

uncovering unidentified cultural resources would be extended due to the projected 50 

year timeline. Risk of project personnel visiting a site and causing damage or disturbance 

to its historic context would continue throughout the life of the project and be greater 

than Alternative A because of the expanded TDF area and extended project timeline. 

3.17.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF with additional expansion of the existing TDF to the south to accommodate an 

additional 12.2 million cubic yards of tailings. Tailings placement would avoid Tributary 

Creek. In addition, the reclamation material storage area and quarry to the south of the 

TDF proposed under Alternative B would be relocated out of the Monument. The result 

would be a new reclamation material storage area located near the junction of the A and 

B roads; moving the quarry out of the Monument would require deepening the quarry at 

the north end of the existing TDF. 

Potential effects to undocumented cultural resources would be similar to those described 

for Alternative B. The new disturbance footprint would be smaller than under 

Alternative B (126 acres versus 128 acres), although some of the new disturbance would 
3.17 Cultural Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-255 

occur near the junction of the A and B roads; this area would be less sensitive than the 

Tributary Creek area where the corresponding facilities are proposed under Alternative B. 

Therefore, Alternative Mitigated B would result in a lower potential for encountering 

undocumented cultural resources than Alternative B. 

Risk of project personnel visiting a site and causing damage or disturbance to its historic 

context would continue throughout the life of the project and be greater than Alternative 

A because of the expanded TDF area and extended project timeline. 

3.17.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Under Alternative C, a new TDF would be created approximately three miles north of the 

existing TDF. Since Alternative C requires the construction of a new TDF, a small 

expansion of the existing TDF would be necessary to accommodate three years’ worth of 

tailings and waste rock disposal during the time necessary to develop the new TDF. 

No previously identified sites are located within the proposed new TDF for this 

alternative; however two sites (Hawk Inlet Cannery and Jacobsen’s Cabin [NRHP 

ineligible]) are located within 0.5 miles and could experience indirect effects. In addition 

to increasing the length of time in which cultural materials may be discovered and 

potentially damaged, unidentified cultural resources within the new TDF could be 

affected due to construction of the TDF and associated activity. As discussed above, the 

estimated amount of disturbance under Alternative C would be greater than alternatives 

A, B, or Mitigated B but based on field observations by the Forest Service, Alternative C 

has lower potential for encountering undocumented cultural resources than Alternative B. 

Furthermore, of the three action alternatives, Alternative C has the fewest project 

components below 100 feet in elevation (high sensitivity areas). Like portions of 

alternatives B and Mitigated B, Alternative C is located near an anadromous stream 

(Fowler Creek) (high sensitivity). Risk of project personnel visiting a site and causing 

damage or disturbance to its historic context would continue throughout the life of the 

project and be similar to alternatives B and Mitigated B. 

3.17.3.6 Effects of Alternative D, Modified Proposed Action 

Under Alternative D, the existing TDF would be expanded to accommodate for an 

additional 10 years of use. In addition, a new TDF and upgraded haul road would be 

constructed three miles north of the existing TDF. 

Similar to Alternative C, Alternative D proposes constructing a new TDF as well as 

expand the existing TDF. No previously identified sites are located within the new TDF 

under this alternative; however two sites (Hawk Inlet Cannery and Jacobsen’s Cabin 

[NRHP ineligible]) are located within 0.5 miles and could experience indirect effects. 

The expansion under Alternative D would pose a greater potential for destroying 

unidentified cultural resources than alternatives A, B, and C. In addition to increasing the 

length of time for uncovering cultural materials by extending the mine’s operating 

capacity, unidentified cultural resources within the new TDF and associated structures 

could be affected due to construction of this facility as well as associated activity. The 

estimated amount of disturbance under Alternative D would be greatest among 

alternatives; however based on field observations by the Forest Service, Alternative D 

has lower potential for encountering undocumented cultural resources than Alternative B 

or Mitigated B. Furthermore Alternative D has fewer project components below 100 feet 
Chapter 3. Affected Environment and Environmental Consequences

3-256 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

in elevation (high sensitivity areas). Like Alternative C, Alternative D is located near an 

anadromous stream (Fowler Creek) (high sensitivity). Risk of project personnel visiting 

a site and causing damage or disturbance to its historic context would continue 

throughout the life of the project and be similar to alternatives B, Mitigated B, and C 

because of the upgraded haul road, expanded and new TDF, and extended project 

timeline. 

3.17.4 Cultural Resources Summary 

Alternative A would have the least potential for impacts on cultural resources due to the 

least amount of disturbance and shortened project timeline that extends through 2019. Of 

all the action alternatives, Alternative B would have the greatest potential for impacts on 

cultural resources due to the higher potential for encountering undocumented cultural 

resources, greatest proximity to high sensitivity zones (e.g., areas lower than 100 feet in 

elevation), and potential indirect effects on one unevaluated site (Soldier’s Additional 

Homestead Claim) (in addition to the effects to two sites that are common to all action 

alternatives). Alternative Mitigated B would have less potential for impacts on cultural 

resources than Alternative B because of the smaller estimated disturbance and movement 

of project components away from a high sensitivity area (i.e., Tributary Creek). 

Although having a larger area of estimated disturbance, Alternatives C and D would 

pose less risk to impacts on cultural resources due to lower potential for encountering 

undocumented cultural resources and fewer project components close to high sensitivity 

zones. The existing road connecting the Crew Ferry Dock to the mine crosses the Hawk 

Inlet Overland Route (JUN-01137) (determined NRHP eligible by Forest Service in 

2012); however, this portion of the road that crosses the route would not be directly 

affected by any of the alternatives. Furthermore, by determining the Hawk Inlet 

Overland Route as eligible, the Forest Service determined that existing conditions 

(including use of the road over the route) do not negatively affect the integrity of the 

property such that it is unable to convey its significance under Criterion A. Thus, there 

would be no adverse effect to the route from the project (Gilliam 2012). In summary, the 

Forest Service determined that no historic properties would be adversely affected by the 

project alternatives resulting in a determination of “No Adverse Effect.” In addition, the 

Forest Service intends to work with the Angoon Community Association to avoid, 

minimize, or mitigate effects to sacred lands (Gilliam 2012). Consultation with the 

SHPO has been initiated and will continue through development of the EIS. Review 

comments provided by the SHPO have been incorporated into this document. 

3.17.5 Recommended Mitigation 

Access related effects could be mitigated through implementation of a Cultural Resources 

Management Procedure that includes annual training for employees/contractors, posting 

of cultural resource information including company policy regarding cultural resources, 

and maintaining confidential records for all sites, with record access limited to designated 

employees. Continued enforcement of procedures related to cultural resources such as 

halting operations when cultural resources are found and documenting the site will help 

mitigate any potential effects in the unlikely event that previously unidentified cultural 

resources are located in the expansion areas. If material for reclamation of mine 

components is obtained from areas outside of the existing footprint or from areas not 
3.18 Socioeconomics 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-257 

previously surveyed, previously undocumented cultural resources could be affected. 

These areas should be surveyed carefully prior to ground disturbing activity. If a cultural 

resource is found, it should be assessed for eligibility for the NRHP and avoided or 

mitigated in an appropriate manner. 

Appendix B notes that a number of reasons contribute to the reduction in traditional and 

customary uses within Hawk Inlet including closure of the cannery, the high cost of fuel 

to run outboard motors, and operations of the Greens Creek Mine. The effect would 

continue to occur under all alternatives. The Forest Service does not believe that 

additional information would influence the decision in this particular case; however, it 

recognizes that additional detail on the customary and traditional uses of Hawk Inlet 

could benefit future decision-making processes and provide greater detail on the history 

of the area. Therefore, the Forest Service is requiring that HGCMC document the history 

of Hawk Inlet and the cannery, including the customary, traditional, and contemporary 

use of the area based on research in the relevant communities and a review of available 

literature. The first step in the process will be for HGCMC to submit a study plan to the 

Forest Service for approval. 

3.18 Socioeconomics ____________________________ 

The purpose of this section is to describe 

socioeconomics in the Greens Creek Mine area and 

to assess potential impacts related to the proposed 

expansion of the TDF at Greens Creek Mine. The 

proposed TDF expansion at the Greens Creek Mine 

would either extend or terminate the life of the 

Greens Creek Mine and would, therefore, have the 

potential to affect socioeconomic resources in the 

CBJ. Socioeconomic effects are focused on the CBJ because that is where the majority 

of effects are realized, such as local employment and income, population, school 

enrollment, housing, and local government revenues. 

3.18.1 Socioeconomics – Pre-mining Environment 

Mining played an important role in the economy of Southeast Alaska from 1906 through 

the mid-1950s. Its economic importance declined following closure of the Alaska-Juneau 

Mine in 1944 and establishment of the pulp mill in Ketchikan in 1954 (Forest Service 

1983). The Greens Creek final EIS (2003) assessed potential socioeconomic impacts to 

the communities of Juneau, Angoon, and Hoonah. 

The CBJ had a total population of 21,080 in 1981 and the local economy was heavily 

dependent on government employment in 1982, with state and federal jobs accounting for 

a combined total of 57 percent of total employment. Juneau typically had a higher per 

capita income and a lower unemployment rate than elsewhere in the State of Alaska in 

the early 1980s (Forest Service 1983). 

The City of Angoon, located on the west coast of Admiralty Island at the mouth of 

Kootznoowoo Inlet, about 44 miles southwest of Greens Creek Mine, is a Tlingit Indian 

community. Angoon had a population of 445 in 1981. Salmon fishing was identified as 

The resource analysis of 

socioeconomics was not identified 

as a significant issue; comments 

from the scoping process 

regarding socioeconomics are 

addressed in this section.
Chapter 3. Affected Environment and Environmental Consequences

3-258 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the main source of employment in the community, with most residents relying heavily on 

subsistence resources (Forest Service 1983). 

The City of Hoonah, located on Chichagof Island, about 20 miles west of the mine, is 

another Tlingit community. Hoonah had a population of 800 in the early 1980s. 

Commercial fishing and government were identified as the main employers in Hoonah, 

with subsistence continuing to play an important role for many local households, some of 

whom occasionally visited Hawk Inlet (Forest Service 1983). 

3.18.2 Socioeconomics – Baseline Conditions 

The Greens Creek Mine is located on northern Admiralty Island, approximately 18 miles 

southwest of the city of Juneau. Juneau City and Borough annexed Greens Creek Mine 

in 1994 and the northern part of Admiralty Island, excluding the Mansfield Peninsula. 

The Mansfield Peninsula and the Monument south of the Greens Creek Mine area are 

part of the Hoonah-Angoon Census Area, which, as the name suggests, also includes the 

communities of Hoonah and Angoon.6

3.18.2.1 Employment and Income 

A total of 17,932 non-agricultural wage and salary (NAWS) jobs were identified in the 

CBJ in 2010, with a total combined payroll of $790 million (Table 3.18-1). These data 

are compiled from unemployment insurance coverage data and do not include selfemployed workers. There were an estimated 1,531 self-employed workers in Juneau in 

2008 (Juneau Economic Development Council [JEDC] 2010a).

Table 3.18-1. Annual Employment and Earnings CBJ, 2010. 

Economic Sector 

Annual Average 

Employment Annual Earnings Average 

Monthly 

Earnings ($) 

Number 

of Jobs 

Percent 

of Total 

Millions 

of Dollars 

Percent 

of Total 

Total Nonfarm 19,912 100 790 100 3,673 

Goods Producing 1,564 8 104 13 5,558 

Services Providing 10,912 55 287 36 2,681 

Natural Resources and Mining 556 3 51 6 7,604 

Construction 729 4 44 6 5,001 

Manufacturing 279 2 10 1 2,937 

Trade/Transportation/Utilities 3,274 18 101 13 2,566 

Retail Trade 1,996 11 51 6 2,134 

Information 245 1 12 1 3,932 

 

6

 Southeast Alaska is divided into six boroughs and two census areas. The six boroughs correspond with 

the county governments found elsewhere in the United States. Four of these boroughs, Juneau, Sitka, 

Yakutat, and Wrangell are city/boroughs. The other two, Ketchikan Gateway and Haines, have 

independent incorporated communities within their boundaries. The remaining unorganized area is 

allocated to two census areas (CAs). While CAs are only statistical units, they are widely recognized from 

a data reporting standpoint by federal agencies and most state agencies as county equivalents. 
3.18 Socioeconomics 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-259 

Table 3.18-1. Annual Employment and Earnings CBJ, 2010. 

Economic Sector 

Annual Average 

Employment Annual Earnings Average 

Monthly 

Earnings ($) 

Number 

of Jobs 

Percent 

of Total 

Millions 

of Dollars 

Percent 

of Total 

Financial Activities 608 3 29 4 3,975 

Professional & Business Services 918 5 37 5 3,399 

Educational & Health Services 1,796 10 64 8 2,964 

Leisure & Hospitality 1,464 8 25 3 1,424 

Other Services 611 3 19 2 2,626 

Government 7,436 37 399 50 4,468 

Federal Government 840 5 73 9 7,215 

State Government 4,276 24 218 28 4,243 

Local Government 2,320 13 108 14 3,887 

Source: ADOL 2011a. 

Notes: 

ADOL – Alaska Department of Labor and Workforce Development. 

JEDC – Juneau Economic Development Council. 

These data are compiled from unemployment insurance coverage data and exclude self-employed 

workers because they are not covered by unemployment insurance. In 2008, there were 1,531 selfemployed residents in Juneau, which was equivalent to about 8 percent of total NAWS employment in 

2008. The top three self-employed occupations were Professional Services, Fishing, and Construction. 

Note that self-employed workers may also hold jobs counted by ADOL (JEDC 2010a). 

The government sector dominates the Juneau economy accounting for 42 percent of total 

NAWS employment and 50 percent of total annual earnings (Table 3.18-1). These totals 

include federal, state, and local jobs. State of Alaska government employment alone 

accounts for almost one-quarter of total NAWS employment and 28 percent of total 

payroll. 

The Natural Resources and Mining sectors employed 556 people in the CBJ in 2010, 

about 3 percent of total NAWS employment and 6 percent of total payroll (Table 3.18-1). 

The government sector dominates the economy in the Hoonah-Angoon CA, accounting 

for 53 percent of total employment and 62 percent of total earnings in 2010. The 

majority of this employment, 36 percent of total employment, is in local government. 

The leisure and hospitality sector is also a major employer, accounting for 8 percent of 

total employment (ADOL 2011a). 

Greens Creek Mine was identified as Juneau’s largest private employer in 2009 (and the 

fourth largest private employer in southeast Alaska), with 333 employees (JEDC 2010a). 

The mine presently employs nearly 330 people with an annual payroll over $32 million. 

The majority of the workers employed at the mine reside in Juneau and commute daily to 

the mine site via ferry. A smaller component of the labor force is comprised of workers 

from elsewhere in Alaska and the lower 48 states who reside in dormitory style housing 

at Hawk Inlet. According to ADOL (2011f), 25.1 percent of the workforce employed by 

the Hecla Greens Creek Mining Corporation in 2009 was nonresident. 
Chapter 3. Affected Environment and Environmental Consequences

3-260 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Gold and silver prices continue to be relatively high, with the price of gold (unadjusted 

for inflation) 28 percent higher in April 2011 than one year earlier (April 2010), and 66 

percent higher than it was in April 2009 (World Gold Council 2011). On average, 

mining workers in Southeast Alaska earned slightly less than $116,000 each in 2010 

(wage data are not available for this sector for the CBJ alone), about 2.4 times the 

average annual wage in Southeast Alaska and 2.6 times the average wage in the CBJ 

(ADOL 2011a). 

Total NAWS employment in the CBJ was approximately 3 percent higher (601 jobs) in 

2010 than in 2002. Employment was higher in 2010 in the Natural Resources and 

Mining, Trade/Transportation/Utilities, Educational & Health Services, and Local 

Government sectors and lower in the Construction, Leisure & Hospitality, and State 

Government sectors (ADOL 2011a). In 2002, State Government accounted for 26 

percent of total NAWS employment and 30 percent of total payroll compared to 24 

percent and 28 percent in 2010, respectively. 

The CBJ had an unemployment rate of 5.3 percent in April 2011, compared to a 

Statewide average rate of 7.7 percent. The unemployment rate in the Hoonah-Angoon 

CA in April 2011 was 19.5 percent. Annual unemployment rates for Juneau, the 

Hoonah-Angoon CA, and the State of Alaska as a whole in 2010 were 5.8 percent, 15.4 

percent, and 8.0 percent, respectively (ADOL 2011b). 

Median household income in Alaska was about one-third higher than the national average 

in 2009. Median household income in the CBJ was 9 percent higher than the statewide 

median. In the Hoonah-Angoon CA, median household income was just two-thirds of 

the statewide median (Table 3.18-2). The percent of the population below the poverty 

level in Juneau was less than half the national average and slightly more than two-thirds 

of the state average, 6.6 percent versus 14.3 percent and 9.1 percent, respectively. The 

percent of the population below the poverty level in the Hoonah-Angoon Census Area 

was higher than the national average and almost twice the state average (Table 3.18-2). 

Residents and representatives from Angoon have expressed concern about the economic 

challenges faced by the community and because there is little benefit realized, in terms of 

employment or some other governmental revenue, from the mine located 44 miles to the 

north. 

Table 3.18-2. Income and Poverty, 2009. 

Area 

Median Household Income Percent of 

Population in 

Poverty (2009) b Dollars (2009) 

Percent of National/ 

State Median a

City and Borough of Juneau 73,044 109 6.6 

Hoonah-Angoon Census Area 41,824 63 17.2 

Alaska 66,712 133 9.1 

United States 50,221 n/a 14.3 

Source: U.S. Census Bureau. 2010. 

Notes: 

a. Statewide median household income is presented as a percent of the national median; county 

medians are shown as a percentage of the state median. 

b. This represents the percentage of the population of all ages below the poverty level. 
3.18 Socioeconomics 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-261 

3.18.2.2 Population 

The CBJ had a total population of 31,275 in 2010 (Table 3.18-3). According to the JEDC 

(2010a), between 2,700 and 2,900 permanent residents move to and from Juneau each 

year. From 2000 to 2009, Juneau experienced a net loss of 2,399 people through outmigration, as well as a slight natural decrease (more deaths than births). Population did, 

however, increase between 2009 and 2010, and the Census identified 564 more residents 

in Juneau in 2010 than it had a decade earlier in 2000, an increase of 1.8 percent. 

Population decreased by 1.9 percent in southeast Alaska over this period, while the State 

of Alaska as a whole experienced a net increase of 13.3 percent (Table 3.18-3). 

Population in the Hoonah-Angoon Census Area decreased by 13.9 percent between 1990 

and 2000, and further decreased 16.5 percent between 2000 and 2010 (Table 3.18-3). 

Table 3.18-3. Population 1990 to 2010. 

Geographic Area 1990 2000 2010 

1990-2000 Change 2000-2010 Change 

Number Percent Number Percent 

Juneau City and Borough 26,751 30,711 31,275 3,960 14.8 564 1.8 

Angoon 638 572 459 -66 -10.3 -113 -19.8 

Hoonah 795 860 760 65 8.2 -100 -11.6 

Hoonah-Angoon CA 2,988 2,574 2,150 -414 -13.9 -424 -16.5 

Southeast Alaska 68,989 73,082 71,664 4,093 5.9 -1,418 -1.9 

Alaska 550,043 626,932 710,231 76,889 14.0 83,299 13.3 

Sources: ADOL 2011c, 2011d; Forest Service 2008a. 

The State of Alaska has developed three series of population projections (low, middle, 

and high) for 2010 through 2034. The middle series of projections for Juneau anticipate 

that population will stay relatively constant over the next 20 years, with a total population 

of 30,191 projected for 2034 (ADOL 2011e). Over a similar period, the Hoonah-Angoon 

CA population is projected to decrease to a total population of 1,385 in 2035, making it 

the census area with the greatest levels of projected average annual population loss over 

the projection period at -1.4 percent (ADOL 2012). Residents and representatives from 

Angoon have expressed concern over the population loss and the need for jobs in the 

community. 

Race and Ethnicity 

The majority of the populations of the CBJ and the State of Alaska are White, with White 

persons making up 70 percent of the population in Juneau and 67 percent statewide 

(Table 3.18-4). The largest minority group identified in the affected area and statewide in 

the 2010 census was American Indian and Alaska Native. Alaska Natives accounted for 

12 percent of the population in Juneau and 15 percent in Alaska. Alaska Natives 

comprise 53 percent of the total population in Hoonah and 76 percent of the total 

population in Angoon, but a smaller share of the total population in the Hoonah-Angoon 

CA (Table 3.18-4). 
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3-262 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.18-4. Race and Ethnicity, 2010. 

Area 

Total 

Population 

Percent of Total 

White 

American 

Indian/ Alaska 

Native Asian 

Other 

Race a

Two or 

More 

Races Hispanic b

Census Tract 6 c 5,474 76 11 2 3 8 4 

City and Borough 

of Juneau 31,275 70 12 6 3 9 5 

Hoonah 760 33 53 1 1 14 3 

Angoon 459 10 76 0 1 12 8 

Hoonah-Angoon 

Census Area 2,150 47 41 1 1 10 4 

Alaska 710,231 67 15 5 6 7 6 

Source: ADOL 2011f. 

Notes: 

a. The “Other Race” category presented here includes census respondents identifying as “Black or 

African American,” “Native Hawaiian and Other Pacific Islander,” or “Some Other Race.” 

b. The federal government considers race and Hispanic/Latino origin to be two separate and distinct 

concepts. People identifying Hispanic or Latino origin may be of any race. 

c. Census Tract 6 within the CBJ encompasses Douglas Island and the portion of Admiralty Island that 

includes the Hecla Greens Creek Mine. 

The Hecla Greens Creek Mine is located in Census Tract 6 of the CBJ. In addition to the 

part of Admiralty Island annexed by Juneau, this Census Tract also includes Douglas 

Island. The population in this Census Tract was predominantly White (76 percent), with 

Alaska Natives comprising 11 percent, which is less than the State of Alaska average of 

15 percent (Table 3.18-4). 

3.18.2.3 School Enrollment 

A total of 4,953 K-12 students were enrolled in the Juneau School District in 2009/2010. 

The total number of students enrolled has steadily decreased since the 2001/2002 school 

year (Table 3.18-5). The number of students enrolled in 2009/2010 was, however, 

slightly higher than in the preceding year and the JEDC (2010a) anticipates that school 

enrollment will increase in the future. The Chatham School District operates two schools 

in Angoon with 75 students attending in 2012 (ADCCED 2012). 
3.18 Socioeconomics 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-263 

Table 3.18-5. Juneau School District K-12 Enrollment. 

School Year Number of Students Rate of Change 

2000/2001 5,463 -- 

2001/2002 5,540 1.4% 

2002/2003 5,506 -0.6% 

2003/2004 5,429 -1.4% 

2004/2005 5,310 -2.2% 

2005/2006 5,218 -1.7% 

2006/2007 5,161 -1.1% 

2007/2008 5,042 -2.3% 

2008/2009 4,930 -2.2% 

2009/2010 4,953 0.5% 

Source: JEDC 2010a. 

3.18.2.4 Housing 

According to the Juneau City Assessor, there were a total of 12,974 housing units in 

Juneau in 2010, with single-family homes making up almost half the total housing stock 

(Table 3.18-6). Housing surveys conducted by the CBJ in 2001 and again in 2008 found 

that the number of housing units increased by 704 (6 percent) over this period, with 

apartment units accounting for the majority (97 percent) of this increase (JEDC 2010a). 

Juneau has historically had low rental vacancy rates. The 2010 Census identified a rental 

vacancy rate of 3.6 percent in Juneau in 2010, slightly more than half the State of Alaska 

average (6.6 percent) (ADOL 2011h). In the Hoonah-Angoon CA, there are about 256 

total housing units with 167 housing units occupied, 89 vacant, and 49 vacant due to 

seasonal use. About 52 percent of the housing units are owner-occupied; the remaining 

82 units are rented (ADCCED 2012). 

Table 3.18-6. Housing in Juneau, 2010. 

Type of Housing Number of Units Percent of Total 

Single-Family Homes 6,349 49% 

Apartments 2,309 18% 

Multi-Unit Dwellings 1,745 13% 

Mobile Home/Cabin 1,381 11% 

Condos and Townhouses 1,190 9% 

Total 12,974 100% 

Source: JEDC 2010b. 
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3-264 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.18.2.5 Local Government Revenue 

Estimated funding sources for the CBJ are presented for Fiscal Year 2011 in Table 

3.18-7. User fees and permits were the largest single source of estimated revenue (and 

funding) for Fiscal Year 2011, accounting for 37.6 percent of total funding. Taxes, 

including property tax, sales tax, alcohol tax, tobacco excise tax, and hotel tax, were the 

second largest source accounting for 25.8 percent of total estimated funding (Table 

3.18-7). 

Table 3.18-7. Estimated Funding Sources for the City and Borough of Juneau Fiscal 

Year 2010. 

Source 

Estimated 

Revenue 

Percent 

of Total 

State Support $16,694,100 5.1% 

Federal Support $2,767,300 0.9% 

Taxes $83,663,600 25.8% 

User Fees and Permits $122,101,100 37.6% 

Penalties and Fines $925,800 0.3% 

Investment Interest and A/R $4,528,200 1.4% 

Property Sales and Rent $4,430,400 1.4% 

Special Assessments $69,300 0.0% 

Other Miscellaneous Revenue $94,500 0.0% 

Total Revenue $235,274,300 72.5% 

Replacement Reserve Contribution -$32,600 0.0% 

Fund Balance Usage Excluding the General Fund $6,573,600 2.0% 

General Fund Balance Usage $3,270,300 1.0% 

Support from Other Funds $79,620,000 24.5% 

Total Revenue, Fund Balance Usage and Support from Other Funds $324,705,600 100.0% 

Source: CBJ 2010. 

Operation of the Greens Creek Mine presently generates annual property tax revenues. 

According to the CBJ (2010), which ranked principal property tax payers based on 

taxable assessed value in 2010, Hecla Greens Creek Mining was ranked first with a 

taxable assessed value of approximately $166 million and accounted for 4.22 percent of 

total taxable assessed value in the City and Borough. Alaska Electric Light & Power 

ranked second, with a taxable assessed value of about $93 million, 2.36 percent of the 

City and Borough total. 

3.18.3 Socioeconomics – Environmental Consequences 

3.18.3.1 Effects Common to All Alternatives 

A key component in assessing the socioeconomic impacts of the proposed alternatives is 

the operating life of the mine under each alternative. Other operating criteria are 

assumed to remain constant. For the purposes of analysis, under Alternative A the mine 
3.18 Socioeconomics 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-265 

is expected to close in 2019. The other four alternatives assume that the mine would 

continue to operate at current levels for 30–50 years. Current annual benefits, which 

would be realized in the CBJ, are summarized in Table 3.18-8. These benefits would be 

expected to end in 2019 under Alternative A and would continue 30–50 years under the 

action alternatives. 

Table 3.18-8. Annual Socioeconomic Impacts. 

 Direct Indirect Total 

Employment a 333 160 493 

Income a, b $38,547,414 $9,636,854 $48,184,268 

Population c 650 324 974 

School Enrollment d 130 65 196 

Housing e 260 130 390 

Source: ADOL 2011a, 2011f, 2011g; Forest Service 2008a. 

Notes: 

a. Employment and payroll multipliers were developed from the Impact Analysis for Planning 

(IMPLAN) Model, which resulted in an employment multiplier of 1.48 and a payroll multiplier of 

1.25. In this case, the “indirect” category includes both indirect and induced employment and 

income. Refer to Forest Service 2008a for more information. 

b. Direct payroll is estimated based on the average annual salary for the Alaska mining sector in 

2010. Note that this is higher than the recent estimate of about $32 million provided by the mine 

(HGCMC 2011). 

c. Population estimates are based on shares of resident versus nonresident workers and family 

versus non-family households. 

d. School enrollment is based on an average ratio of one school age child for every five residents. 

e. Housing estimates are based on an average household size of 2.5 as measured in the 2010 

Census. 

The following analysis assumes that closure of the mine would result in the loss of 333 

direct jobs. The analysis also assumes that the share of the affected labor force that 

presently resides in Juneau and their families would, as a result, leave Juneau. Assuming 

that all former employees and their families would relocate following closure of the mine 

represents a worst case scenario for the purposes of analysis. It is, however, also possible 

that other residents presently employed in jobs indirectly supported by the mine’s 

operation would relocate from Juneau if the mine were to close and their jobs were lost. 

Closure of the Hecla Greens Creek Mine would also result in a loss of property tax 

revenue to the CBJ. The mine accounted for 4.22 percent of total taxable assessed value 

in the CBJ in 2010 (CBJ 2010). If the mine were to close, the value of the mine would be 

reduced to its salvage value, a fraction of its current value, with a commensurate 

reduction in property tax revenue. Further, were the mine to permanently close, per the 

Exchange Act and Agreement, the lands owned and occupied by HGCMC would revert 

to federal ownership and would be entirely removed from the local tax base. As noted in 

the baseline conditions discussion, the economic effects from mine operations are 

realized in the CBJ more than anywhere else. This is expected to be the case for future 

operation under any alternative. There would be little economic benefit to the 

community of Angoon or other communities located in proximity of the mine. 
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3-266 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.18.3.2 Effects of Alternative A, No Action 

Under Alternative A, mining operations would continue through 2019. Impacts similar to 

those associated with ongoing mining activities would continue until mining ceased. The 

TDF would continue to be built out to the maximum footprint and height permitted in the 

2003 EIS (Forest Service 2003). The mine would continue to support the annual direct 

and indirect employment and associated payroll through 2019 (Table 3.18-8). Following 

2019, the mine would close, which would result in an annual loss of most of the 493 

direct and indirect jobs and $48 million in direct and indirect payroll (Table 3.18-8). 

Assuming the workers directly employed by the mine and their families would move 

from Juneau would result in a net loss of 650 residents or about 2 percent of the total 

2010 population of the CBJ (Table 3.18-8). Closure of the mine would also result in a 

loss of property tax revenues and operating fees that would otherwise be paid to the CBJ. 

3.18.3.3 Effects of Alternative B, Proposed Action 

Under Alternative B, mining activities would extend an additional 30–50 years, and the 

TDF would be expanded immediately adjacent to the existing TDF. Viewed in terms of 

the annual benefits summarized in Table 3.18-6, this would result in the continued direct 

and indirect employment of an estimated 493 workers, as well as a total of $48 million in 

direct and indirect payroll based on the estimates presented in Table 3.18-8. The mine 

would continue to pay property taxes to the CBJ. 

Full build-out for development, construction, and reclamation under this alternative 

would employ additional contractors for site preparation, additional investigations, 

construction, and specialized work, like liner installation. The current mine work force 

would also do much of the work. 

3.18.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF. Approximately half of the material would be placed in the initial phase of the 

expansion with the remaining volume being placed in the final phase. In addition, the 

reclamation material storage area and quarry to the south of the TDF would be relocated 

out of the Monument. The result would be a new reclamation material storage area 

located near the junction of the A and B roads; moving the quarry out of the Monument 

would require deepening the quarry at the north end of the existing TDF. There are no 

differences in socioeconomic effects between Alternative B and Mitigated Alternative B. 

3.18.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would involve the initial short-term expansion of the existing TDF and the 

construction of a new TDF located approximately three miles north of the existing TDF. 

Alternative C would also extend the operating period of the mine by 30–50 years. This 

would result in the same annual and total economic benefits as Alternative B. 

Construction under Alternative C would be relatively condensed, with the A Road 

needing to be upgraded, the new TDF built and the existing TDF expanded (land 

clearing, drain and liner placement) all within the first 3 years and, as a result, this 

alternative could employ a small additional number of contractors relative to Alternative 

B, but the difference would be minimal. 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-267 

3.18.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would involve both the expansion of the existing TDF and the construction 

of the new TDF to the north. Like alternatives B and C, Alternative D would extend the 

operating period of the mine by 30–50 years. 

This would result in the same annual and total economic benefits as alternatives B and C. 

3.18.4 Socioeconomics – Summary 

Alternative A would have the largest impact on jobs, income, and tax revenues in the 

CBJ. Further, assuming the workers presently employed by the mine and their families 

would move from Juneau; Alternative A would result in a reduction in local population 

sooner. Mining operations would extend for an additional 30–50 years under the action 

alternatives and would likely result in continued levels of employment, income, and tax 

revenues in the CBJ. Full built-out for development, construction, and reclamation under 

these alternatives would employ a small number of contractors (about 10) for specialized 

work. 

3.19 Monument Resources _______________________ 

The location of mine facilities, including the 

proposed TDF expansion, within the Monument 

was identified as a significant issue during scoping. 

Although ANILCA permits the holders of valid 

mining claims to carry out activities related to the 

exercise of rights under those claims, any lease of 

Monument lands for mining must not cause 

irreparable harm to Monument resources. 

The 2008 Tongass National Forest Land and 

Resource Management Plan (Forest Plan) governs 

Forest Service administered public lands and 

resources within and surrounding the Greens Creek 

Mine area. This includes land within both the 

Tongass National Forest and the Monument. The 

majority of the proposed TDF expansion area will 

be located within the Monument; the Forest Plan 

designation for this area is “Non-Wilderness National Monument,” although the Forest 

Service land use prescription for the area allows HGCMC to “facilitate the development 

of mineral resources in a manner compatible with National Monument purposes.” 

As defined in the Forest Plan, the desired condition for the Monument is “During mining 

operations, mining activities are localized and limited to the area necessary for their 

efficient and orderly development. Off-site effects to Monument resources are minimal, 

and most Monument users are not aware of, or affected by, the mines. After the 

completion of mining, reclamation of the affected areas is done to minimize the evidence 

of past mining and, to the maximum extent feasible, seek to return the area to generally 

natural conditions. Ultimately, the entire Non-wilderness National Monument provides 

Impacts related to expanding the 

TDF further into the Monument is 

identified as significant Issue 4. 

Concerns raised during scoping 

include disclosing any reasonably 

foreseeable activities that would 

affect the intrinsic and ecological 

resources of the Monument. 

Measures of impacts to the 

Monument include the potential 

for reclamation of impacted areas 

to pre-project conditions and 

acres disturbed in the Monument.
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3-268 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the same natural settings and recreation experiences as the adjacent Wilderness National 

Monument areas.” 

Goals identified in the Forest Plan for non-wilderness portions of the Monument include 

the following: 

 Preserving intact a unique coastal island ecosystem to ensure continued opportunities 

for study of Admiralty Island’s ecology and its notable cultural, historical, and 

wildlife resources, within its relatively unspoiled natural ecosystem; 

 Protection and study of Tlingit cultural resources, other historical resources; brown 

bear and bald eagle populations are specifically directed; 

 Facilitate the development of significant mineral resources located within portions of 

Admiralty Island; 

 Protect objects of ecological, cultural, geological, historical, pre-historical, and 

scientific interest; 

 Minimize effects on non-mineral resources to the extent feasible; 

 Limit mining activities to claims with valid existing rights, and to the land area 

actually needed to carry out mining operations; and 

 In the long term, when mining is completed, to reclaim areas disturbed by mining to a 

near-natural condition. 

Objectives identified in the Forest Plan for Non-wilderness National Monument lands 

include the following: 

 Ensure that the Plan of Operations for each mineral development specify the activities 

to be conducted, the location and timing of those activities, and how the environment 

and resources in each area will be protected through compliance with federal and 

state requirements. 

 In areas affected by mining, manage activities to maintain the productivity of 

anadromous fish and other foodfish habitat to the maximum extent feasible. Stress 

protection of fish habitat to prevent the need for mitigation. 

 In areas affected by mining, manage public recreation use as directed in the Plan of 

Operations.

 Develop reclamation plans prior to project initiation. Include, as needed, 

rehabilitation of fish and wildlife habitats, soil resources, and the scenery.

In the long term, when mining is completed, areas disturbed by mining are to be returned 

to a near-natural condition. 

3.19.1 Monument Resources – Pre-mining Environment 

The Monument had not yet been established when, between 1974 and 1976, Pan Sound 

Joint Venture staked mineral claims in the Greens Creek area. In 1978, Greens Creek 

claims were put into a development category. 

It was also in 1978 when, by Presidential Proclamation (43 Federal Register 57009 dated 

December 1, 1978), President Carter established the Monument with the goal to 

“preserve intact the unique scientific and historic objects and sites located there.” As 

noted in the Proclamation, Admiralty Island provided “superlative combination of 

scientific and historic objects.” The island had been inhabited by indigenous people for 

approximately 10,000 years and provided a “unique combination of archeological and 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-269 

historical resources in a relatively unspoiled natural ecosystem that enhances their value 

for scientific study.” Wildlife were abundant. President Carter specifically noted the 

abundance of bears and eagles and the opportunity to study these animals. 

While the Proclamation withdrew all lands from entry, location, selection, sale, or other 

disposition, it also expressly made the establishment of the Monument subject to “valid 

existing rights,” such as the mining claims associated with the Greens Creek Mine. 

In 1980, ANILCA reinforced that “valid existing rights” included mining rights. While 

ANILCA designated most of the Monument as Wilderness, portions of the project area, 

including the mine site, are within the Monument, but are not in the Wilderness Area. In 

Section 503 of ANILCA, Congress specifically entitled the holders of the Greens Creek 

claims to a lease and the ability to obtain the necessary permits for the use of Monument 

lands in support of mining operations on their claims. 

ANILCA Section 503(c) provides that the Monument be managed “to protect objects of 

ecological, cultural, geological, historical, prehistorical, and scientific interest.” These 

objects have been used to describe Monument resources, although it is recognized that all 

the purposes defined in the Proclamation and in ANILCA are valued. In the Admiralty 

Island National Monument Land Management Act of 1990, Congress further recognized 

the Monument as an area of unparalleled natural beauty containing multiple resources 

including but not limited to, fish and wildlife, forestry, recreational, subsistence, 

educational, wilderness, historical, cultural, and scenic resources. 

3.19.2 Monument Resources – Baseline Conditions 

The Monument has long been recognized for its local, national, and global value across a 

broad spectrum of resources. Resource specific baseline conditions relevant to the 

proposed action have been described in the preceding sections and are not repeated here 

in detail. Specific resources identified through proclamation or legislation applicable to 

non-wilderness lands are identified in Table 3.19-1. Each of these resources is discussed 

briefly below. 

Table 3.19-1. Specific Resources Identified in Proclamation or Legislation Applicable to 

Non-wilderness Areas of the Monument. 

Recreation/Public Access a, b Scenic b Educational b, c 

Forestry b Historical a, b, c Fish and Wildlife (Bears and Eagles) b, c 

Geological a Subsistence a, b Ecological a, c 

Prehistoric a, c Cultural a, b, c 

Notes: 

a. ANILCA 1980. 

b. Admiralty Island National Monument Land Management Act 1990. 

c. Presidential Proclamation 1978. 

Recreation/Public Access 

Hawk Inlet and Admiralty Island as a whole, including the Monument have been, and 

continue to be, used for subsistence activities and recreation including sport fishing, 

wildlife viewing, and hunting. Notably, the large population of brown bears is important 
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3-270 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

to tourists and hunters, the Pack Creek Bear Viewing Area is a popular tourism 

destination to view bears. 

Most of the recreation use occurs on the waters or shoreline of Hawk Inlet, but hunting is 

also a popular activity throughout the upland areas, except within developed areas of the 

mine site and associated facilities. Current patterns of recreation use in the study area are 

similar to those under pre-mining conditions; hunting, fishing, boating, and wildlife 

viewing are the primary activities and there is a limited amount of recreational trapping. 

Recreational use is not allowed within the developed areas of the mine site and associated 

facilities. Mine employees are prohibited from engaging in recreational activities in the 

adjacent areas. 

Trapping for mink, marten, and river otter occurs in the Hawk Inlet area for both 

recreational and subsistence purposes. Baseline recreation conditions are described in 

more detail in Section 3.15. 

Forestry 

The area consists primarily of Sitka spruce-western hemlock forest interspersed with a 

mosaic of non-forested plant communities, including peat wetlands, shrub wetlands, and 

sedge meadows. The understory consists of a combinations of devil’s club (Oplopanax 

horridus), Vaccinium spp., and salmonberry (Rubus spectabilis). Common ferns and 

herbs include oak fern (Gymnocarpium dryopteris), spiny wood fern (Dryopteris 

dilatata), goldthread (Coptis aspleniifolia), dogwood (Cornus spp.), trailing raspberry 

(Rubus pedatus), deer berry (Maianthemum dilatatum), skunk cabbage (Lysichiton 

americanus), and foamflower (Tiarella trifoliate). 

Commercial timber sales and harvesting are prohibited in the Monument. Forested land 

within the Monument, which includes largely intact Sitka spruce and western hemlock 

forests, is classified as unsuitable for timber production and withdrawn from the timber 

base. Baseline vegetation conditions are described in more detail in Section 3.10. 

Scenic 

Prior to mining, with the exception of the historic cannery, the Monument was 

predominantly natural in appearance in the vicinity of the project. The landscape is 

dominated by rugged glaciated mountains with deep V-shaped and U-shaped valleys. 

The landscape is known for its meandering shorelines and islands, with numerous bays 

and coves. A relatively uniform canopy of Sitka spruce and western hemlock forest 

dominated the lower elevations, interrupted by pocket clearings of meadows, muskegs, 

and lakes. Baseline scenic resource conditions are described in more detail in Section 

3.14. 

Prehistorical/Historical 

In his Proclamation, President Carter noted that Admiralty Island provides a “superlative 

combination of scientific and historic objects.” The island had been inhabited by 

indigenous people for approximately 10,000 years and provided a “unique combination 

of archeological and historical resources.” Available data indicate that humans have been 

present in the Southeast Alaska archipelago for at least 10,000 years. Given the length of 

time humans have lived in the area and the presence of fish and wildlife resources, 

prehistoric and historic objects may exist in the project area, including lands within the 

Monument. However, there are no known objects or sites within the immediate area of 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-271 

the proposed TDF expansion. Prehistoric and historical resources are described in more 

detail in Section 3.17. 

Subsistence 

Nearby rural subsistence communities include Angoon, 44 miles to the south, Tenakee 

Springs, 28 miles to the southwest, Hoonah, 28 miles to the west, and Funter Bay, 10 

miles to the north. Deer, salmon, waterfowl, plants and berries are important subsistence 

foods that occur within the Monument. Historically, cultural and subsistence trapping 

was an important activity in the area. Trapping for mink, marten, and river otter continue 

for both recreational and subsistence purposes. Baseline subsistence uses are described 

in more detail in Section 3.16. 

Educational 

In his proclamation, the island was described by President Carter as “an outdoor living 

laboratory for the study of bald eagle and Alaska brown bear.” Other than mine related 

investigations, there are currently no formal educational activities within the project area. 

Elsewhere within the Monument, ongoing fish and wildlife investigations occur, visitors 

can view wildlife in dedicated areas, and other educational opportunities are 

implemented. 

Fish and Wildlife 

Fish and wildlife resources within the Monument have been noted by both Presidential 

Proclamation and through acts of Congress. President Carter specifically noted the 

exceptional populations of bears and eagles. As a result of existing mine operations, 

habitat removal has occurred within the Monument, primarily consisting of sprucehemlock forests and muskegs. Noise and activity from ongoing operations has likely had 

an effect on terrestrial species, resulting in a direct and indirect loss of habitat. Although 

it was expected that some animals would avoid mine activity areas, species such as deer 

and brown bears are seen frequently in areas with active operations. Within Monument 

portions of the project area, fish are present in Tributary, Zinc, and Greens Creeks 

systems. These streams systems contain resident and anadromous fish species common 

to the region, including cutthroat trout, dolly varden, sculpin, stickleback, and coho, pink 

and chum salmon. Baseline fisheries and wildlife uses are described in more detail in 

sections 3.7 and 3.11, respectively. 

Ecological 

The ecology of the Monument refers to the relation between organisms, such as fish and 

wildlife species, and their environments. The ecological system involves a complex 

relationship between biotic (living) and abiotic (nonliving) components. Common 

measures of ecological health include species composition and richness, nutrient cycling 

and flow, productivity, and community structure (Cordell et al. 2005). 

It is assumed that the ecological value of the Monument is high, as the vast majority of 

the Monument is preserved as Wilderness and developed portions of the Monument are 

managed to minimize the adverse effects of authorized actions. 

Cultural 

The Monument is culturally valuable not only to those that use it, but also to the Nation 

as a whole. It is valued by many for the unique opportunities for subsistence, recreation, 
Chapter 3. Affected Environment and Environmental Consequences

3-272 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

scenic enjoyment and many other aspects. The value inherent in preserving this unique 

island ecosystem is valuable to many. 

3.19.3 Monument Resources – Environmental 

Consequences 

ANILCA directs that, subject to valid existing rights and except as otherwise provided 

for, the Monument be managed to protect objects of ecological, cultural, geological, 

historical, prehistorical, and scientific interest (ANILCA 503(c)) and that activities must 

be carried out in accordance with reasonable regulations promulgated by the Secretary to 

assure that such activities are compatible, to the maximum extent feasible, with the 

purposes for which the Monuments were established (ANILCA 503(f)(2)(A); 36 CFR 

228.80). Any effect to the resources for which the Monument was established to protect 

would be an effect to Monument resources. The magnitude and duration of these effects, 

as described in the preceding resource discussions, and ultimately the ability to restore 

areas disturbed by mining to near-natural conditions when mining is completed, 

determine what level of effect these actions would have on the Monument and its 

purpose, and whether those effects constitute irreparable harm. 

3.19.3.1 Effects Common to All Alternatives 

Each of the alternatives, including the No Action Alternative, involves tailings disposal 

and related development within the Monument, as authorized by current plan of 

operations. The primary differences between each alternative are the spatial extent and 

location of disturbances within the Monument, the duration of mining activities within 

the Monument, and the time before reclamation of facilities within the Monument would 

begin. 

HGCMC would implement operational measures similar to those currently used to 

minimize effects to Monument resources. These measures include, but are not limited to: 

 Diverting clean surface run-off around the TDF; 

 Placing tailings and waste rock as described in Section 2.4.3 to promote runoff, 

reduce the potential for oxygen and water infiltration, and ensure geotechnical 

stability; 

 Constructing the TDF as described in Section 2.4.4 to contain tailings contact waters; 

 Relocating existing waste rock piles to the TDF to improve containment, reduce the 

potential for oxygen and water infiltration and improve geotechnical stability; 

 Covering interim, unused slopes with rock, hydroseeding outer slopes of the tailings 

pile, and installing snow fences and concrete blocks to serve as a wind break to limit 

the spread of dust; and 

 Minimizing disturbance by maintaining a small footprint. 

Under each alternative, disturbed lands within the Monument would be reclaimed at the 

cessation of mining or earlier if an alternate disposal location is selected. Reclamation 

would include: 

 Decommissioning and removal of unnecessary structures and facilities (water 

treatment facilities and electric power utility lines would remain as long as 

necessary); 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-273 

 Establishing surface contours conducive to natural revegetation or consistent with an 

alternate post-mining land use(s); 

 Reclamation within the Monument will be to as near a natural condition as 

practicable. This would include sealing mine openings, restoring original surface 

drainage, removal of all structures, and re-contouring where possible; 

 Placement of an engineered soil cover over the TDF; 

 Implementation, maintenance and monitoring of reclamation; and

 Revegetation of all disturbed areas as described in Section 2.4.9.2. 

The current understanding of the predicted water balance and chemistry post closure is 

that discharge water would not meet Alaska WQS and treatment would be required for at 

least 100 years after closure and perhaps in perpetuity. Water quality within the 

Monument will be protected by requiring HGCMC to treat all contact water until Alaska 

WQS can be achieved. Only treated water that meets Alaska WQS will be discharged 

inside or outside the Monument. See Section 3.5, Water Resources – Surface Water, for 

a more detailed discussion of water quality effects and Section 3.7, Aquatic Resources, 

for more detail on effects to freshwater streams within the Monument. 

Following successful reclamation of the TDF and associated facilities and closure of the 

mine, recreational and subsistence users could return to the area. Vegetation similar to 

the surrounding hillsides would be allowed to regenerate on top of the engineered soil 

cover, providing habitat, food, and cover for wildlife. The topography and vegetation 

would look similar to surrounding areas. Mining activity would cease and wildlife that 

may have been displaced would return. Anadromous and resident fish will continue to 

use streams within the Monument. The cycle of vegetation generation and decay would 

promote soil genesis on top of the cover. In the long term, when mining is completed, the 

mine and TDF would be reclaimed to a near-natural condition. It is acknowledged, 

however, that water treatment systems may be maintained over the long term and could 

be present on the Monument long after the reclamation of other facilities. Effects to the 

specific resources identified in Table 3.19-1 are described below. 

Recreation/Public Access 

All of the alternatives would meet the standards and guidelines of Non-Wilderness 

National Monument LUDs because public recreation use within Monument area would 

be managed in accordance with direction contained in the GPO. Following closure and 

reclamation, Monument lands affected by the mine would be reclaimed and restored to a 

near-natural condition and re-opened for public recreation when safe to do so. Access 

restriction may remain around facilities maintained for long-term water treatment. The 

alternatives differ in terms of their extent and location of new disturbed areas within the 

Monument. These effects are discussed in detail in Section 3.15, Recreation. 

Compared to the size of the entire Monument (nearly 921,000 acres), the expansion of the 

existing tailings pile, under any alternative, would represent about 1/100th of 1 percent of 

the Monument. Because HGCMC is required to restore lands to near-natural conditions, 

the relatively small size of disturbance and recreational access restrictions, and the fact 

that most restored areas would be made accessible to Monument visitors following 

reclamation, there would be negligible effects to recreation and public access within of 

the Monument as a whole. 
Chapter 3. Affected Environment and Environmental Consequences

3-274 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Forestry 

Under all alternatives, commercial timber sales and harvesting would continue to be 

prohibited in the Monument. The alternatives differ in terms of their extent of forest 

removal within the Monument. These effects are described in detail in Section 3.10, 

Vegetation. 

There would be no additional forest clearing within the Monument as a result of 

Alternative A. Clearing of vegetation associated with Alternative B would occur 

adjacent to the existing TDF, whereas alternatives C and D would result in vegetation 

clearing at the alternative TDF site, which is outside the Monument. Alternative C would 

affect the least amount of forests within the National Monument, whereas Alternative B 

would affect the largest number of acres within the Monument. Table 3.19-2 provides 

the acres of POG within the Monument that would be lost by each alternative. Compared 

to the size of the entire Monument, the expansion of the existing tailings pile, under any 

alternative, would represent about 1/100th of 1 percent of the Monument. Thus, there 

would be negligible effects to Monument forests as a whole. 

Table 3.19-2. New Acres of Productive Old Growth Removal within the Monument 

 Alternative A Alternative B

Mitigated 

Alternative B Alternative C Alternative D 

Acres of POG removed 

(558,350 acres total in 

Monument) 

None 57 37 2 8 

Scenic 

Under all alternatives, the TDF would be visible within the Monument; however 

disturbed lands would be returned to near natural condition following closure and 

reclamation of the mine. Some facilities needed for access and water treatment would 

remain until no longer needed. The Forest Service SIOs would be met, however, since 

approved mining areas are to be managed to a very low SIO, or “heavily altered,” 

landscape within the Non-Wilderness National Monument LUD. These effects are 

described in detail in Section 3.14, Scenic Resources. Visual simulations of the TDF, 

prior to reclamation and revegetation are also provided in Section 3.14. 

Compared to the size of the entire Monument, the expansion of the existing tailings pile, 

under any alternative, would represent about 1/100th of 1 percent of the Monument. 

While the TDF would continue to be visible within the Monument locally, most 

Monument visitors would be unable to see it. Because of the relatively small portion of 

the Monument affected and the fact that the most of the site would be revegetated during 

reclamation, there would be negligible effects to scenic resources within the Monument 

as a whole. Locally, scenic affects from ongoing and future operations would continue 

during operations, the duration of which varies by alternative. Access and water 

treatment infrastructure would remain for at least 100 years, perhaps in perpetuity, under 

each alternative. The visual effect of these facilities on the Monument, however, would 

be very localized. 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-275 

Prehistorical/Historical 

Given the length of time humans have lived in the area and the presence of fish and 

wildlife resources, prehistoric and historic objects may exist in the project area, including 

lands within the Monument. However, there are no known objects or sites within the 

immediate area of the TDF. The alternatives differ in terms of their extent and location 

of new disturbed areas within the Monument. These effects are discussed in detail in 

Section 3.17, Cultural Resources. 

Considering that the area that would be affected by the action alternatives is unlikely to 

contain prehistorical and historical objects and that the area affected would be about 

1/100th of 1 percent of the total Monument area, effects to these Monument resources 

would be minimal. The alternatives differ in their potential to affect unidentified 

prehistorical or historical resources within the Monument. This risk is directly related to 

the physical extent of disturbance within the Monument. Alternative A would disturb the 

least acres within the Monument and Alternative B would disturb the most acres within 

the Monument (see Table 3.19-3). 

Table 3.19-3. Comparison of Alternatives with Respect to Monument Disturbances. 

Total Tailings-related 

disturbance within the 

Monument * (acres) 

Estimated Time 

Before Mine 

Closure (years) 

Estimated Time Before 

Existing TDF 

Reclamation Begins 

(years) 

Alternative A 37 2–3 2–3 

Alternative B 141 30–50 30–50 

Mitigated Alternative B 120 30–50 30–50 

Alternative C 55 30–50 3 

Alternative D 8 30–50 10 

* 37 acres of disturbance within the Monument were evaluated in previous NEPA actions are authorized 

in the current GPO. 

Subsistence 

Existing development has had negligible effect on subsistence uses within the Monument. 

There would be no new effect on subsistence under Alternative A. Each of the action 

alternatives would require expanding the existing TDF southward into the Monument, 

increasing the facilities lease area, and delaying reclamation of the new TDF for 30 to 50 

years. While, of the action alternatives, Alternative B would have the least effect on 

subsistence within the project area, Alternative B would result in the greatest expansion 

within the Monument. Of the action alternatives, Alternative C would have the least 

effect on subsistence uses within the Monument. These effects are discussed in detail in 

Section 3.16, Subsistence, and Appendix G. 

Compared to the size of the entire Monument, the expansion of the existing TDF, under 

any alternative, would represent about 1/100th of 1 percent of the Monument. Thus, 

there would be negligible effects to subsistence uses within the Monument as a whole. 

There would be localized effects. Alternative A would have the least impact on 

subsistence uses within the Monument due to the limited new construction and shorter 

project timeline ending in 2019. Alternative B would have the greatest impact on 
Chapter 3. Affected Environment and Environmental Consequences

3-276 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

subsistence uses within the Monument because it would affect the most Monument acres 

(Table 3.19-3). This differs from the finding in Section 3.16 that alternatives C and D 

would have a greater affect to subsistence uses overall, because only Monument uses and 

effects are considered here. 

Educational 

There would be negligible effects to educational opportunities under each of the 

alternatives. Education opportunities provided in the Monument well outside of the 

project area would not be affected. 

Fish and Wildlife 

Except for Alternative A, each alternative would result in some further development into 

the Monument (Table 3.19-3), potentially affecting fish and wildlife resources. Effects to 

subsistence resources are discussed above. Alternative A would have the least affect to 

fish and wildlife resources within the Monument because no further expansion into the 

Monument would be approved. Effects to aquatic and wildlife resources within the 

Monument would be greatest with Alternative B because this alternative would disturb 

the most acres of fish and wildlife habitat within the Monument, including burial of 

portions of Tributary Creek. Under Mitigated Alternative B, design modification and 

relocation of some of the proposed facilities outside the Monument would reduce effects 

to fish and wildlife within the Monument. While alternatives C and D would limit 

disturbance within the Monument compared to alternatives B and Mitigated B, mining 

operations and associated effects to fish and wildlife habitat and species would continue 

for an additional 30 to 50 years under all action alternatives. Effects to fish and wildlife 

resources are described in more detail in sections 3.7 and 3.11, respectively. 

Compared to the size of the entire Monument, the expansion of the existing tailings pile, 

under any alternative, would represent a very small percentage of available fish and 

wildlife habitat within the Monument (about 1/100th of 1 percent of the Monument). 

Thus, there would be negligible effects to fish, wildlife, and their habitats on the scale of 

the Monument as a whole. 

Ecological 

Locally, within the TDF area, biotic (wildlife, aquatic species, plant, etc.) and abiotic 

(soils, hydrology, etc.) have been affected by mine related activities, habitat removal and 

alteration, changes in topography and hydrology and similar alterations. Alternative A 

would result in no additional changes to the local ecological system. The action 

alternatives would each result in some new disturbance within the Monument that would 

increase local impacts to ecological systems. Disturbance within the Monument because 

of these alternatives is presented in Table 3.19-3. Compared to the size of the entire 

Monument, the expansion of the existing tailings pile, under any alternative, would 

represent about 1/100th of 1 percent of the Monument. Thus, there would be negligible 

effects to ecological systems of the Monument as a whole. BMPs and mitigation 

measures would continue to be implemented to reduce the effects of the project under all 

alternatives. Monitoring and adaptive management will continue, providing opportunity 

for operational and management response to ecological effects as they are identified. 
3.19 Monument Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-277 

Cultural 

Except for Alternative A, each alternative would result in some further development into 

the Monument, potentially affecting objects of cultural interest. Effects to 

prehistoric/historic objects are discussed above. The alternatives differ in their potential 

to affect unidentified cultural objects within the Monument. This risk is directly related 

to the physical extent of disturbance within the Monument. Alternative A would disturb 

the least acres within the Monument and Alternative B would disturb the most acres 

within the Monument (see Table 3.19-3). Compared to the size of the entire Monument, 

the expansion of the existing TDF, under any alternative, would represent about 1/100th 

of 1 percent of the Monument. Thus, there would be negligible effects to cultural objects 

of interest within the Monument as a whole. 

3.19.3.2 Effects of Alternative A, No Action 

Alternative A would have the least impact on the Monument. No further expansion of 

the TDF would be authorized in the Monument and reclamation would begin following a 

predicted closure around 2019. In total, approximately 37 acres of disturbance would 

occur within the Monument. 

3.19.3.3 Effects of Alternative B, Proposed Action 

Alternative B would affect the largest area within the Monument and therefore have the 

largest effect. At the completion of mining, activities would have disturbed a total of 

approximately 141 acres within the Monument; 37 acres of that were analyzed in 

previous NEPA documents and authorized in the current GPO. Under Alternative B, full 

reclamation of the TDF would not occur for 30 to 50 years. 

3.19.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the expansion of the TDF would result in about 2 million 

cubic yards of tailings and waste rock being placed in the northeast corner of the existing 

TDF, outside of the Monument. Approximately half of the material would be placed in 

the initial phase of the expansion with the remaining volume being placed in the final 

phase. In addition, the reclamation material storage area and quarry to the south of the 

TDF would be relocated out of the Monument. The result would be a new reclamation 

material storage area located near the junction of the A and B roads; moving the quarry 

out of the Monument would require deepening the quarry at the north end of the existing 

TDF, which is also outside the Monument. At the completion of mining, activities would 

have disturbed a total of approximately 120 acres within the Monument; 37 acres of that 

disturbance were previously approved. As with Alternative B, full reclamation of the 

TDF would not occur for 30 to 50 years. 

3.19.3.5 Effects of Alternative C, New TDF Located Outside Monument 

Alternative C would reduce effects to the Monument compared to the proposed action by 

relocating most of the additional tailings disposal capacity outside of the Monument at a 

new site. At the completion of mining, activities would have disturbed a total of 

approximately 55 acres within the Monument; 37 acres of that disturbance were 

previously approved. Reclamation of the TDF within the Monument would begin in 

approximately 3 years. Mine operations and associated activity that currently occur 

within the Monument would continue for 30 to 50 years while the mine continued to 

operate and place tailings at the alternative site. 
Chapter 3. Affected Environment and Environmental Consequences

3-278 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.19.3.6 Effects of Alternative D, Modified Proposed Action 

Alternative D would reduce effects to the Monument compared to the proposed action by 

relocating some of the additional tailings disposal capacity outside of the Monument at a 

new site. At the completion of mining, activities would have disturbed a total of 

approximately 68 acres within the Monument; 37 acres of that disturbance were 

previously approved. Reclamation of the TDF within the Monument would begin in 

approximately 10 years. Mine operations and associated activity that currently occur 

within the Monument would continue for 30 to 50 years while the mine continued to 

operate and place tailings at the new TDF. 

3.19.4 Monument Resources – Summary 

Each of the alternatives would have some local effect on the Monument resources. 

Because the tailings pile is already existing on Monument lands, many of the effects to 

resources described throughout this EIS have already occurred and will require 

reclamation to restore the land to near-natural conditions. Based on current water 

chemistry data, study results and the modeling that was undertaken for this analysis, long 

term water treatment, perhaps in perpetuity, is anticipated regardless of which alternative 

is developed, including the No Action Alternative. 

The greatest difference between the alternatives is the spatial extent of disturbances 

within the Monument the period of time in which mining will continue within the 

Monument, and the time until reclamation occurs. Under each alternative, operational 

measures would be implemented to reduce effects to the Monument and reclamation 

would restore lands to near-natural conditions after closure. 

Table 3.19-3 presents the spatial extent of disturbance within the Monument, duration of 

continued mining, and approximate time before reclamation of the TDF within the 

Monument. While local effects to resources and objects of the Monument would occur 

from any expansion, this new disturbance is about 1/100th of 1 percent of the total 

Monument area (about 895,000 acres). 

3.20 Inventoried Roadless Areas ___________________ 

3.20.1 Background 

This project-level analysis does not evaluate roadless 

areas for wilderness recommendation. However, 

roadless characteristics are used in this EIS to analyze 

and describe potential changes to roadless areas by 

alternative, and are discussed further in the individual 

resource analysis sections. Effects to roadless 

characteristics are summarized at the end of this section. 

Table 3.20-1 summarizes the roadless characteristics 

considered and the section in this chapter where 

potential effects are discussed. 

Inventoried roadless areas 

are defined as undeveloped 

areas typically exceeding 

5,000 acres that meet the 

minimum criteria for 

wilderness consideration 

under the Wilderness Act 
3.20 Inventoried Roadless Areas 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-279 

Table 3.20‐1. Roadless Characteristics and Discussion Section. 

2000 Roadless Characteristics * Chapter 3 Section 

Soil, Water, Air Soils; Water Resources - Surface Water; Water 

Resources - Groundwater; Air Quality 

Sources of public drinking water Water Resources - Surface Water 

Diversity of plant and animal communities Vegetation; Wetlands, Wildlife; Threatened, 

Endangered, Candidate, and Forest Service Alaska 

Region Sensitive Species and Rare Plants; Aquatic 

Resources 

Habitat for threatened, endangered, proposed, 

candidate, and sensitive species and for those species 

dependent on large, undisturbed areas of land 

Threatened, Endangered, Candidate, and Forest 

Service Alaska Region Sensitive Species and Rare 

Plants 

Primitive, Semi-Primitive Non-Motorized, and SemiPrimitive Motorized classes of recreation opportunities Recreation 

Reference landscapes Scenic Resources 

Landscape character and scenic integrity Scenic Resources 

Traditional cultural properties and sacred sites Cultural Resources; Subsistence 

Other locally identified unique characteristics Monument Resources 

* November 2000 Forest Service Roadless Area Conservation FEIS (Forest Service 2000, Volume 1, pp. 3-3 

to 3-7). 

Effects are measured by acres of development and feet of road construction within 

roadless area boundaries, as well as total acres affected by proposed activities, including 

“zones of influence” that include a 600-foot buffer around the TDF and a 1,200-foot 

buffer placed around roads. The analysis focuses on the potential impacts to the unique 

or outstanding biological, physical, or social values of the IRAs. Roadless characteristics 

(i.e., values or features that make the area appropriate and valuable for wilderness) are 

described in the November 2000 Forest Service Roadless Area Conservation FEIS (FEIS 

Vol. 1, pp. 3-3 to 3-7). The 2001 dataset has been used to analyze the effects of proposed 

alternatives on the roadless characteristics of the Greens Creek (307) and Mansfield 

Peninsula (306) IRAs. 

IRAs are defined as undeveloped areas typically exceeding 5,000 acres that meet the 

minimum criteria for wilderness consideration under the Wilderness Act and were 

inventoried during the Forest Service’s Roadless Area Review and Evaluation (RARE II) 

process, with subsequent assessments and forest planning analyses. Including 

Wilderness, the Tongass National Forest is currently more than 90 percent unroaded. 

3.20.2 Inventoried Roadless Areas – Baseline 

Conditions 

The Forest Plan Revision SEIS (Forest Service 2003) outlines all the values used to 

evaluate the wilderness potential of the Greens Creek (307) and Mansfield Peninsula 

(306) IRAs (Figure 3.20-1). Both IRAs represent the typical qualities of many IRAs in 

southeast Alaska. Descriptions of existing conditions are used to help facilitate an 

understanding of the potential change to the roadless characteristics that could occur as a 
Chapter 3. Affected Environment and Environmental Consequences

3-280 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.20-1. Inventoried Roadless Areas. 
3.20 Inventoried Roadless Areas 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-281 

result of the Greens Creek Mine Tailings Disposal Facility Expansion EIS Decision. The 

following discussion focuses on the unique or outstanding qualities of these IRAs. 

Greens Creek IRA 

The Greens Creek (307) IRA is located on the north end of Admiralty Island. The 

southern portion of the IRA contains the Greens Creek Mine and the Monument. The 

Non-wilderness National Monument LUD facilitates the development of mineral 

resources in portions of the IRA. To the south and east of the area is the Admiralty 

Island National Monument-Kootznoowoo Wilderness. Greens Creek Mine and Young 

Bay access roads border the northern portion of the area and separate it from the 

Mansfield Peninsula Roadless (306) IRA. The Greens Creek Mine access road also 

borders the western portion of the area and provides access to the National Monument. 

The city of Juneau is located approximately 18 miles northeast of the area. 

The Greens Creek (307) IRA is accessed primarily by private boat or chartered aircraft. 

Regular transportation by boat has been provided to Greens Creek Mine employees since 

1987. There is no area suitable for landing wheeled airplanes. There is no public 

transportation in the roadless area. The Hawk Inlet trail is located north of the area, and 

access into the interior portion of the roadless area is by foot or helicopter (Forest Service 

2003). 

The topography of the area ranges from blocky and hummocky landforms to complex 

terrain with sharply defined crests and angular profiles. The main geologic features are 

rock outcrops and craggy peaks, and prominent escarpments dominate the view. Level 

plains and foothills along Young Bay include pocket clearings of muskegs, lakes, and 

meadows. There are 3 miles of saltwater shoreline in the area. Approximately 1,552 

acres are inventoried as alpine and 715 acres are identified as rock; there are no ice or 

snow features (Forest Service 2003). 

Biological Values 

There are no unique ecologic values in the area. The federally listed threatened and 

endangered species likely to occur within or adjacent to the IRA are the humpback whale 

(endangered) and the Steller sea lion (threatened). Listed Chinook salmon, sockeye 

salmon, and steelhead occur infrequently in the inside waters of southeast Alaska. 

Two Forest Service Region 10 Sensitive Species are suspected or known to occur within 

the area: Queen Charlotte goshawk and black oystercatcher. As inhabitants of late seral 

forests, Queen Charlotte goshawks are closely associated with POG and are known to 

nest within the roadless area. Black oystercatchers inhabit the rocky marine shorelines. 

Both the yellow-billed loon and dusky Canada goose may occur during migration. In 

addition, eight sensitive plant species are known or suspected to occur in the Juneau 

Ranger District. 

Other important wildlife populations in the Greens Creek (307) IRA include brown bear, 

bald eagle, Sitka black-tailed deer, waterfowl/shorebirds, and furbearers such as marten, 

river otter, beaver, and mink. Black bears are not present on Admiralty Island, and 

moose and mountain goats have not been reported in this area. 

Admiralty Island streams within the area provide habitat for pink, coho, and chum 

salmon. The Tongass Fish and Wildlife Resource Assessment identified all three value 

comparison units (VCUs) in the area as secondary salmon producers and no VCUs as 
Chapter 3. Affected Environment and Environmental Consequences

3-282 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

primary sport fish producers (ADF&G 1998). Fisheries resources in the project area are 

discussed in more detail in Section 3.7. 

Physical Values 

There is a very small area of high vulnerability karst in the southwest section of this 

roadless area adjacent to the border of the Monument. The mapped karst resources 

encompass 127 acres, which is less than one percent of the roadless area. Approximately 

30 percent of the karst is mapped as having high vulnerability. There are no known 

glaciers or unique geologic features in the area. 

Portions of the IRA within the project area have been affected since the inventories were 

conducted for the 2001 Roadless Rule. Limited geotechnical and mineral exploration 

drilling has been authorized. 

Human modifications are not highly visible within much of this area, which is 

predominantly natural in appearance. The landscape character as seen from Hawk Inlet is 

dominated by the densely forested ridges and valleys of the Greens Creek drainage and 

the level plains and foothills along the shoreline. High forested ridges and numerous 

bodies of water form a repetitive pattern in the landscape surrounding the mine site. 

Within the Hawk Inlet viewshed, the existing TDF and cannery site are the most 

dominant human alterations. Most of the other mine facilities are not visible from the 

inlet. 

Social Values 

There are no unique scientific or educational values identified in the area. The Greens 

Creek (307) IRA is bordered to the east and south by wilderness. The area is bordered to 

the west by the Greens Creek Mine access road and an area allocated to the 

Transportation and Utility System LUD. The 2008 Tongass Land Management Plan 

Revision identifies the existing road and transportation line corridor from Young Bay to 

the Hawk Inlet cannery, and continuing up to the mill site. A potential transmission line 

corridor continues west from the Hawk Inlet cannery site outside of the roadless area. 

Adjacent land to the north is allocated to the Semi-remote Recreation LUD. Recreational 

use in the area occurs mainly along the shoreline. Areas south and east of the area are 

used more intensively for recreational activities. The 1998 Tongass Fish and Wildlife 

Resource Assessment indicated that subsistence use in the VCUs that comprise this area 

are not sensitive to disturbance. None of the VCUs in this area were included among the 

highest value community use areas (ADF&G 1998). 

Evidence of prehistoric and historic use of this roadless area is documented. Historically, 

Tlingit clans used the area as a seasonal subsistence area. Trapper cabins have been 

found in the area, along with evidence of hunting and fishing camps. 

Greens Creek Mine, located in the south portion of the area, employs approximately 330 

workers. 

Mansfield Peninsula (306) IRA 

The Mansfield Peninsula IRA encompasses the northernmost portion of Admiralty 

Island. The area is bordered by saltwater to the north, east, west, and part of the south. 

Lynn Canal, Chatham Strait, and Funter Bay State Marine Park border the western 

portion of the area. Stephens Passage and Saginaw Channel border the area to the east. 
3.20 Inventoried Roadless Areas 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-283 

The southern portion of the area is bordered by Hawk Inlet and the Greens Creek Mine 

access road, which separates the area from the adjacent Greens Creek (307) IRA. It is 

approximately 3 miles from the eastern shore of the peninsula to the west side of Douglas 

Island and approximately 10 miles to Auke Bay. 

The area is accessed primarily by boats, float planes and helicopters. There is no area 

suitable for landing wheeled airplanes. There is no public transportation in the area. 

Several anchorages are found adjacent to the peninsula, including Funter Bay, Barlow 

Cove, and Hawk Inlet. Access into the interior is by foot or helicopter. There are several 

trails used to access 11 isolated privately owned hunter, recreation, and residence cabins 

located within the area. The area also includes Bear Creek Trail and part of the old Hawk 

Inlet Road, which is now used as a trail. 

Biological Values 

There are no unique ecologic values in the area. Like the Greens Creek (307) IRA, the 

federally listed threatened and endangered species likely to occur within or adjacent to 

the IRA are the humpback whale (endangered) and the Steller sea lion (threatened). 

Listed Chinook salmon, sockeye salmon, and steelhead occur infrequently in the inside 

waters of southeast Alaska. 

Two Forest Service Region 10 Sensitive Species are suspected or known to occur within 

the area: Queen Charlotte goshawk and black oystercatcher. As inhabitants of late seral 

forests, Queen Charlotte goshawks are closely associated with POG and are known to 

nest within the roadless area. Black oystercatchers inhabit the rocky marine shorelines. 

Additionally, both the yellow-billed loon and dusky Canada goose may occur during 

migration. In addition eight sensitive plant species are known or suspected to occur in 

the Juneau Ranger District. 

The Mansfield Peninsula supports a large population of brown bear as well as Sitka 

black-tailed deer. Wolves may be present (MacDonald and Cook 1999), as well as 

furbearers such as marten, mink, and beaver. Black bears are not present on Admiralty 

Island, and moose and mountain goats have not been reported in this area. 

Physical Values 

There are no known karst or cave resources in this roadless area. There are no glaciers or 

known unique geological features. 

The visual condition of the area is predominantly natural. The area appears natural when 

viewed from Lynn Canal, Saginaw Canal, Funter Bay State Marine Park, Barlow Cove, 

and the hiking trails within the area. Viewed from Hawk Inlet, the roadless area itself 

appears unmodified, but the Greens Creek Mine access road, which partially borders the 

area to the south, affects the perceived naturalness of the landscape. 

Social Values 

There are no unique scientific or educational values identified in the area. The area is 

located approximately 10 miles southwest of Juneau and is reasonably accessible. 

Approximately 11 isolated hunter or recreation residence cabins are under special use 

permit in this area, and most are accessed from the eastern shoreline which is closest to 

Juneau. Hunting is the primary activity in the area. There are no public recreation 

cabins, but there are several trails used to access recreation residences as well as Bear 
Chapter 3. Affected Environment and Environmental Consequences

3-284 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Creek Trail and part of the Hawk Inlet Trail. Subsistence use occurs in the area (Forest 

Service 2003). The Tongass Fish and Wildlife Resource Assessment (ADF&G 1998) 

identified two of the VCUs in this area (VCUs 125 at the northern tip and VCU 128 

along Hawk Inlet) as subsistence use areas with a high sensitivity to disturbance. None 

of the VCUs in this area were included among the highest, second, or third group for 

community use values (ADF&G 1998). 

The Mansfield Peninsula has had a long history of use. Native use of the area focused on 

fishing and hunting. Goldschmidt and Haas (1946) identified commercial fish traps 

along the west shore of the peninsula. They also identified hunting or trapping, a former 

camp, and a former village in the area. More recent history reveals the importance of 

mining in the area. Much of the peninsula contains evidence of active or historic mining 

claims (Forest Service 2003). 

3.20.3 Inventoried Roadless Areas – Environmental 

Consequences 

3.20.3.1 Effects Common to All Alternatives 

Under all action alternatives, portions of the IRAs would be affected by TDF expansion. 

Most IRA acres affected would occur within the zones of influence as a result of the 

600-foot buffer around roads and 1,200-foot buffer around facilities. In all alternatives, 

the Greens Creek (307) and Mansfield Peninsula (306) IRAs would remain greater than 

5,000 acres in size. Mining activities would continue through 2019 under Alternative A 

and for an additional 30 to 50 years under the action alternatives. For each alternative, 

Table 3.20-2 displays the length of new road, acres of development, acres that would be 

affected within the zone of influence or roads and facilities, and total acres affected 

within each IRA. As a result of each alternative, some roadless characteristics (e.g., 

ecologic values, natural integrity and appearance, scenic values, and semi-primitive and 

primitive recreation opportunities) may be reduced within the project area, although this 

would only occur within a small percentage of either IRA. These effects would diminish 

to some degree following mine closure and reclamation. Figure 3.20-2 shows IRAs 

along with the disturbance footprint of each alternative at the existing TDF site. Figure 

3.20-3 shows the same at the north site. 

For both IRAs, the roadless characteristics would be modified locally. No unique 

attributes would be affected. The biological value of old-growth forest would be reduced 

proportionately by the amount of old growth removed in each roadless area. The scenic 

condition of the IRAs would only be slightly changed compared to the existing condition. 

3.20.3.2 Effects of Alternative A – No Action 

Under Alternative A, the No Action Alternative, the mine would continue to operate until 

2019. No new roads would be constructed within either IRA. About 1 acre of facilities 

would be constructed within the Greens Creek IRA at full build-out in 2019. 

Approximately 12 acres would be affected within the zone of influence facilities and 

roads. This would result in about 13 acres, less than 0.1 percent of the Greens Creek 

(307) IRA, being affected. 
3.20 Inventoried Roadless Areas 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-285 

Table 3.20-2. IRA Effects by Alternative. 

 

Alternative 

A 

Alternative 

B 

Mitigated 

Alternative B 

Alternative 

C 

Alternative 

D 

Length of new road (feet)

Greens Creek (307) 0 1,400 1,400 0 0 

Mansfield Peninsula (306) 0 0 0 163 120 

Acres of development

Greens Creek (307) 1 26 18.8 1 3 

Mansfield Peninsula (306) 0 0 0 51 46 

Acres affected in Zone of Influence

Greens Creek (307) 12 78 85 21 26 

Mansfield Peninsula (306) 0 0 0 112 74 

Total acres affected within IRA

Greens Creek (307) 13 104 105 22 29 

Mansfield Peninsula (306) 0 0 0 163 120 

Percent of IRA affected

Greens Creek (307) 0.05 0.38 0.39 0.08 0.11 

Mansfield Peninsula (306) 0.00 0.00 0.00 0.30 0.22 
Chapter 3. Affected Environment and Environmental Consequences

3-286 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Figure 3.20-2. Greens Creek IRA Affected by Each Alternative. 
3.20 Inventoried Roadless Areas 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-287 

Figure 3.20-3. Mansfield IRA Affected by Alternatives C and D. 
Chapter 3. Affected Environment and Environmental Consequences

3-288 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3.20.3.3 Effects of Alternative B 

Under Alternative B, the mine would continue to operate for an additional 30 to 50 years. 

Approximately 1,400 feet of new road would be constructed within the Greens Creek 

(307) IRA. Alternative B would affect the greatest amount of acres within the Greens 

Creek (307) IRA, totaling approximately 104 acres, or about 0.4 percent of the IRA. 

There would be no new impacts to the Mansfield Peninsula (306) IRA, although 

operations in Hawk Inlet would be viewable from the Mansfield Peninsula and would 

continue for decades. 

Figure 3.20-2 shows each action alternative footprint in relation to IRAs at the existing 

TDF site. 

3.20.3.4 Effects of Mitigated Alternative B 

Under Mitigated Alternative B, the mine would continue to operate for an additional 30 

to 50 years. Approximately 1,400 feet of new road would be constructed within the 

Greens Creek (307) IRA. Mitigated Alternative B would affect 100 acres within the 

Greens Creek (307) IRA. There would be no new impacts to the Mansfield Peninsula 

(306) IRA, although operations in Hawk Inlet would be viewable from the Mansfield 

Peninsula and would continue for decades. 

3.20.3.5 Effects of Alternative C 

As with Alternative B, Alternative C would extend the mine life an additional 30 to 50 

years. However, there would be no new road construction in either IRA and less effect 

on the Greens Creek (307) IRA. Tailings disposal would continue at the existing TDF for 

approximately 3–5 years while a new TDF would be constructed to the north, partially 

within the Mansfield Peninsula (306) IRA. While Alternative C would result in less 

acres of effect within the Greens Creek IRA compared to Alternative B, the total effect 

on any IRA would be increased. Alternative C would result in about 22 acres (less than 

0.1 percent) of total effects within the Greens Creek (307) IRA and 163 acres (about 0.3 

percent) within the Mansfield Peninsula (306) IRA, totaling approximately 185 acres the 

most of any alternative. 

Figure 3.20-3 shows the footprints of alternatives C and D in relation to IRAs at the north 

site. 

3.20.3.6 Effects of Alternative D 

The effects of Alternative D are similar to those of Alternative C. The mine would 

continue to operate for an additional 30 to 50 years. No new road construction in either 

IRA would occur. While tailings disposal continues at the existing TDF for about 10 

years, a new TDF would be constructed to the north, partially within the Mansfield 

Peninsula (306) IRA. Alternative D would also reduce effects within the Greens Creek 

(307) IRA compared to Alternative B while adding effects to the Mansfield Peninsula 

(306) IRA. Alternative D would result in about 29 acres (about 0.1 percent) of effects 

within the Greens Creek IRA and 120 acres (about 0.2 percent) within the Mansfield 

Peninsula (306) IRA, totaling approximately 149 acres. Alternative D would result in 

fewer IRA acres affected than Alternative C due, in part, to the elimination of a quarry 

along the A road. 
3.21 Environmental Justice 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-289 

3.20.4 Roadless Areas – Summary 

The activities currently proposed are not likely to significantly affect the roadless 

characteristics of the Greens Creek and Mansfield Peninsula IRAs. No unique attributes 

would be affected. In all alternatives, the Greens Creek Mansfield Peninsula IRAs would 

remain greater than 5,000 acres in size. When considering the potential change to the 

roadless characteristics of the IRAs, Alternative C would affect the most acres within the 

two IRAs but does not include new road construction with IRAs. Facility development 

(all action alternatives) and road construction (Alternative B only) at the south TDF site 

would occur adjacent to existing facilities. Only alternatives C and D would result in a 

new affect to the Mansfield Peninsula (306) IRA. No alternative would result in more 

than 0.4 percent of either IRA being affected. The individually identified roadless values 

would either remain unchanged or be minimally influenced by any alternative activities. 

Effects to either of these IRAs would diminish to some degree following mine closure 

and reclamation. 

3.21 Environmental Justice _______________________ 

3.21.1 Background 

This section addresses environmental justice and is 

formatted differently than other resource sections in this 

EIS. The analysis presents a brief description of the 

policies and guidance related to environmental justice, an 

assessment of how environmental justice applies in the 

region, and the effect the project may have in terms of 

environmental justice. 

Executive Order 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and LowIncome Populations, requires each federal agency to 

make the achievement of environmental justice part of its mission by identifying and 

addressing disproportionately high and adverse human health or environmental effects of 

its programs, policies, and activities on minority and low-income populations. The Order 

further stipulates that the agencies conduct their programs and activities in a manner that 

does not have the effect of excluding persons from participation in them, denying persons 

the benefits of them, or subjecting persons to discrimination because of their race, color, 

or national origin. 

Evaluating whether a proposed action has the potential to have disproportionately high 

and adverse impacts on minority and/or low income populations typically involves: 

(1) identifying any potential high and adverse environmental or human health impacts, 

(2) identifying any minority or low income communities within the potential high and 

adverse impact areas, and (3) examining the spatial distribution of any minority or low 

income communities to determine if they would be disproportionately affected by these 

impacts. 

Guidelines provided by the CEQ (1997) and USEPA (USEPA 1998) indicate that a 

minority community may be defined where either: (1) the minority population comprises 

more than 50 percent of the total population, or (2) the minority population of the 

The resource analysis of 

environmental justice was 

not identified as a significant 

issue; comments from the 

scoping process regarding 

environmental justice are 

addressed in this section.
Chapter 3. Affected Environment and Environmental Consequences

3-290 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

affected area is meaningfully greater than the minority population in the general 

population of an appropriate benchmark region used for comparison. Minority 

communities may consist of a group of individuals living in geographic proximity to one 

another, or a geographically dispersed set of individuals who experience common 

conditions of environmental effect. Further, a minority population exists if there is “more 

than one minority group present and the minority percentage, as calculated by 

aggregating all minority persons, meets one of the above-stated thresholds” (CEQ 1997, 

page 26). 

The CEQ and USEPA guidelines indicate that low income populations should be 

identified based on the annual statistical poverty thresholds established by the U.S. 

Census Bureau. Like minority populations, low income communities may consist of 

individuals living in geographic proximity to one another, or a geographically dispersed 

set of individuals who would be similarly affected by the proposed action or program. 

The U.S. Census Bureau defines a poverty area as a census tract or other area where at 

least 20 percent of residents are below the poverty level (U.S. Census Bureau 2011b). 

Communication and Outreach 

Government-to-Government Consultation 

As discussed in this section, the community of Angoon is considered an environmental 

justice community. From the beginning of the NEPA process, the Forest Service has 

worked to ensure that Angoon has been sufficiently involved in the decision-making 

process, and that the analysis has considered the potential for disproportionately high 

adverse effects to the local population. 

The Forest Service conducted consultations with Alaska Native groups on October 15, 

2010, to comply with Executive Order 13175, which addresses consultation and 

coordination with Indian tribal governments. The purpose of the meetings was to explain 

the nature of the project and to solicit comments and concerns. The Forest Service 

conducted government-to-government consultations to solicit comments on the project 

from the Angoon Community Association and Kootznoowoo Incorporated on October 

15, 2010, and held a follow up meeting with Kootznoowoo on November 10, 2010. 

Additional consultation occurred with the Angoon Community Association on October 

13, 2011. The Sealaska Corporation declined the Forest Service offer to consult on a 

government-to-government basis. 

During consultations with the Forest Service, the Angoon Community Association 

expressed concern about the effects on fish and wildlife and indicated that Hawk Inlet, 

along with all of Admiralty Island, is considered a Sacred Place. The Angoon 

Community Association has indicated that Hawk Inlet is a traditional migration and trade 

route between Chatham Straight and Stephens Passage; an important source of food, both 

from freshwater streams and the marine environment; and the inlet is important to elders, 

as many of them grew up and learned their traditions in that area. 

Scoping 

Public scoping for this EIS was initiated with publication of a Notice of Intent (NOI) to 

prepare an EIS in the Federal Register on October 5, 2010. The Forest Service also 

mailed a scoping document to a mailing list developed by the Forest Service. 
3.21 Environmental Justice 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-291 

The scoping process was intended to provide information about the proposed project and 

solicit comments from local, state, and federal agencies; tribes; non-governmental 

organizations; and the public. In addition to the NOI, the Forest Service placed a public 

notice in the Ketchikan Daily News and the Juneau Empire on October 8, 2010 (each 

running 4 days), and used email to advertise public meetings. The Forest Service held 

public meetings in Juneau on October 14, 2010, and in Angoon on October 15, 2010. 

The purposes of the scoping meetings were to provide project information to the public, 

solicit comments from the public, and inform the public on how to participate in the 

process. 

Attendance at the public meetings consisted of representatives from the Forest Service 

and cooperating agencies, the proponent, Non-Governmental Organizations, and 

individuals. Fifteen people signed the attendance sheets at the public meeting in Juneau, 

and 20 signed in at the Angoon meeting. 

This scoping process is documented in the Scoping Summary Report prepared for the 

project (Tetra Tech 2011b). This report summarizes the scoping process, presents the 

concerns and issues that were identified during the scoping process, and describes how 

the scoping comments will be addressed in the EIS. 

3.21.2 Environmental Justice – Baseline Conditions 

Geographic Communities 

Census data that may be used to identify the presence of minority and low income 

populations in the vicinity of the proposed project are presented in Section 3.18, 

Socioeconomics. Data on race and ethnicity were compiled as part of the 2010 Census. 

As noted in the Socioeconomics section, the CBJ annexed the mine in 1994. The 

surrounding areas are part of the Hoonah-Angoon CA, an unincorporated area that is 

considered equivalent to a Borough in Alaska (or a County in the lower 48 states) for data 

compilation purposes. 

Data on median household income and poverty compiled by the Census Bureau for 2009 

are summarized in Table 3.18-2 in the Socioeconomics section. Data are presented for 

Juneau, the Hoonah-Angoon CA, and the State of Alaska. Data are not available in this 

series at the place or census tract level. 

Review of these data suggests that the communities of Angoon and Hoonah and the 

population of the entire Hoonah-Angoon CA may be considered minority communities 

because the combined minority population comprises more than 50 percent of the total 

population in these areas. The majority of the populations in the CBJ and the census tract 

that encompasses the mine site are White, with 70 percent and 76 percent of their 

respective populations identifying as White in the 2010 Census (Table 3.18-4). 

The data on median household income and poverty summarized in Table 3.18-2 suggest 

that the Hoonah-Angoon CA could be considered a low income community. Although 

less than 20 percent of the population was identified as below the poverty level in 2009, 

median household income in this area was just 63 percent of the State of Alaska median, 

which suggests the area may be considered low income. Median household income was 

9 percent higher than the State of Alaska average in the CBJ in 2009, and the percent of 
Chapter 3. Affected Environment and Environmental Consequences

3-292 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

the population below the poverty level was lower than the State of Alaska average (Table 

3.18-2). 

Communities of Shared Interest 

The term community of shared interest is used here to refer to geographically dispersed 

individuals who could experience common conditions of environmental effect. Potential 

impacts to subsistence use are addressed in Section 3.16, Subsistence. Communities of 

shared interest in the vicinity of the mine include subsistence users. 

3.21.3 Environmental Justice – Environmental 

Consequences 

3.21.3.1 Effects Common to All Alternatives 

Potential high and adverse environmental impacts are addressed by affected resource 

elsewhere in this EIS. There are no communities located near the mine site. There are 

recreational cabins located at Wheeler Creek, approximately 5 miles from the mine site, 

and Funter Bay is located approximately 10 miles from the mine and proposed project. 

Although the mine site is part of the CBJ, it is located approximately 15 miles from the 

closest populated parts. The nearest minority communities are Hoonah (28 miles) and 

Angoon (44 miles). None of these communities are expected to be affected by the action 

alternatives (alternatives B, Mitigated B, C, and D) due to the distance of the 

communities from the project area. 

Impacts to subsistence use are addressed in Section 3.16, Subsistence. Hawk Inlet is not 

in the Customary and Traditional Use Area for any rural communities, but the area has 

long been used for subsistence hunting, fishing, and gathering. However, the reliance on 

subsistence resources harvested in this area is minor and the impacts of the action 

alternatives on fish and wildlife resources are expected to be negligible. As a result, the 

potential impacts of the action alternatives on the subsistence use of wildlife, fish, or 

other resources are expected to be very low and would not disproportionately affect 

minority or low income populations. 

3.21.3.2 Effects of Alternative A – No Action 

Under Alternative A, the No Action Alternative, the mine would continue to operate until 

2019 and continue to support the annual direct and indirect employment and associated 

payroll. Following 2019, the mine would close, which would result in an annual loss of 

493 direct and indirect jobs and $48 million in direct and indirect payroll. These 

reductions in employment and payroll would primarily affect the CBJ and would not be 

expected to disproportionately affect minority or low income populations. 

3.21.3.1 Effects of Alternatives B, Mitigated B, C, and D 

As discussed in Section 3.21.3.1, Effects Common to All Alternatives, none of the action 

alternatives are expected to disproportionately affect minority or low income populations. 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-293 

3.21.4 Environmental Justice – Summary 

Under Alternative A, reductions in payroll and income would primarily affect the CBJ 

and would not be expected to disproportionately affect minority or low income 

populations. The action alternatives are not expected to affect the closest minority 

communities—Hoonah and Angoon—and the reliance on subsistence resources harvested 

in the affected areas are minor and the impacts of the action alternatives on fish and 

wildlife resources are expected to be negligible. The Forest Service has made a 

concerted effort to involve the environmental justice communities in the NEPA process, 

including encouraging comments during scoping and holding government-to-government 

consultation meetings. 

3.22 Cumulative Effects __________________________ 

Cumulative effects are defined in the CEQ regulations as “the impact on the environment 

which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or 

non-Federal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor but collectively significant actions taking place over a period of 

time” (40 CFR 1508.7). 

This section considers the cumulative effects by judging whether the direct and indirect 

effects of the proposal are significant when coupled with the effects from other past, 

present, and reasonably foreseeable future actions. Cumulative actions are defined as 

“actions, which when viewed with other proposed actions, have cumulatively significant 

impacts and should therefore be discussed in the same impact statement” (40 CFR 

1508.25). 

This section presents a discussion of the potential cumulative effects associated with the 

proposed project and is presented in three sections: Section 3.22.1, Basis for Assessment, 

addresses the basis of the evaluation including the regulatory framework, scope, and lists 

the past, present, and reasonably foreseeable future actions. Section 3.22.2, Descriptions 

of Selected Relevant Actions, describes relevant actions addressed. Section 3.22.3, 

Cumulative Effects by Resource, addresses the potential cumulative effects associated 

with the proposed project when considered together with the relevant past, present, and 

reasonably foreseeable actions. 

3.22.1 Basis for Assessment 

3.22.1.1 Scope of the Analysis 

The Greens Creek Mine and its TDF already exist. Alternative A considered in this 

document represents a continuation of the existing mining operation through 2019. All 

action alternatives represent an extension of mining operations of 30 to 50 years based on 

the current knowledge of the mineral resources, the positive forecast for the metals 

market, the historic success in replacing reserves over two decades, and the possibility of 

identifying and defining additional economic resources at the site through continuing 

exploration activities. It is acknowledged that the Green Creek Land Exchange Act 

allows mining to continue through 2095; however, there are no proposals to mine past 50 

years at this time. Proper final closure would include reclamation of the TDF in a 
Chapter 3. Affected Environment and Environmental Consequences

3-294 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

stabilized and re-vegetated condition. Consequently all analyses of impacts throughout 

this chapter consider the impact of the mine operation in the past, combined with the 

anticipated impacts of future operations. 

The scope for the analysis of cumulative impacts used in this EIS includes the following: 

 Identify potential effects of the expansion of the TDF and attendant extended life of 

the Greens Creek Mine that may occur on the natural resources and human 

environment; 

 Analyze other past, present, and reasonably foreseeable future projects that 

reasonably could affect the natural resources in the vicinity of the Greens Creek 

Mine; 

 Attempt to quantify effects by estimating the extent of changes to existing 

environment; and 

 Consider the guiding principles from existing standards, criteria, and policies that 

control the management of the natural resources of concern. 

To keep the cumulative effects analysis useful, manageable, and concentrated on the 

effects that are meaningful, greater weight has been given to activities that are more 

certain and geographically close to the project with a focus on issues of greatest concern. 

The analysis of impacts to different resources has involved the use of different spatial 

boundaries. For example, in analyzing the impacts to scenic resources, it makes sense to 

analyze impacts within visual range of the project or other portions of the mine. In 

analyzing socioeconomic impacts, the boundaries of the analysis are expanded to the 

effect of the continued life of the mine on the economy of the CBJ. 

Likewise, the analysis of impacts to different resources involved the use of different 

temporal boundaries. Direct impacts to wildlife from the activities associated with the 

operation of the mine or reclamation can be measured in a shorter timeframe than the 

potential effects of the TDF on water quality and secondary impacts to fish, wildlife, and 

vegetation, which can be longer term. 

3.22.1.2 Alternatives Chosen for Evaluation 

Overall, there would be very small differences between any of the action alternatives in 

terms of cumulative effects. These small differences are greatly overshadowed by the 

inherent uncertainty in making estimates of past, present, and reasonably foreseeable 

cumulative effects. Therefore, one analysis is presented for all four action alternatives. 

3.22.1.3 Selection of Relevant Past, Present and Reasonably Foreseeable 

Actions 

Based on a review of published material and available information about the Tongass 

National Forest and Admiralty Island on various agency websites and the scoping 

process, an initial list of existing, proposed, and reasonably foreseeable actions in the 

region was compiled to be assessed for inclusion in this cumulative effects evaluation. 

Resources drawn from include the Forest Service Schedule of Proposed Actions report 

April 2011 through June 2011 (Forest Service 2011a), October 2011 through December 

2011 (Forest Service 2011b), January 2012 through March 2012 (Forest Service 2012), 

the Alaska Department of Transportation and Public Facilities Project Information as of 

April 2011, the results of the scoping process, and agency comments. 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-295 

Some general criteria were developed to help assess the relevance of each past, present, 

and reasonable foreseeable actions. The relationships of the general criteria to the 

environmental resources evaluated in this EIS are summarized in Table 3.22-1. The basis 

and resources listed in Table 3.22-2 identifies potential effects of each action. The 

evaluation of applicable effects that contribute to cumulative effects is discussed under 

each resource below. 

The long list of potentially relevant past, present, and reasonably foreseeable actions was 

reviewed to assess the actions for relevance in this evaluation of cumulative effects and 

circulated to key stakeholder agencies to enlist their help in assessing the actions for 

relevance in this evaluation of cumulative effects (Table 3.22-2). 

This cumulative effects analysis does not attempt to quantify the effects of past human 

actions by adding up all prior actions on an action-by-action basis. The only major past 

action in the proposed project area is the operation of the mine. By looking at current 

conditions, residual effects of past human actions and natural events are captured, 

regardless of which particular action or event contributed those effects. In addition, the 

CEQ issued an interpretive memorandum on June 24, 2005 regarding analysis of past 

actions, which states, “agencies can conduct an adequate cumulative effects analysis by 

focusing on the current aggregate effects of past actions without delving into the 

historical details of individual past actions.” For these reasons, the analysis of past 

actions in this section is based on current environmental conditions as described in the 

previous sections (sections 3.2 through 3.22) and summarized below by resource.

3.22.2 Descriptions of Selected Relevant Actions 

Continued Operation of the Greens Creek Mine 

If a TDF expansion is approved, as considered in this EIS, the mine may continue to 

operate for an additional 30 to 50 years. Ongoing impacts to the environment considered 

in this and previous analyses (Forest Service 1983, 1988, 1992, 2003) would continue 

during this time and final reclamation would be delayed. It is acknowledged that the 

Green Creek Land Exchange Act allows for mining through 2095; however, there are no 

proposals to mine past 50 years at this time. If mining were to extend beyond 50 years, 

the overall impact would be similar to those considered in this analysis and in previous 

analysis; however, additional tailings and waste rock disposal areas would need to be 

identified and the effects analyzed consistent with NEPA. The overall footprint required 

for disposal of these additional wastes would be similar in size to that described for the 

proposed expansion in this EIS, approximately 150 acres more acres. 
Chapter 3. Affected Environment and Environmental Consequences

3-296 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.22-1. Relationship of Selection Criteria to Environmental Resources. 

Resource Selection Criteria 

General 1 Actions are planned (beyond speculation), are located in the same spatial 

scale (within proximity of the proposed action on Admiralty Island), and are 

able to be implemented within the same temporal scale (operating life of 30–

50 years) of the proposed action. 

General 2 Actions have international or global importance (e.g., climate change). 

Air Quality 3 Actions are within the same general air shed as the proposed action. 

Geotechnical 

Stability 

4 Actions are within the same watersheds as the proposed action. 

Geochemistry 5 Actions are within the same watersheds or aquifer as the proposed action. 

Water Resources 6 Actions are within the same watersheds or aquifer as the proposed action. 

Aquatic Resources 7 Actions occur within the same watersheds as the proposed action and Hawk 

Inlet. 

Soils 8 Actions involve a disturbance area that overlaps with the proposed action 

(project area). 

Vegetation 9 Actions involve vegetative zones and geographic distribution of plant 

communities that overlap with the study area for the proposed action (project 

area). 

Wetlands 10 Actions are within the same watersheds as the proposed action. 

Wildlife 11 Actions occur within wildlife habitats, ranges, or migratory corridors that 

overlap with the study area for the proposed action (Admiralty Island and 

surrounding waters). 

Threatened and 

Endangered 

Species 

12 Actions occur within wildlife habitats, ranges, or migratory corridors that 

overlap with the study area for the proposed action (Admiralty Island and 

surrounding waters). 

Land Use 13 Actions occur within geographic areas that overlap with the study area for the 

proposed action (Admiralty Island). 

Scenic Resources 14 Actions occur within the same viewshed as the proposed action 

Recreation 15 Actions occur within geographic areas that overlap with the study area for the 

proposed action (project area). 

Subsistence 16 Actions involve locations, habitats, ranges, or migratory corridors of 

subsistence resources that overlap with the study area for the proposed 

action. 

Cultural Resources 17 Actions occur within geographic areas that overlap with the study area for the 

proposed action. 

Socioeconomics 18 Actions occur within the CBJ and on Admiralty Island that could affect the 

area in terms of economics, commerce, or culture. 

Monument 

Resources 

19 Actions occur within the geographic boundaries of the Monument and 

overlap with the study area for the proposed action. 

Inventoried 

Roadless Areas 

20 Actions occur within the Greens Creek or Mansfield Peninsula IRAs 

Environmental 

Justice 

21 Actions occur within geographic areas that overlap with the study area for the 

proposed action. 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-297 

Table 3.22-2. General Criteria Applied in Selecting Relevant Actions for this Evaluation. 

Action Relevant Basis Resources 

Tongass National Forest, Admiralty National Monument

Continued operation 

of the Greens Creek 

Mine 

Y TDF expansion would allow 

mining to continue for up to 50 

years. Applicable selection 

criteria: 1, 3, 4, 5, 6, 7, 8, 9, 10, 

11, 12, 13, 14, 15, 16, 17, 18, 

19, 20, 21. 

All 

Angoon Airport 

Project (facility and 

road management, 

City of Angoon) 

Y Construction of a new 

commercial airport near the 

village of Angoon. Selected for 

this cumulative effects 

evaluation. Applicable selection 

criteria include 1, 11, 12, 18, 19. 

Wildlife, Threatened and Endangered 

Species, Socioeconomics, Monument 

Resources 

Hecla Greens Creek 

Mine (exploration 

drilling) 

Y Continuation of surface 

exploration program; provide 

safe helicopter landings and drill 

pads. Selected for this 

cumulative effects evaluation. 

Applicable selection criteria 

include 1, 3, 4, 5, 6, 7, 8, 9, 10, 

11, 12, 13, 14, 15, 16, 17, 18, 

19, 20. 

Air Quality, Geotechnical Stability, 

Water Resources, Geochemistry, 

Aquatic Resources, Soils, Vegetation, 

Wetlands, Wildlife, Threatened and 

Endangered Species, Land Use, 

Scenic Resources, Recreation, 

Subsistence, Cultural Resources, 

Socioeconomics, Monument 

Resources, IRAs 

Hecla Greens Creek 

Mine (geotechnical 

drilling) 

Y Mineral exploration and drilling. 

Selected for this cumulative 

effects evaluation. Applicable 

selection criteria include 1, 3, 4, 

5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 

15, 16, 17, 18, 19, 20. 

Air Quality, Geotechnical Stability, 

Water Resources, Geochemistry, 

Aquatic Resources, Soils, Vegetation, 

Wetlands, Wildlife, Threatened and 

Endangered Species, Land Use, 

Scenic Resources, Recreation, 

Subsistence, Cultural Resources, 

Socioeconomics, Monument 

Resources, IRAs 

Kanalku Creek 

Barrier Modification 

(modify partial barrier 

falls for improved 

migration of sockeye, 

southeast corner of 

Mitchell Bay) 

Y Modification of barrier falls. 

Selected for this cumulative 

effects evaluation. Applicable 

selection criteria include 1, 11, 

12, 19, 

Wildlife, Threatened and Endangered 

Species, Monument Resources 

Pack Creek 

Zoological Area 

Outfitter/Guide 

Permitting (recreation 

and special use 

management in Park 

Creek Zoological 

Area, SkagwayHoonah-Angoon 

Boroughs) 

Y Nature based viewing outfitting 

and guiding activities. 

Applicable selection criteria 

include 1, 11, 12, 19. 

Wildlife, Threatened and Endangered 

Species, Monument Resources 

Angoon Thayer 

Creek Hydroelectric 

Project 

Y Construction of a hydroelectric 

facility on Thayer Creek. 

Selected for this cumulative 

effects evaluation. Applicable 

selection criteria include 1, 11, 

12, 18, 19 

Wildlife, Threatened and Endangered 

Species, Socioeconomics, Monument 

Resources 
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3-298 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.22-2. General Criteria Applied in Selecting Relevant Actions for this Evaluation. 

Action Relevant Basis Resources 

Admiralty Cove Trail 

Project: completion 

of trails 

Y Completion of trails near 

Admiralty Cove. Selected for 

this cumulative effects 

evaluation. Applicable selection 

criteria include 1, 11, 12, 15, 19 

Wildlife, Recreation, Threatened and 

Endangered Species, Monument 

Resources 

Whitewater Bay 

Nonnative Invasive 

Plant Control 

Y Control of nonnative invasive 

plant in Whitewater Bay. 

Selected for this cumulative 

effects evaluation. Applicable 

selection criteria include 1, 9, 11, 

19 

Wildlife, Threatened and Endangered 

Species, Monument Resources 

Isolated or 

recreational 

residence cabins 

Y Permitted cabins on Mansfield 

Peninsula. Applicable selection 

criteria include 1, 11, 12, 15, 20. 

Wildlife, Threatened and Endangered 

Species, Recreation, IRAs. 

Mt. Robert Barron 

Communication Site 

Y Permitted communication site on 

the Mansfield Peninsula. 

Applicable selection criteria 

include 1, 11, 12, 20. 

Wildlife, Threatened and Endangered 

Species, IRAs. 

Alaska Department of Transportation and Public Facilities 

Angoon Ferry 

Terminal Passenger 

Facility (in 

preconstruction 

phase) 

Y Construct ferry terminal 

building/shelter with utilities 

and facilities for ferry 

passengers which may 

include parking and staging 

area improvements. Selected 

for this cumulative effects 

evaluation. Applicable 

selection criteria include 1, 11, 

12. 

Threatened and Endangered Species 

Angoon Ferry 

Terminal 

Improvement (in 

construction phase) 

Y Upgrades to existing bridge, 

float, dolphins, and structures 

to accommodate the fast ferry 

and LeConte class vessels to 

provide more options for ferry 

service to Angoon. Selected 

for this cumulative effects 

evaluation. Applicable 

selection criteria include 1, 11, 

12. 

Threatened and Endangered Species 

Other 

Indian Reservation 

Road Route 0025 

N Not selected for evaluation. 

Planned action is the 

development of a roadway. 

Although this action could take 

place within the operating life 

of the proposed action, it is 

considered too speculative to 

contribute to an evaluation of 

potential cumulative effects. 

N/A 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-299 

Table 3.22-2. General Criteria Applied in Selecting Relevant Actions for this Evaluation. 

Action Relevant Basis Resources 

Shee Atika ongoing 

timber harvest on 

private lands south of 

the mine 

Y Timber harvest on private 

lands. Selected for this 

cumulative effects evaluation. 

Applicable selection criteria 

include 1, 11, 12, 18. 

Wildlife, Threatened and Endangered 

Species, Socioeconomics 

Angoon Airport Project 

According to the 2007 Angoon Airport Master Plan prepared by the Alaska Department 

of Transportation and Public Facilities, the proposed airport would be designed around a 

single 3,300-foot runway with a full length parallel taxiway system. This runway would 

accommodate all small aircraft that are forecast to use the airport. Planned ancillary 

developments would include an aircraft parking apron, aircraft maintenance and storage 

facilities, and various support facilities, all of which would be situated to interface with 

the proposed taxiway system. A terminal building and associated parking lot is also 

anticipated to provide arriving and departing passengers shelter during inclement weather 

(FAA 2011). The Final EIS is expected to be completed in summer 2013 (Forest Service 

2011b). 

Hecla Greens Creek Mine (Exploration Drilling) 

The HGCMC plans to continue its surface exploration program in 2013 and proposes 

limited or minimal tree cutting in the Greens Creek IRA to provide safe helicopter 

landings and drill pads. Similar exploration programs are anticipated throughout mine 

operations (up to 50 years if the expansion is approved). 

Hecla Greens Creek Mine (Geotechnical Drilling) 

Geotechnical and hydrologic drilling were conducted in the project area in summer and 

fall 2011. About 15 sites were affected resulting in about 1.75 acres of total disturbance. 

Three sites were located within IRAs, with a total disturbance of about 0.3 to 0.4 acre 

within these areas. No roads were constructed (Forest Service 2011b). 

Angoon Ferry Terminal Passenger Facility 

Construct ferry terminal building/shelter with utilities and facilities for ferry passengers. 

Parking and staging area improvements may also be constructed. It is currently in the 

preliminary design and scoping stage as of April 2011. 

Angoon Ferry Terminal Improvement 

Angoon Ferry Terminal is in the construction stage to replace conventional mono-hulled 

service to Angoon with service by Alaska Marine Highway System Fast Vehicle Ferries 

Fairweather or Chenega when transiting between Sitka and Juneau. This will increase the 

frequency of service to Angoon and increase opportunities for the residents to go to Sitka 

and Juneau by stopping in Angoon once in one direction on each round trip between 

Juneau and Sitka. This federally funded project consists of removing the existing ferry 

terminal and constructing new ferry terminal structures. Work includes furnishing and 

installing a new steel transfer bridge; steel float system and associated pile restraints, 
Chapter 3. Affected Environment and Environmental Consequences

3-300 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

fenders and intermediate ramp and apron systems; six-pile supported mooring and 

breasting dolphin structures, and other miscellaneous work (State of Alaska 2010). 

Kanalku Creek Barrier Modification 

The Forest Service proposes to improve sockeye salmon passage over a partial fish 

passage barrier falls on the outlet stream from Kanalku Lake. The project area is located 

nearly 8 air miles from the community of Angoon, Alaska on Admiralty Island and is 

within the Kootznoowoo Wilderness Area, which is part of the Monument. The decision 

to implement this action was made in February 2012. 

Angoon Thayer Creek Hydroelectric Project 

The development of a hydroelectric facility on Thayer Creek to supplement the use of 

diesel generators by the City of Angoon was authorized in May 2009. The facility is a 1 

megawatt run of river hydroelectric facility located approximately 6 miles north of 

Angoon that includes a diversion dam, penstock, powerhouse, transmission lines and 

access roads. An application for a special use permit from the Forest Service was 

submitted in summer 2011 for installation of a stream gauge on Thayer Creek, locating 

and brushing the proposed access road center line and exploratory drilling for quality of 

quantity of rock quarries (Forest Service 2011c). 

Shee Atika Timber Harvest 

Timber harvesting has occurred and could occur in the future on private lands on 

Admiralty Island south of the mine. 

Admiralty Cove Trail Project 

This proposal involves the completion of trails from Admiralty Cove Cabin to Young 

Lake trail, with potential trail to Mole Harbor trail and Mitchell Bay trail. This is an 

American Recovery and Reinvestment Act project in agreement with SAGA (Forest 

Service 2011d). 

Whitewater Bay Nonnative Invasive Plant Control 

To control invasive plants, this project uses volunteers to hand-pull species hidden in the 

beach rye grass in Whitewater Bay, Kootznoowoo Wilderness Area. The existing project 

has been ongoing for three plus years with significant progress in controlling the spread 

of black bindweed. Additional work proposed includes one week long trips in the next 

two years (Forest Service 2011e). 

Isolated and Recreational Residence Cabins 

The Forest Service permits approximately 11 cabins on the Mansfield Peninsula. Most of 

these cabins are located on the eastern shore of the Mansfield Peninsula or in Barlow 

Cove, closest to Juneau. 

Mt. Robert Barron Communication Site 

Continued operation of communication site(s) located on Mt. Robert Barron on the 

Mansfield Peninsula. 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-301 

3.22.3 Cumulative Effects by Resource 

The above-described actions are reasonably foreseeable to occur in or affect resources in 

the general vicinity of the proposed action or alternatives and therefore are included in 

the cumulative effects evaluation. The actions comprise primarily two types of activities: 

(1) drilling (Hecla Greens Creek Mine exploration and geotechnical drilling) and 

(2) construction and operation of expanded or new facilities and infrastructure (Angoon 

Airport, Angoon Ferry Terminal Passenger Facility, and Terminal Improvement). The 

main source of cumulative impacts for the proposed action or alternatives is the 

continued operation of the mine and its associated facilities such as the mill, roads, 

offices, Young Bay dock, and Hawk Inlet seaplane, and barge loading docks. All action 

alternatives allow operations to continue for an additional 30 to 50 years; however, 

mining could potentially continue until 2095 as authorized by the Greens Creek Land 

Exchange Act. The potential cumulative effects of the proposed action or alternatives 

when considered together with these relevant actions are discussed below by resource. 

Climate Change 

Climate change refers to the large scale, global changes in precipitation patterns and 

temperatures over time, resulting from human activity and natural variability. Climate 

change has been included in this document because it is an ongoing condition that must 

be taken into consideration when evaluating the cumulative effects of the proposed action 

alternatives. 

Ongoing climate change research has been summarized in reports by the United Nations 

Intergovernmental Panel on Climate Change. The reports conclude that GHG emissions 

are the main source of accelerated climate change. Impacts of projected climate change 

include sea level rise, increase in air temperature, as well as changes in climate and 

weather patterns (Climate Change Considerations in project-level NEPA Analysis 2009). 

Combustion of fossil fuel produces emission byproducts that include GHG emissions. It 

is expected that the each alternative would result in GHG emissions which may 

contribute to a net increase in global concentrations. 

The magnitude of total GHG emissions associated with any one of the action alternatives 

has not been measured. Emission standards for primary pollutants including GHG for 

any action alternative would be set by air permits issued by the ADEC based on Alaska 

Ambient Air Quality Standards. On a global scale, the emissions from the alternatives 

are at such a minor scale and fairly dispersed that the direct effects of the project’s GHG 

emissions on climate change cannot be quantified. There are no quantifiable differences 

in carbon storage and GHG emissions between the action alternatives. No adaptive 

capacity of ecosystems is needed to mitigate climate change effects on the projects 

surrounding ecosystem. Likewise the proposed action and action alternatives are not 

sensitive to projected climate change impacts outlined by the United Nations 

Intergovernmental Panel on Climate Change (IPCC 2007). Predicted changes in 

precipitation magnitude and intensity (IPCC 2007) could alter the volume of runoff. 

Ongoing monitoring of precipitation would continue to be used by HGCMC to predict 

water management and treatment capacity needs. 

The EIS prepared for the 2008 Tongass Forest Plan Amendment discusses several issues 

related to climate change. These include the risk of possible effects, the considerable 

uncertainty concerning specific predictions of how the climate may change, and the 
Chapter 3. Affected Environment and Environmental Consequences

3-302 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

greater uncertainty regarding the effects of climate change on the resources of the 

Tongass National Forest. The Forest Plan EIS (Forest Service 2008a) contains an 

extensive discussion of climate change related to management activities (pages 3-11 to 3-

20, 3-50 to 3-51, 3-77, 3-92 to 3-93, 3-116 to 3-117, 3- 125 to 3-126, 3-203, 3-250, 3-

296, 3-340, 3-351 and 3-401). It describes the current considerable variability and 

uncertainty of possible outcomes because models available for estimating climate change 

are designed to predict changes on regional scales, and are not detailed enough to predict 

changes to the Tongass National Forest. Existing models do not entirely agree on how 

global warming will affect Southeast Alaska. 

Carbon sequestration, the flow of carbon into aquatic or terrestrial systems from the 

atmosphere, is also difficult to evaluate. Mature forests in Alaska are considered to be 

carbon ‘sinks’ meaning that these forest stands accumulate more carbon than they 

release. The regeneration of trees that would occur after mining has ceased and 

reclamation has begun would also accumulate carbon into the system. 

The 2008 ROD for the Tongass Forest Plan concludes there is uncertainty related to the 

specific effects climate change has on the resources of the Tongass National Forest and 

uncertainty about how activities on the forest affect climate change. The ROD indicates 

that the best course of action is continued management of the Tongass National Forest for 

resiliency in the face of uncertain, but anticipated, change. This will be accomplished 

primarily by management of the Tongass National Forest as a mostly intact ecosystem 

with a robust monitoring plan that will allow for adaptive management intervention if, 

and when, effects of climate change are more certain. Important components of the Forest 

Plan include: 

 A conservation strategy that includes an extensive reserve system in non-development 

LUDs and standards and guidelines where active management is minimized that 

protect over 90 percent of the existing productive old-growth habitat. 

 Standards and guidelines that include protection for soils on slopes >67 percent 

(roads), and slopes >72 percent (timber harvests), to help retain carbon stored as 

organic material in soils where timber harvest and road building occur. 

In addition to the Forest Plan’s monitoring and evaluation provisions that have been 

updated to address the effects of climate change, there are the long-term forest inventory 

system and regional forest health program monitoring changes related to insects, disease, 

pathogens, and windthrow and if effects from climate changes are detected, they would 

be addressed through existing planning procedures to determine whether changes in 

management are warranted. Even at the Forest Plan level, differences between 

alternatives in terms of the effects of climate change on the Tongass National Forest—

and in the effects of land management activities on climate change—are uncertain, 

unquantifiable, and likely to be small, especially compared to other routine human 

activities. For these reasons, information on climate change was deemed not essential to 

a reasoned choice among the alternatives considered in the Forest Plan EIS and therefore 

for the same reasons, would not be essential to a reasoned choice among alternatives for 

this FEIS. 

Air Quality 

Current baseline conditions resulting from past and present actions (mainly, the 

construction and operation of the mine) are described in detail in Section 3.2. In 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-303 

summary, air quality measurements for PM10 at the mine site are below NAAQS 

standards set to protect human health and the environment. 

Short-term cumulative adverse effects on air quality could result from construction of 

exploration drill pads and roads, transportation and stockpiling of mining products, and 

during construction associated with relevant actions. Effects from emissions, including 

GHGs, could occur from stationary and mobile combustion engines. Fugitive dust would 

be generated during construction of facilities, as well as during project operations as part 

of the proposed action alternatives. 

Most mobile sources of emissions (e.g., pad construction) associated with exploration 

would be of limited duration, although emissions from drilling operations may occur 

intermittently throughout the year. In these cases, the emission sources would be limited 

to a small number of engines at each location. While the additional dust generated would 

be of a cumulative nature, the mine’s air permits would continue to require that all 

emissions levels meet NAAQS at the mine’s industrial boundary. 

Construction activities associated with the Angoon airport, the Angoon Ferry Terminal 

Passenger Facility, and the Angoon Ferry Terminal Improvement may overlap in time 

with the proposed action alternatives, although individual projects may not overlap with 

each other; however, measureable effects to air quality are not expected to overlap 

spatially. 

Mining and construction activities would be regulated under air permits issued by ADEC 

and all other stationary and mobile emissions would be regulated according to Alaska and 

federal regulations. Existing air quality in the air shed associated with these past, present, 

and reasonably foreseeable projects is expected to remain within NAAQS. Therefore, it 

is anticipated that potential cumulative effects on air quality, based on the incremental 

effects of the existing and relevant projects considered in this cumulative effects 

evaluation, would be less than significant. 

Geotechnical Stability 

Current baseline conditions resulting from past and present actions (mainly, the 

construction and operation of the mine) are described in detail in Section 3.3. In 

summary, the TDF has been constructed in compliance with the Plan of Operations, 

waste management permit, and design measures established to ensure stability of the pile. 

Potential cumulative effects on geotechnical stability would be limited to the proposed 

action alternatives and drilling activities. The relevant construction actions are not 

expected to affect geotechnical stability within the area of the proposed action 

alternatives. The proposed facilities are expected to remain stable or will require 

mitigation for some alternatives. Relevant action drilling activities will not likely have a 

significant effect to stability of the existing and proposed facilities. If mining were to 

continue beyond 30 to 50 years, potentially up to the year 2095, additional geotechnically 

stable tailings and waste rock disposal areas would need to be identified. 

Geochemistry 

Among the relevant actions being evaluated, it is anticipated that potential geochemical 

effects would be limited to those relevant actions involving mining. Measurable 

environmental effects are not expected to result from exploration drilling or any other of 

the relevant actions. The proposed action alternatives accounts for continued success in 
Chapter 3. Affected Environment and Environmental Consequences

3-304 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

identifying additional reserves and continued mining activities for 30 to 50 years, there 

are no other relevant actions that would contribute cumulatively to the geochemical 

effects of the proposed action alternatives. Effects would be similar if mining continued 

through 2095, although the location of waste facilities may vary, potentially affecting 

new areas. The need for long-term water quality treatment would be the same, as longterm water quality treatment is necessary. 

Water Resources 

Current baseline conditions resulting from past and present actions (mainly, the 

construction and operation of the mine) are described in detail in sections 3.5 and 3.6 for 

surface water and groundwater, respectively. Water resources have been managed by 

past and present actions to reduce or eliminate significant effects. Fresh surface water 

within the Greens Creek area is monitored and protected using water quality criteria for 

all designated beneficial uses, including aquatic life. Collected wastewaters are treated to 

meet effluent limits identified in an NPDES permit prior to discharge through a diffuser 

outfall located in Hawk Inlet. The majority of native groundwater at the site is 

intercepted or routed around the TDF by perimeter up-gradient groundwater diversions 

and barriers, and this water does not require containment or treatment. 

Exploration drilling and the proposed action alternatives would all occur within the same 

watershed and aquifer, and effects of each could overlap in time. Thus, these projects 

could potentially produce adverse cumulative effects on water resources. Exploration 

drilling is unlikely to have any effect on marine waters, nor any significant effect on 

freshwater. Cumulative adverse effects on marine water could occur as a result of the 

Angoon Airport and Ferry construction, and cumulative adverse effects to surface waters 

in a separate watershed could occur from sediment and runoff from the construction; 

however, these effects would not overlap in space with the proposed action alternatives 

and are therefore not considered. The other relevant actions are not located within the 

same watersheds as the proposed action alternatives, therefore will not contribute to 

cumulative effects to surface water. 

The planned drilling activities would involve a relatively low level of activity that would 

have minimal effect on fresh surface water quality. Because wastewater from the mining 

operations would be treated, and the discharge quality would be governed by applicable 

permits, the potential cumulative effects on water quality are anticipated to be less than 

significant. Most of the effects to water resources, including interbasin water transfer, 

would be due to the proposed action alternatives, and therefore cumulative effects are 

likely to be insignificant. 

Effects to water resources would be similar if mining continued through 2095, although 

the location of waste facilities may vary, potentially affecting new watersheds. The need 

for long-term water quality treatment would be the same, as long-term water quality 

treatment is necessary. 

Aquatic Resources 

The relevant actions within the aquatic habitats and migratory corridors include the 

drilling and construction actions. Potential adverse cumulative effects on freshwater 

aquatic resources (fish and benthic invertebrates) could occur within freshwater streams 

from drilling activities in combination with the proposed action alternatives. Short-term 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-305 

effects on aquatic resources could include increased turbidity, increased sediment 

generated, temporary physical disruption of habitats during construction, and possible 

spills of contaminants from the relevant actions. The ongoing and future drilling 

activities would involve a relatively low level of activity with corresponding limited 

opportunity to contribute sediments or other discharges to the local drainages. Therefore, 

they would be expected to have minimal incremental effect on aquatic resources. The 

combined proposed action alternatives and relevant construction actions may have greater 

potential to create adverse cumulative effects on the aquatic resources in the respective 

drainages through increased sediment loading and wastewater discharges. Long-term 

effects would include a loss of habitat from changes to water quality or physical changes 

such as sedimentation in spawning gravels. Sediment would be controlled with BMPs 

identified within the storm water management plan (part of the discharge permit 

requirements). Wastewater from mining operations would be treated, discharged to 

Hawk Inlet, and the discharge quality controlled by applicable permits. Therefore the 

potential cumulative effects on freshwater aquatic resources are expected to be less than 

significant in the drainages associated with the proposed action alternatives. 

Cumulative aquatic resources effects associated with construction of the ferry and airport 

and other actions would occur within a different watershed and not overlap within the 

freshwater drainages of the proposed action alternatives. The effects would be localized 

and at a location well removed from the proposed action alternatives and therefore 

contributions to effects to freshwater resources would not be considered cumulatively 

significant. 

Cumulative adverse effects on marine aquatic resources could occur from relevant 

actions related to the proposed action, and operation and construction of the ferry 

passenger terminal and improvements due to marine wastewater discharge and the risk of 

concentrate or fuel spills. Cumulative effects would primarily occur as short-term 

increases in sediments and turbidity during construction activities. BMPs (e.g., sediment 

control) required through Section 10 permits would limit construction effects. Any 

marine discharge of wastewater would need to meet permit limits, therefore limiting the 

area affected by the outfall. Spills either from supply unloading, fuel transfers, or 

concentrate loading or transport could cause significant localized effects to marine 

aquatic resources over the short term until the spill is cleaned up. Overall, cumulative 

effects are not anticipated to produce significant adverse impacts to aquatic resources. 

Effects to aquatic resources would be similar if mining continued through 2095, although 

the location of waste facilities may vary, potentially affecting new watersheds and 

additional fish habitat. 

Wetlands 

The past and present construction and operation of the mine has resulted in direct impacts 

to wetlands as described in Section 3.8. The acres of wetlands affected by the original 

tailings pile are not well defined; existing dock facilities, portions of the road system, and 

the original TDF occupy former wetland areas. In 2003, the USACE issued a permit to 

the operator to discharge fill material into approximately 60 acres of waters of the United 

States, consisting mainly of Palustrine Forested Wetlands, to facilitate the expansion of 

the TDF and related infrastructure. The relevant actions within the wetland zones and 

geographic distribution of wetlands that overlap with those affected by the proposed 

action alternatives include the drilling actions and not the construction actions in Angoon 
Chapter 3. Affected Environment and Environmental Consequences

3-306 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

or other projects located in the Monument. Minimal filling of wetlands, if any, would 

occur for drilling actions. Minimal clearing is expected that would directly impact 

wetlands. Relative to the proposed action alternatives, which would result in the filling 

of about 85 acres of wetlands, the effects on wetlands from drilling actions are minimal; 

therefore cumulative effects are likely to be insignificant as most of the effects to 

wetlands would be from the proposed action alternatives. Effects to wetlands would be 

similar if mining continued through 2095, although additional wetlands would likely be 

lost as additional waste disposal areas are developed. 

Soils 

The past and present construction and operation of the mine has resulted in direct impacts 

to soils (soil disturbance) as described in detail in Section 3.9. The relevant actions 

within the soil disturbance area of the proposed action alternatives include the drilling 

actions and not the construction actions in Angoon or other projects located in the 

Monument. Effects to soil resources from relevant drilling actions are expected to be 

minimal. Most of the effects to soil resources would be due to the proposed action 

alternatives, and therefore cumulative effects are likely to be insignificant. Effects to 

soils would be similar if mining continued through 2095, although the location of waste 

facilities may vary, potentially affecting new areas. 

Vegetation 

FSM 2670.22 requires the preservation of “viable populations of all native ...plant 

species in habitats distributed throughout their geographic range on National Forest 

System lands.” Populations in southern Tongass National Forest may be affected by 

logging activities. A large portion of Admiralty Island, including along the southern edge 

of the mine area, has been designated as wilderness since 1980. Wilderness designation 

protects those lands from most disturbances. Historically, human disturbance in the 

project area has occurred in the form of mining, road building, port and administrative 

and other facility construction, and minerals exploration activities. 

The past and present construction and operation of the mine has resulted in direct impacts 

to vegetation as described in Section 3.10. Changes to vegetation include direct impacts 

to vegetation communities, mostly Sitka spruce-western hemlock forests. Effects on 

plant populations are cumulative over time due to the repetition and interaction of direct 

and indirect effects. Possible effects of the proposed increase in disturbance area are 

cumulative with historical, present, and future uses of the project area. Ongoing mining 

exploration and extraction activities have occurred over the past 25 years, including 

establishment and alterations of roads, above-ground mining/processing sites, waste 

disposal, equipment and topsoil storage, administration complex, rock/gravel pits, and 

exploratory drilling sites. Under any of the action alternatives, mining would continue 

for another 30 to 50 years with potential adjustments to the current proposal in the future 

that may lead to more disturbances. The relevant actions within the vegetative zones and 

geographic distribution of plant communities that overlap with those affected by the 

proposed action alternatives include the drilling actions and not the construction actions 

in Angoon or other projects located in the Monument. Minimal tree cutting would occur 

for exploration drilling and less than 2 acres of ground disturbance would occur for the 

geotechnical drilling. Relative to the proposed action alternatives, the effects on 

vegetation from drilling actions are minimal; therefore cumulative effects are likely to be 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-307 

insignificant as most of the impacts to vegetation would be from the proposed action 

alternatives. There would be a continued risk of introduction or spread of noxious weeds 

or invasive plant species; however, with the implementation of mitigation measures 

identified in the invasive plant risk assessment, impacts from noxious weeds and invasive 

species are expected to be minimal. These mitigation measures would apply to all 

operations at the mine, and thus the cumulative impact from noxious or invasive plants 

would also be minimal. Effects to vegetation would be similar if mining continued 

through 2095, although additional vegetation would be removed to make room for 

additional waste disposal. 

Impacts to rare plants from the action alternatives are described in Section 3.12. Malaxis 

paludosa (bog adder’s-mouth) was found near the existing TDF and would be adversely 

impacted by the proposed action. Bog adder’s-mouth could also be affected by drilling 

activities at the mine. 

Wildlife 

Current baseline conditions resulting from past and present actions (mainly, the 

construction and operation of the mine) are described in detail in Section 3.11. Potential 

effects to wildlife associated with construction and operation of the mine included habitat 

loss, disturbance and/or displacement due to mining activities, attraction of wildlife to 

mine facilities, and contamination due to contact with water discharged into Hawk Inlet. 

Relevant actions that would affect wildlife include the drilling actions within Greens 

Creek Mine and construction actions in Angoon and are therefore evaluated in 

cumulative effects. Human activity, direct habitat loss, and exposure to contaminants 

may affect wildlife. The effects of drilling activities on wildlife are relatively low; 

drilling project footprints are small and management requirements are enforced to limit 

environmental effects. Exploration drilling is typically authorized annually in a decision 

memo, as it is a type of activity that normally does not individually or cumulatively have 

a significant effect on the quality of the human environment (36 CFR 220.6(e)(8)). 

Disturbance to species may occur from human activity associated with mining operations, 

drilling actions, construction and operation of the Angoon airport, and construction and 

operation of the Angoon ferry terminal facility and improvement, causing an indirect loss 

of habitat and displacement of species in the vicinity of the ongoing and proposed action 

alternatives. Construction activities could be postponed or relocated to avoid significant 

adverse effects to nest sites of species such as bald eagles and marbled murrelet, however 

ongoing operation of the proposed action and airport would continue to have cumulative 

effects for the duration of the actions. 

Oil or fuel spills could occur from vessels at the marine terminal or at the dock in Young 

Bay as well as the Angoon ferry terminal. Spills could adversely impact marine 

mammal, waterfowl, and shorebird species foraging or moving through the shallow 

shoreline areas. Spill control plans and rapid response to spills would be the primary 

mitigation measures to avoid or minimize adverse spill effects to wildlife species in the 

marine environment. 

The proposed action alternatives and relevant drilling and construction and operation of 

relevant actions would extend the duration of direct habitat loss such as old growth forest 

and wetlands used for foraging and breeding. Cumulative loss of habitat acreages 
Chapter 3. Affected Environment and Environmental Consequences

3-308 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

associated with the proposed action alternatives as well as construction of the Angoon 

airport and ferry terminal facility, hydroelectric facility, and timber harvest could affect 

some species of wildlife. Specific acreages of habitat lost due to construction and 

operation of related facilities is not known at this time. 

The proposed action alternatives and ferry terminal facility and improvements could 

increase marine mammal exposure to metal concentrations in prey due to project-related 

discharges, oil or fuel spills, and vessel/crew shuttle traffic. However, given the seasonal 

nature of these species in Hawk Inlet, Chatham Straight, Young Bay, and Stephens 

Passage, the proposed action alternatives would not result in “take” as defined under the 

MMPA. It is undetermined at this time if the ferry terminal and Angoon airport 

construction and operation would also not result in a “take.” Effects to wildlife would be 

similar if mining continued through 2095, although additional wildlife habitat would be 

lost as additional waste disposal areas are developed. 

Although detailed impacts assessments have not been prepared for relevant construction 

projects around Angoon, it is likely that managing authorities would require management 

practices and mitigation to offset adverse effects. Additionally, these projects are located 

about 40 miles from the action alternatives. However, because detailed effects analyses 

are not yet available, the cumulative effect of the action alternatives when combined with 

the relevant actions may be minor to moderate. 

Threatened, Endangered, Candidate, and Forest Service Alaska Region 

Sensitive Species and Rare Plants 

Current baseline conditions resulting from past and present actions (mainly, the 

construction and operation of the mine) are described in detail in Section 3.12. Potential 

effects to wildlife associated with construction and operation of the mine included habitat 

loss, disturbance and/or displacement due to mining activities and associated marine 

traffic, attraction of wildlife to mine facilities, and increased metals concentrations in 

prey due to treated water discharged into Hawk Inlet. Operation of the port does not 

constitute harassment or a “take” under the ESA or the MMPA according to the 2003 BA 

for marine mammals. 

Operation of the proposed Angoon ferry terminals would result in additional marine 

traffic and an increased risk of spills in the marine environment, and thus have the 

potential to disturb marine mammals, birds, and fish using Chatham Strait or result in 

their exposure to toxics. Therefore, these projects have the potential to impact 

individuals of these species that could also occur in the vicinity of the Hawk Inlet Marine 

Terminal. The proposed action alternatives and relevant actions are not likely to 

adversely affect the humpback whale or Steller sea lion because of the seasonal nature of 

these species would reduce the exposure to metals concentrations in prey, oil and fuel 

spills, or vessel traffic. Yellow-billed loons do not occur in large concentrations in 

southeast Alaska, therefore few individuals would be at risk of exposure to fuel or oil 

spills from vessels. Herring are not known to spawn in this area, but juveniles would be 

present (Monagle 2011); therefore, juveniles would be at risk of exposure to project 

related water quality and sedimentation impacts. However, the NPDES permit would 

limit the effects of the project on water quality. Therefore, impacts to Southeast Alaska 

DPS Pacific Herring would be minor. In addition, it is assumed that these projects would 

operate in compliance with the ESA and the MMPA. Therefore, the proposed project 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-309 

when taken together with these foreseeable projects would not result in significant 

cumulative impacts on the humpback whale, Steller sea lion, yellow-billed loon, and 

pacific herring. 

The relevant actions occurring in Angoon (ferry terminal and airport) would not overlap 

in space and time with the proposed action alternatives in terms of impacts on goshawks, 

therefore are not included in the cumulative impacts analysis. No nesting goshawks were 

documented within the existing lease area in 2010, though suitable nesting habitat was 

documented in the vicinity of the TDF proposed action. Surveys were also conducted in 

2011 in the area around the proposed TDF north of the existing TDF and an active nest 

was documented adjacent to the new TDF site. Future exploration drilling has the 

potential to disturb nesting goshawks if drilling were proposed near an active nest site. 

However, it is assumed that goshawk nest surveys would be conducted in suitable habitat 

in the vicinity of the drill sites prior to ground disturbance. If an active nest were 

documented, the Forest Service Standards and Guidelines for goshawks would be 

implemented to minimize impacts to this species. Therefore, the proposed action, when 

taken together with the foreseeable actions, would result in moderate cumulative impacts 

on this species. 

The proposed action alternatives would result in potential for exposure of black 

oystercatchers to oil or fuel spills at the Hawk Inlet marine terminal. Ongoing marine 

traffic in Hawke Inlet has the potential to contribute to this effect. However, because 

there are no large concentrations of black oystercatchers known to occur in Hawk Inlet 

and likely few individuals to occur in the vicinity of the marine terminal, and because the 

risk of spills is also low, the likelihood of cumulative effects to the black oystercatcher 

population associated with the proposed action alternatives in combination with existing 

marine traffic is very low. 

The relevant actions occurring in Angoon (ferry terminal and airport) would not overlap 

in space and time with the proposed action alternatives in terms of impacts on sensitive 

plants, therefore are not included in the cumulative impacts analysis. No sensitive plants 

were found in the currently permitted tailings lease area, Surveys for rare and sensitive 

plants would likely be conducted prior to drilling, and sensitive plants would be avoided, 

therefore the proposed action alternatives in combination with future mine drilling 

activities would have negligible cumulative impacts on sensitive plants. 

Effects to threatened and endangered species would be similar if mining continued 

through 2095. Effects determination for threatened and endangered species would not 

likely change, although determinations would be reevaluated and consultation would 

occur with NMFS and USFWS. 

Land Use 

The past and present construction and operation of the mine has resulted in changes to 

land use from forest land and a cannery as described in Section 3.13. Relevant drilling 

actions would occur within the existing site of the proposed action alternatives, therefore 

would not result in a change of land use and would not have significant cumulative 

effects. The relevant actions located in Angoon would change the land use in that part of 

Admiralty Island. Cumulatively, the change in land use is not considered a significant 

adverse impact on land use overall on Admiralty Island. Under the terms of the Greens 
Chapter 3. Affected Environment and Environmental Consequences

3-310 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Creek Land Exchange Act, mining may not occur in the area after 2095 when most lands 

would be turned over to the federal government. 

Scenic Resources 

The past and present construction and operation of the mine has resulted in changes to 

scenic resources from predominantly natural in appearance, except for the presence of the 

historic cannery facility, as described in Section 3.14. The relevant actions occurring in 

Angoon (ferry terminal and airport) would not overlap in space and time with the 

proposed action alternatives in terms of impacts on scenic resources, therefore are not 

included in the cumulative impacts analysis. The relevant drilling actions may be visible 

from Hawk Inlet, and therefore may overlap in space and time with the proposed action 

alternatives. However, effects of the drilling activities are temporary and of limited 

extent, and therefore impacts on scenic resources would primarily be from the proposed 

action alternatives, and therefore cumulative impacts would be negligible. 

If mining continues beyond 30 to 50 years, waste disposal areas would need to be 

expanded or additional areas developed. The effect on scenic resources would depend on 

how and where additional waste disposal facilities were developed. 

Recreation 

The past and present construction and operation of the mine has not resulted in significant 

changes to recreation except within the project area, as described in Section 3.15. 

Increased boat traffic during the construction phase of the proposed action alternatives 

and relevant actions in Angoon (ferry terminal and airport) may overlap in time and 

space. However, the indirect effects on recreation, including hunting and fishing are not 

likely to significantly adversely affect recreation. Views to boaters and anglers using 

Hawk Inlet would be not significantly changed as a result of drilling activities, and 

relevant actions in Angoon would not be within views of boaters and anglers in the 

vicinity of the proposed action alternatives, and therefore would not contribute to a 

cumulative effect. Effects to recreation would be similar if mining continued through 

2095. 

Subsistence 

The past and present construction and operation of the mine has not resulted in significant 

changes to subsistence as described in Section 3.16. There are no communities located in 

the vicinity of the mine, however the community of Angoon may be considered within 

the study area for subsistence. The proposed action alternatives, drilling activities, and 

construction and operation of the Angoon airport and ferry facilities are considered for 

the cumulative effects analysis on subsistence resources due to the proximity to Hawk 

inlet and Chatham Strait. Hawk Inlet is not in the Customary and Traditional Use Area 

for any rural communities, but the area has long been used for subsistence hunting, 

fishing, and gathering. However, the reliance on subsistence resources harvested in this 

area is minor and the impacts of the action alternatives on fish and wildlife resources are 

expected to be negligible. As a result, the cumulative effects of the proposed action 

alternatives and relevant actions on the subsistence use of wildlife, fish, or other 

resources are expected to be very low. Effects to subsistence resources would be similar 

if mining continued through 2095, although there some additional habitat would be lost 

as expanded or new waste disposal facilities would be developed. 
3.22 Cumulative Effects 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-311 

Cultural Resources 

The past and present construction and operation of the mine has not resulted in significant 

changes to cultural resources as described in Section 3.17. The proposed action 

alternatives, drilling activities, construction of the Angoon Ferry terminal facilities and 

construction of the Angoon airport would require ground disturbance, and thus could 

have the potential to affect cultural resources. Each activity would be subject to 

investigation and consultation procedures prescribed under the Section 106 process of the 

NHPA. Prior to any planned disturbance at these project sites, the areas would be 

surveyed to determine the presence or absence of archaeological and historic evidence, 

and sites containing such evidence would be evaluated for listing on the NRHP. Eligible 

sites would either be avoided or would undergo data recovery and documentation under 

strict protocols. 

The cumulative nature of the effects of these projects would be regional rather than local. 

Because projects would need to follow the Section 106 guidelines regarding the presence 

of cultural resources, effects from the development of any of the relevant projects under 

consideration would be minimized. Therefore, it is expected that potential cumulative 

effects on cultural resources would not be significant. 

If mining continued through 2095, additional waste disposal areas would need to be 

identified. Prior to development, the areas affected would be surveyed for cultural 

resources and the effects would be avoided or mitigated. 

Socioeconomics 

Greens Creek Mine was identified as Juneau’s largest private employer in 2009, it 

generates approximately $1 million in annual property tax revenues, and the mine pays 

$5 million per year for a license. The relevant actions occurring in Angoon (ferry 

terminal and airport) would not overlap with the study area of the proposed action 

alternatives, as the proposed action alternatives are in the CBJ, and the relevant actions in 

Angoon are part of the Hoonah-Angoon Census area, and therefore are not included in 

the cumulative effects analysis. The relevant drilling activities overlap in space and time 

with the proposed action alternatives, and are therefore included in the cumulative effects 

analysis. In comparison to the proposed action alternatives, drilling activities are 

expected to be short-term in nature, employ relatively few people, generate relatively 

little income, generate little to no income for the CBJ, and not change the population 

significantly. Therefore, cumulative socioeconomic effects are expected to be less than 

significant. Socioeconomic effects would be similar if mining continued through 2095, 

although the positive benefits realized by local communities, primarily Juneau, would 

continue longer. 

Monument Resources 

The past and present construction and operation of the mine has affected Monument 

resources as described in Section 3.19. The location of the proposed action alternatives is 

in and adjacent to the Monument, although to varying extent between the alternatives. 

Relevant actions that may occur in this vicinity include drilling activities on the mine site,

Angoon airport and ferry terminal, Kanalku Creek Barrier Modification, Pack Creek 

Outfitter, Thayer Creek Hydroelectric Project, Admiralty Cove trails, and Whitewater 

Bay nonnative invasive plant control. The effects of drilling activities on Monument 
Chapter 3. Affected Environment and Environmental Consequences

3-312 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

resources are relatively low; drilling project footprints are small and management 

requirements are enforced to limit environmental effects. Exploration drilling is typically 

authorized annually in a decision memo, as it is a type of activity that normally does not 

individually or cumulatively have a significant effect on the quality of the human 

environment (36 CFR 220.6(e)(8)). The Angoon airport and ferry terminal are adjacent 

to the Monument, and therefore have indirect effects to wildlife and habitat over the longterm operation of each facility. The effects of the Kanalku Creek Barrier Modification 

improve fish habitat by improving passage for sockeye salmon. The effects of the Pack 

Creek Outfitter and Guide activities include minor effects to wildlife with the increased 

usage of the Monument by people. The Thayer Creek Hydroelectric Project will affect 

the scenic landscape in the vicinity of the creek, the natural ecology of Thayer Creek for 

the 1-mile span, and alter fish passage in the creek. The Admiralty Cove trail completion 

project will encourage hikers to the area, thus affect wildlife resources. The Whitewater 

Bay nonnative invasive plant control will enhance wildlife habitat on the shores of 

Whitewater Bay by controlling the spread of invasive species. Each of these relevant 

actions has localized effects: some adverse and some positive enhancements. However, 

they do not overlap with the area of the proposed action alternatives. Therefore, due to 

the spatial distribution throughout the Monument, from a cumulative effects standpoint, 

the overall effects to Monument resources are relatively low. 

If mining continued through 2095, additional waste disposal areas are would need to be 

developed either by expanding existing facilities or developing a new disposal site. 

Effects to Monument resources would depend on how and where the additional disposal 

areas were developed. 

Inventoried Roadless Areas 

The Greens Creek (307) and Mansfield Peninsula (306) IRAs surround the project area. 

Other actions that occur within or affect these IRAs could incrementally contribute to 

cumulative effects on the roadless characteristics of the IRAs. Other relevant actions or 

activities that occur within these IRAs include exploration and geotechnical drilling 

activities on and around the mine site (within the Greens Creek IRA) and the continued 

presence of communication sites and several cabins within the Mansfield Peninsula IRA. 

The effects of these activities on the biological, physical, and social values of the IRAs 

are relatively low and well dispersed. Besides the continued presence and operation of 

the mine, no other projects have been identified that would measurably affect roadless 

characteristics within these IRAs. Relative to the proposed action alternatives, the effects 

on IRAs from other relevant actions are minimal; therefore cumulative effects are likely 

to be insignificant as most of the impacts to IRAs would be from the proposed action 

alternatives. 

If mining continued through 2095, additional waste disposal areas are would need to be 

developed either by expanding existing facilities or developing a new disposal site. 

Effects to IRAs would depend on how and where the additional disposal areas were 

developed. Because of the extent of IRAs in the area, any expansion would likely 

include these lands. 

Environmental Justice 

The past and present construction and operation of the mine has not affected 

environmental justice as described in Section 3.21. There are no communities located in 
3.23 Irretrievable and Irreversible Commitment of Resources 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 3-313 

the vicinity of the proposed action alternatives. The nearest minority communities are 

Hoonah (28 miles) and Angoon (44 miles). None of these communities are expected to 

be significantly affected by the proposed action alternatives; therefore no cumulative 

effects are expected. Effects would be similar if mining continued through 2095. 

3.23 Irretrievable and Irreversible Commitment of 

Resources _________________________________ 

An irreversible commitment of resources applies primarily to the loss of non-renewable 

resources (e.g., minerals or cultural resources) and resources that are renewable only over 

a long period of time (e.g., soil productivity). Irretrievable commitments apply to loss of 

production or use of renewable resources. These opportunities are forgone for the period 

of the proposed action, during which the resource cannot be used. These decisions are 

reversible, but the utilization opportunities forgone are irretrievable. Table 3.23-1 

presents the irreversible and irretrievable resource commitments associated with the 

Greens Creek Mine TDF expansion. Note that because this mine is already in operation 

irretrievable and irreversible commitment of resources has already occurred for most 

resources and was evaluated in past EISs. 
Chapter 3. Affected Environment and Environmental Consequences

3-314 Greens Creek Mine Tailings Disposal 

Table 3.23-1. Irreversible and Irretrievable Resource Commitments. 

Resource Alternative A Alternative B Mitigated Alternative B Alternative C 

Air quality No foreseeable or 

predicted irreversible or irretrievable commitments beyond those previously evaluated. 

Same as Alternative A. Same as Alternative A. Same as Alternative A. 

Geochemistry/ Geology 

Loss of 360,000 cubic yards of tailings and waste rock per year until 2019. 

Loss of 360,000 cubic yards of tailings and waste rock per year for 30–50 years 

Same as Alternative B. Same as Alternative B. 

Surface water hydrology - Percent of watersheds affected by new disturbance 

No foreseeable or predicted irreversible or irretrievable commitments beyond those previously evaluated. 

Tributary Creek: 23 Cannery Creek: 6 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 0 South Hawk Inlet: 17 

Tributary Creek: 18 Cannery Creek: 6 Fowler Creek: 0 North Hawk Inlet: 0 Middle Hawk Inlet: 2 South Hawk Inlet: 17 

Tributary Creek: 2 Cannery Creek: 4 Fowler Creek: 2 North Hawk Inlet: 7 Middle Hawk Inlet: 1 South Hawk Inlet: 20 

Surface water hydrology – Reduction in stream flow 

No foreseeable or predicted irreversible or irretrievable commitments beyond those previously evaluated. 

Minor reduction in flow in two creeks (Tributary and Cannery) but more than Alternative A. 

Similar to Alternative B. Minor reduction in flow in 

three creeks (Tributary, Cannery, and Fowler). 

Surface Water Quality 

No foreseeable or predicted irreversible or irretrievable commitments beyond those previously evaluated. 

Same as Alternative A. Same as Alternative A. Same as Alternative A. 

Groundwater Additional and increased 

lowering of groundwater heads in bedrock in the expansion area would likely occur. 

Additional and increased lowering of groundwater heads in bedrock in the expansion area would likely occur. 

Additional and increased lowering of groundwater heads in bedrock in the expansion area would likely occur. 

Additional and increased lowering of groundwater heads in bedrock in the expansion area would likely occur. Reduction in groundwater discharge to Fowler Creek and tributaries could occur. 
3.23 Irretrievable and Irreversible 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Table 3.23-1. Irreversible and Irretrievable Resource Commitments. 

Resource Alternative A Alternative B Mitigated Alternative B Alternative C 

Aquatic Resources Reduced stream flow to 

Tributary and Zinc creeks from water interception in the TDF, resulting in reduction of spawning and rearing habitat. 

Direct habitat loss of about 4,000 linear feet of streams (Class I and II combined) by burial. Reduced stream flow to Tributary and Zinc creeks from water interception in the TDF would increase from Alternative A, resulting in reduction of spawning and rearing habitat. 

Direct habitat loss of about 2,850 linear feet of streams (Class I and II combined) by burial. Reduced stream flow to Tributary and Zinc creeks from water interception in the TDF would increase from Alternative A, resulting in reduction of spawning and rearing habitat. 

Direct habitat loss of about 1,000 linear feet of streams (Class II only) by burial. Reduced stream flow to Fowler, Tributary and Zinc creeks from water interception in the TDF, and resulting in reduction of spawning and rearing habitat, though to a much lesser extent than under Alternative B or Mitigated Alternative B. 

Soils No foreseeable or 

predicted irreversible or irretrievable commitments; not previously evaluated. 

Same as Alternative A. Same as Alternative A. Same as Alternative A. 

Vegetation and Wetlands 

Some additional irreversible change in vegetative species composition likely due to fugitive dust deposition from road and TDF. 64 acres of vegetation irretrievably impacted by the existing TDF Some areas revegetated through reclamation after closure. Permanent loss of 5 acres of wetlands at the TDF 

Some additional irreversible change in vegetative species composition likely due to fugitive dust deposition from road and TDF. 178 acres of vegetation irretrievably impacted by the existing TDF Some areas revegetated through reclamation after closure. Permanent loss of 85 acres of wetlands at the TDF 

Some additional irreversible change in vegetative species composition likely due to fugitive dust deposition from road and TDF. 160 acres of vegetation irretrievably impacted by the existing TDF Some areas revegetated through reclamation after closure. Permanent loss of 77 acres of wetlands at the TDF 

Some additional irreversible change in vegetative species composition likely due to fugitive dust deposition from road and TDF. 189 acres of vegetation irretrievably impacted by the existing TDF Some areas revegetated through reclamation after closure. Permanent loss of 112 acres of wetlands at the TDF 

Wildlife and Threatened and Endangered Species 

Irreversible commitment of wildlife habitat associated with the TDF (64 acres total). 

Irreversible commitment of additional wildlife habitat associated with the TDF (128 acres). 

Irreversible commitment of additional wildlife habitat associated with the TDF (126 acres). 

Irreversible commitment of additional wildlife habitat associated with the TDFs (174 acres). 
Chapter 3. Affected Environment and Environmental Consequences

3-316 Greens Creek Mine Tailings Disposal 

Table 3.23-1. Irreversible and Irretrievable Resource Commitments. 

Resource Alternative A Alternative B Mitigated Alternative B Alternative C 

Land Use and Recreation 

None. All proposed activities are appropriate within LUDs. 

None. All proposed activities are appropriate within LUDs. 

None. All proposed activities are appropriate within LUDs. 

None. All proposed activities are appropriate within LUDs. 

Scenic Resources No foreseeable or 

predicted irreversible or irretrievable commitments; not previously evaluated. 

Same as Alternative A. Same as Alternative A. Same as Alternative A. 

Subsistence and Cultural Resources 

No foreseeable or predicted irreversible or irretrievable commitments; not previously evaluated. 

Same as Alternative A. Same as Alternative A. Same as Alternative A. 

Socioeconomics Closure of the mine in 

2019 would result in a net loss of $48 million associated direct and indirect payroll. 

Extending the life of the mine 30–50 years would result in a continued direct and indirect payroll of $48 million. 

Same as Alternative B. Same as Alternative B. 

Monument Resources 

Irretrievable commitment of 37 acres within the Monument. 

Irretrievable commitment of an additional 104 acres within the Monument compared to Alternative A. 

Irretrievable commitment of an additional 83 acres within the Monument compared to Alternative A. 

Irretrievable commitment of an additional 18 acres within the Monument compared to Alternative A. 
Chapter 4. List of Preparers 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 4-1 

CHAPTER 4. LIST OF PREPARERS 

Tetra Tech Team 

Preparer Degree/Years of Experience Project Role

Gene Weglinski M.S., Horticulture 

B.S., Botany 

Years of experience: 20 

Project Manager 

Dave Cox B.S. Geology 

Years of experience: 10 

Deputy Project Manager 

Katie Goodwin M.S., Environmental Sciences 

B.S., Natural Resources 

Years of experience: 4 

Project Assistant 

Air Quality 

Susan Bautts M.S., Civil Engineering 

B.S. Environmental Engineering 

Years of experience: 6 

Air Quality 

Mike Henderson, P.E. M.S., Geotechnical and Water Resources 

Engineering 

B.S., Civil Engineering 

Years of experience: 30 

Geotechnical Stability 

Diana Cook, EIT Ph.D, Colorado School of Mines 

M.S., University of Illinois Urbana Champaign 

B.S., New Mexico State University 

Years of experience: 4 

Geotechnical Stability 

Mark Williamson Ph.D., Geochemistry 

M.S., Geochemistry 

B.S., Chemistry 

Years of experience: 25 

Geochemistry 

Tim Reeves M.S., Range Management / Water Resources 

B.S., Range Management 

Years of experience: 25 

Water Resources 

Joe Frank M.S., Geology\Hydrogeology 

B.S., Geology 

Years of experience: 35 

Groundwater Hydrology 

John Knutzen M.S., Fisheries 

B.S., Biology 

Years of experience: 31 

Fisheries 

Henry Sauer B.S., Range Management 

Years of experience: 18 

Soils 

Selina Koler M.S., Restoration Ecology 

B.S., Natural Resource Management 

Years of experience: 8 

Vegetation, Wetlands 

Steve Negri M.S., Wildlife Ecology 

B.S., Business-Finance 

Years of experience: 16 

Wildlife 

Brita Woeck M.S., Wildlife Ecology and Management B.S. 

Wildlife Science 

Years of experience: 9 

Wildlife 

Susan Ernst Corser M.U.P., Urban Planning 

M.A., Landscape Design 

B.A., Geography/Environmental Studies 

Years of experience: 25 

Land Use and Recreation 

Stephen Braund M.A., Anthropology 

B.A., Northern Studies/English 

Years of experience: 33 

Subsistence, Traditional 

Knowledge, and Cultural 

Resources 

Erik Hilsinger M.A., Anthropology 

Years of experience: 16 

Cultural Resources 
Chapter 4. List of Preparers 

4-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Preparer Degree/Years of Experience Project Role 

Paul Lawrence B.A., Anthropology 

Years of experience: 8 

Subsistence, Cultural 

Resources 

Raena Schraer B.A., Geography/Spanish 

Years of experience: 7 

Subsistence, GIS 

Matt Dadswell M.A., Economic Geography, 1990 

B.A., Economics and Geography, 1988 

Years of experience: 16 

Socioeconomics, 

Environmental Justice 

Jennifer Hawkins B.S., Environmental Science and Biology 

Years of experience: 15 

Cumulative Effects 

MaryJo Watson B.S., Business Administration - Computer 

Information Systems 

Years of experience: 20 

GIS Lead 

Sierra Marrs B.S., Environmental Geology 

Years of experience: 5 

GIS 

Juanita Barboa B.S., Technical Communication 

Years of experience: 22 

Formatting and Editing 

Lead Agency Reviewers 

USDA Forest Service 

Sarah Samuelson, Project Manager 

Karen Iwamoto, Land Management Planner 

Steve Paustian, Hydrology 

Cooperating Agency Reviewers 

U.S. Environmental Protection Agency 

Lynne McWhorter, Project Lead/NEPA Compliance 

Cindi Godsey, NPDES Permits and Water Resources 

Lorraine Edmond, Water Resources, Groundwater, Hydrogeology, Geochemistry 

Phil North, Wetlands 

U.S. Army Corps of Engineers 

Heidi Firstencel, Project Lead 

State of Alaska 

Sharmon Stambaugh, Alaska Department of Natural Resources 

Kenwyn George, Alaska Department of Environmental Conservation 

Ed Emsweiler, Alaska Department of Environmental Conservation 

David Wilfong, Alaska Department of Natural Resources 

Kate Kanouse, Alaska Department of Fish and Game 

City and Borough of Juneau 

Teri Camery, Community Development Department 
Chapter 4. List of Preparers 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 4-3 

List of Recipients 

Federal Agencies 

Advisory Council on Historic Preservation 

Animal and Plant Health Inspection Service 

Federal Highway Administration 

National Agricultural Library 

National Marine Fisheries Service 

National Oceanic and Atmospheric Administration 

U.S. Army Corps of Engineers 

U.S. Coast Guard 

U.S. Department of Agriculture, National Resources Conservation Service 

U.S. Department of Energy, NEPA Policy & Compliance 

U.S. Department of the Interior, Office of Environmental Policy and Compliance 

U.S. Environmental Protection Agency 

U.S. Fish and Wildlife Service 

U.S. Forest Service 

State Agencies 

Alaska Department of Environmental Conservation 

Alaska Department of Fish and Game 

Alaska Department of Natural Resources /Mining Land and Water 

State of Alaska Department of Natural Resources, Office of Project Management 

and Permitting 

Individuals 

Art Kolter 

Bride Seifort 

Bruce Abel 

Bruce Baker 

Cade Smith 

Daniel Monteith Ph.D 

David L. Wilmarth 

Dennis J. McLerran 

Deryl Box 

Don Gotschall 

Don Ried 

Dough Schwartz 

Douglas K. Mertz 

Duff W. Mitchell 

Elaine Price 

Eric Twelker 
Chapter 4. List of Preparers 

4-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Ethan Berto 

Fred M. Morino 

Freeman Bell 

Howard Grey 

Hugh Noel Grant 

Irene Alexakos 

Irene M. Gallion 

James F. Clark 

Jason Morford 

Jeannette Pursell 

Jocelyn Webb 

John A. Sandor 

John and Kyle Rust 

John Sisk 

K.J. Metcalf 

Kasen Spickler 

Ken Gerondale 

Louis C. Harris, Jr. 

Lydia Garvey, Public Health Nurse 

Margo Waring 

Michael Hekkers 

Michael Tobin 

Mike Heatwole 

Neil MacKinnon 

Paul Friesema 

Phillip Walker 

Randy Brand 

Rebecca Chester 

Richard Gard 

Rick Fredericksen 

Rod and Kathi Cleland 

Sarah Dunlap and Butch Laughlin 

Scott and Pat Hartman 

Scott and Sandy Spickler 

Shelly Wright, Executive Director 

Shirley F. Kohls, Attorney 

Theresa Williams 

Wayne Browning 

Wes Nason 

William A. Corbus 

William Brent 
Chapter 4. List of Preparers 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 4-5 

Libraries 

Juneau Public Library 

Organizations and Businesses 

Admiralty Environmental 

Alaska Energy and Resources Company 

Alaska Interstate Construction 

Alaska Marine Lines 

Alaska Marine Trucking 

Alaska Miners Association, Inc 

ALPG 

Amerikanuak, Inc 

Arrowhead Transfer 

Borell Consulting Services LLC 

Cementation USA Inc 

Center for Science 

Center for Science in Public Participation 

Clean Production Action 

Coeur d’ Arlene Mines Corporation 

Construction Machinery Industrial 

Council of Alaska Producers 

D.J.G. Development 

Douglas Indian Association 

ESS Support Services Worldwide 

First Things First Alaska Foundation 

Fluetsch Financial Services, LLC 

Friends of Admiralty Island 

Gas ‘n’ Go Petro Express 

Hecla Greens Creek Mining Company 

J.S. Redpath Corporation 

Joel Bennett Productions 

Juneau Economic Development Council 

Kootznoowoo, Inc 

Les Schwab Co 

Lynden Logistics 

Max E. Mertz, CPA, Elgee Rehfeld Mertz, LLC 

NC Machinery 

Operating Engineers Local 302 

Reliable Transfer Corporation 

Resource Development Council 

Sierra Club 
Chapter 4. List of Preparers 

4-6 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Southeast Alaska Conservation Council 

Southeast Stevedoring Corporation 

Tetra Tech, Inc. 

Trout Unlimited: America’s Leading Coldwater Fisheries Conservation 

Organization 

Public Officials, Tribes, and Cities 

Public Officials 

Cathy Munoz, State Representative 

Native Tribal Organizations 

Angoon Community Association 

Cities 

Juneau Chamber of Commerce 
Chapter 5. References

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 5-1 

CHAPTER 5. REFERENCES 

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Functions and Values of Wetlands Associated with some Proposed Hecla 

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ADEC (Alaska Department of Environmental Conservation). 2002. Air Quality 

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ADEC. 2008. Title V Air Quality Operating Permit No. AQ302TVP02. 

ADEC. 2010. Field Inspection Report Hecla Greens Creek Mining Company. April 29, 

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ADEC. 2011. Air Quality Control Minor Permit No. AQ0302MSS01. 

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ADEC, 2009. Water Quality Standards 18 AAC 30. 2009, amended 2011. 

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ADNR (Alaska Department of Natural Resources). 2005. Handbook of Statues & 

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Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6 -1 

CHAPTER 6. GLOSSARY 

100-year flood A stream discharge that occurs on the average of once every 100 

years. 

Acid-base 

accounting 

A test method to predict acid mine drainage. The “static” test 

compares a waste rock’s maximum potential acidity with its 

maximum neutralization potential. 

Acid-generating 

potential 

The long-term potential of a material or waste to generate acid, as 

related to acid mine drainage. 

Acid mine (rock) 

drainage 

Drainage of water from areas that have been mined for mineral ores. 

The water has a low pH because of its contact with sulfur-bearing 

material. Dissolved metals, including heavy metals, might be 

present. Acid mine drainage might be harmful to aquatic organisms 

and to drinking water supplies. 

Acre-foot (ac-ft) The amount of water that covers an acre of land to a depth of 1 foot; 

equal to 325,827 gallons. 

Adaptive 

management 

A systematic process for continually improving management 

policies and practices by learning from the outcomes of operational 

programs (adapted from B.C. Ministry of Forests and Range). 

Adsorb To take up and hold by the physical or chemical forces of 

molecules. 

Airshed An area of land over which the pattern of air movement is 

influenced by major topographic features. 

Alkaline Having the qualities of a base; basic (pH greater than 7.0). 

Alkaline 

chlorination 

A treatment method by chemical reaction used to break down by 

chlorination the toxic cyanide radical (NC) into nontoxic sodium 

bicarbonate, nitrogen, sodium chloride, and water. This method can 

be used to treat mill effluent and tailings. 

Alkalinity A measure of the alkali content of a sample occasionally expressed 

as the number of milliequivalents of hydrogen ion that can be 

neutralized. 

Alluvium Material, including clay, silt, sand, gravel, and mud, deposited by 

flowing water. 

Alternatives For National Environmental Policy Act purposes, alternatives to the 

proposed action examined in an environmental impact statement or 

environmental assessment. The discussion of alternatives must 

“sharply [define] the issues and [provide] a clear basis for 

choice...by the decision maker and the public” (40 CFR 1502.14). 
Chapter 6. Glossary 

6-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Ameliorate To influence or alter conditions so as to cause improvement. 

Anadromous Describes fish that migrate upstream from salt water to fresh water 

to spawn (breed), such as salmon, some trout and char species, and 

shad. Also describes the fishery or habitat used for spawning by 

these species. 

Aquatic Growing, living, frequenting, or taking place in water. In this EIS, 

used to indicate habitat, vegetation, and wildlife in fresh water. 

Aquifer A zone, stratum, or group of strata acting as a hydraulic unit that 

stores or transmits water in sufficient quantities for beneficial use. 

Aspect The direction toward which a slope faces. 

Attainment area A geographic region within which National Ambient Air Quality 

Standards (NAAQS) are met. Three categories of attainment— 

Class I, Class II, and Class III—are defined by the level of 

degradation of air quality which may be permitted. 

Base drain A drain for water at the bottom of an impoundment or a storm 

runoff catchment. 

Base flow A sustained or fair-weather flow of a stream. 

Baseline data Data gathered prior to the Proposed Action to characterize 

predevelopment site conditions. 

Bathymetry The measurement of depths of water in an ocean, lake, or sea. 

Benthic All underwater bottom terrain from the shoreline to the greatest 

deeps. 

Berm An earthen embankment; dike. 

Best available 

control technology 

Pollution control as defined by EPA for a specific emission or 

pollutant stream and required for meeting pollution control 

regulations. 

Bioaccumulation Pertaining to concentration of a compound, usually potentially toxic, 

in the tissues of an organism. 

Bioassay The study of living organisms to measure the effect of a substance, 

factor, or condition by comparing before-and-after exposure or other 

data. 

Biodegradable Capable of being broken down by the action of living organisms 

such as microorganisms. 

Biomass The amount (weight or mass) of living material. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6 -3 

Biomonitoring The use of living organisms to test the suitability of effluents for 

discharge into receiving waters and to test the quality of such waters 

downstream from the discharge. 

Biota All living material in a given area; often refers to vegetation. 

Bond An agreed-to sum of money which, under contract, one party pays 

another party under the condition that when certain obligations or 

acts are met, the money will be returned; an example is mining 

reclamation. See Reclamation guarantee. 

Borough An area incorporated for the purpose of self-government; a 

municipal corporation. 

Borrow area Source area for earthen construction material, such as sand and 

gravel, till, or topsoil used in construction or reclamation; a quarry. 

Cadmium A tin-white, malleable, ductile, toxic, bivalent metallic element used 

in electroplating of iron and steel and in the manufacture of 

Carbon monoxide A colorless, odorless, very toxic gas formed as a product of 

incomplete combustion of carbon. 

Catchment area The drainage area or basin drained by a river, stream, or system of 

streams. 

Change analysis An interdisciplinary review conducted to determine if a proposed 

modification to an action constitutes a substantial change relevant to 

environmental concerns (40 CFR 1502.9(c) (1) (i)) or if there are 

significant new circumstances or information relevant to 

environmental concerns and bearing on the proposed action or its 

impacts (40 CFR 1502.9(c) (1) (ii)). 

Char Fish that is closely related to trout. The char genus (Salvelinus) 

comprises Dolly Varden present in the project area. 

Climax plant 

community 

The stabilized plant community on a particular site. The relative 

composition of species does not change so long as the environment 

remains the same. 

Closure The final stage of mining, which involves closing all mine openings, 

regrading, and reclaiming disturbed areas. 

Colluvial Describes soil material that has moved downhill and has 

accumulated on lower slopes and at the bottom of a hill, consisting 

of alluvium in part and also containing angular fragments of the 

original rocks; i.e., cliff and avalanche debris. 

Concentrate The ore that contains the mineral sought following the concentration 

process (e.g., flotation, gravity). 
Chapter 6. Glossary 

6-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Conductivity 

(electrical) 

An electrical measurement to determine the amount of salinity or 

total dissolved solids in soils, surface water, and groundwater. 

Cone of depression The geometry or shape of an inverted cone on the water table or 

artesian pressure surface caused by pumping of a well. The cone of 

depression disappears over time after well pumping ceases. 

Copper A red, ductile, malleable native metal found in hydrothermal 

deposits, cavities of basic igneous rocks, and zones of oxidization of 

copper veins. 

Council on 

Environmental 

Quality (CEQ) 

A body established by the National Environmental Protection Act 

(NEPA) to draft regulations for implementing and monitoring 

NEPA. CEQ regulations are presented in 40 CFR 1500–1508. 

Cover Living or nonliving material (e.g., vegetation) used by fish and 

wildlife for protection from predators and to ameliorate conditions 

of weather. 

Criteria Standards on which a judgment or decision can be based. Water 

quality criteria can be based on various standards, including aquatic 

life or human health. 

Cubic feet per 

second (cfs) 

One cubic foot per second (cfs) equals 448.33 gallons per mile. 

Cumulative impacts Combined impacts of past, present, and reasonable foreseeably 

future actions. For example, the impacts of a proposed timber sale 

and the development of a mine together result in cumulative 

impacts. 

Demography A statistical study of the characteristics of human populations with 

reference to size, density, growth, distribution, migration, and effect 

on social and economic conditions. 

Depletion Use of water in a manner that makes it no longer available to other 

users in the same system. 

Deposit A natural accumulation, such as precious metals, minerals, coal, gas, 

oil, and dust, that may be pursued for its intrinsic value; gold 

deposit. 

Development The work of driving openings to and into a proven ore body to 

prepare it for mining and transporting the ore. 

Dewatering The reduction of aquatic habitats by diversion of stream flow; 

removal of water from underground mine workings. 

Dilution The act of mixing or thinning and thereby decreasing a certain 

strength or concentration. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6 -5 

Direct impacts Impacts that are caused by the action and occur at the same time and 

place (40 CFR 1508.7). Synonymous with direct effects. 

Discharge The volume of water flowing past a point per unit time, commonly 

expressed as cubic feet per second, million gallons per day, gallons 

per minute, or cubic meters per second. 

Dispersion The act of distributing or separating into lower concentrations or 

less dense units. 

Diversion Removing water from its natural course of location, or controlling 

water in its natural course of location, by means of a ditch, canal, 

flume, reservoir, bypass, pipeline, conduit, well, pump, or other 

structure or device. 

Earthquake Sudden movement of the earth resulting from faulting, volcanism, 

or other mechanisms within the earth. 

Effluent discharge Disposal of water previously used, as in a milling process. 

Endangered species Any species that is in danger of extinction throughout all or a 

significant portion of its range. 

Environmental 

Impact Statement 

(EIS) 

A detailed written statement of the potential environmental effects 

resulting from a action proposed by a federal agency required by 

section 102(2)(c) of the National Environmental Policy Act (40 CFR 

1508.11). 

Ephemeral stream A stream channel that is normally dry; stream flow occurs for short 

periods of time in response to storm events. 

Erosion The wearing away of the land surface by running water, wind, ice, 

or other agents. 

Estuarine Of, relating to, or formed in a place where an ocean tide meets the 

current of a freshwater stream. 

Exploration The search for economic deposits of minerals, ore, gas, oil, or coal 

through the practices of geology, geochemistry, geophysics, drilling, 

shaft sinking, and/or mapping. 

Fault A displacement of rock along a shear surface. 

Fines Fine particulate matter; specifically, particles less than 0.4 mm in 

diameter. 

Fishery All activities related to human harvest of a fisheries resource. 

Flocculation The addition of an agent to a settling pond that causes suspended 

particles to aggregate and settle out more rapidly than they would 

under natural conditions. 
Chapter 6. Glossary 

6-6 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Flotation An ore concentration process that separates ground ore from waste 

in a mixture of ore, water, and chemicals. When air is forced 

through the ore/water mixture, the chemicals cause certain minerals 

to adhere to the air bubbles and float to the top in a froth, thus 

effecting a separation. 

Flotation circuit The portion of the milling process where the flotation process 

occurs. See Flotation. 

Flotation 

concentrate 

The layer of mineral-laden foam built up at the surface of a flotation 

cell. 

Fry A recently hatched fish. 

Fugitive dust Dust particles suspended randomly in the air from road travel, 

excavation, or rock-loading operations. 

Fugitive emissions Emissions not caught by a capture system. 

Geomorphic Pertaining to the form of the surface of the earth. 

Geotechnical Related to branch of engineering that is essentially concerned with 

the engineering design aspects of slope stability, settlement, earth 

pressures, bearing capacity, seepage control, and erosion. 

Geotextile A synthetic fabric used in the construction of earthen structures, 

such as embankments, landfills, and roads. 

Grade The content of precious metals per volume of rock (expressed in 

ounces per ton). 

Gradient The inclination or the rate of regular or graded ascent or descent (as 

of a slope, roadway, or pipeline). 

Gypsum A naturally hydrated calcium sulfate, CaSO4·2H2O, white or 

colorless, sometimes tinted grayish, reddish, yellowish, bluish, or 

brownish. Insoluble in water; soluble in ammonium salts, acids, and 

sodium chlorides. 

Habitat The natural environment of a plant or animal, including all biotic, 

climatic, and soil conditions, or other environmental influences 

affecting living conditions. 

Hardness Quality of water that prevents lathering because of the presence of 

calcium and magnesium salts, which form insoluble soaps. 

Hazardous waste By-products of society that can pose a substantial or potential 

hazard to human health or the environment when improperly 

managed. Possesses at least one of four characteristics (ignitability, 

corrosivity, reactivity, or toxicity) or appears on special EPA lists. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6 -7 

Heavy metals A group of elements, usually acquired by organisms in trace 

amounts, that are often toxic in higher concentrations. Heavy metals 

include copper, lead, mercury, molybdenum, nickel, cobalt, 

chromium, iron, silver, and others. 

Herbaceous Lacking woody tissue; used to describe vegetation. 

Heterogeneous Not uniform in structure or composition. 

Hydraulic barrier An abrupt change in geology or soil type that inhibits the flow of 

water. 

Hydraulic 

conductivity 

A measure of the ability of soil to permit the flow of groundwater 

under a pressure gradient; permeability. 

Hydrogen sulfide A colorless, flammable, poisonous gas. 

Hydrologic system All physical factors, such as precipitation, stream flow, snowmelt, 

and groundwater, that affect the hydrology of a specific area. 

Hydrophytic Pertaining to aquatic plants that require an abundance of water for 

growth. 

Impermeable Having a texture that does not permit the passage of fluids through 

its mass. 

Impoundment The accumulation of any form of water in a reservoir or other 

storage area. 

Incised Cut into. 

Increment The amount of change from an existing concentration or amount, 

such as air pollutant concentrations. 

Indigenous Originating, developing, or produced naturally in a particular land, 

region, or environment; native. 

Indirect impacts Effects that are caused by the action and occur later in time farther 

removed in distance but are still reasonably foreseeable (40 CFR 

1508.8). Synonymous with indirect effects. 

Infauna Aquatic animals living in and on soft bottom substrates. 

Infiltration The movement of water or some other fluid into the soil through 

pores or other openings. 

Jurisdictional 

wetland 

A wetland area delineated or identified by specific technical criteria, 

field indicators, and other information for purposes of public agency 

jurisdiction. The public agencies that administer jurisdictional 

wetlands are the U.S. Fish and Wildlife Service, U.S. Army Corps 

of Engineers, EPA, and the USDA Natural Resources Conservation 

Service. 
Chapter 6. Glossary 

6-8 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Lime Calcium oxide. Sometimes used as an abbreviated name for any 

rock consisting predominantly of calcium carbonate. 

Long-term impacts Impacts that result in permanent changes to the environment. An 

example is a topographic change resulting from tailings disposal in a 

creek drainage. 

Marine discharge Disposal of mine water, treated sewage, and/or stormwater bypass. 

Marine outfall The mouth or outlet of a river, stream, or pipeline where it enters the 

sea. 

Median The value of the middle number of a data set such that half of the 

data values are greater than the median and half of the data values 

are less than the median. 

Microclimate The local climate of a given area or habitat characterized by 

uniformity over the site. 

Migratory Moving from place to place, daily or seasonally. 

Milling The act or process of grinding, extraction, or mineral processing. 

Mine drainage Gravity flow of water from a mine to a point remote from the 

mining operations. 

Mine Safety and 

Health 

Administration 

(MSHA) 

A federal agency under the Department of Labor that regulates 

worker health and safety in mining operations. 

Minimum stream 

flow requirement 

A set amount of water to be maintained in a watercourse for the 

purpose of reasonably maintaining the environment. 

Mining plan See Operating plan.

Mitigation measure A step planned or taken to lessen the effects of an action. 

Mixing zone An area between an effluent discharge point and the associated 

water quality compliance monitoring station. 

Monitoring Continued testing of specific environmental parameters and of 

project waste streams for purposes of comparing with permit 

stipulations, pollution control regulations, mitigation plan goals, and 

so forth. 

National 

Environmental 

Policy Act of 1969 

(NEPA) 

National charter for protection of the environment. It establishes 

policy, sets goals, and provides means for carrying out the policy. 

The regulations for implementing the act are at 40 CFR 1500–1508. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6 -9 

National Pollutant 

Discharge 

Elimination System 

(NPDES) 

A program authorized by sections 318, 402, and 405 of the Clean 

Water Act, and implemented by regulations at 40 CFR 122. The 

NPDES program requires permits for the discharge of pollutants 

from any point source into waters of the United States. 

National Register of 

Historic Places 

(NRHP) 

A list, maintained by the National Park Service, of areas that have 

been designated as being of historical significance. 

NEPA process All measures necessary to comply with the requirements of section 

2 and Title I of NEPA. 

New Source 

Performance 

Standards 

Standards set by EPA defining the allowable pollutant discharge (air 

and water) and applicable pollution control for new facilities by 

industrial category (Clean Air Act and Clean Water Act). 

Nonpoint pollution Pollution caused by sources that are nonstationary. In mining, 

nonpoint air pollution results from such activities as blasting and 

hauling minerals over roads, as well as dust from mineral stockpiles, 

tailings, and waste dumps prior to mulching and/or revegetation. 

Oligotrophic Having a deficiency in plant nutrients that is usually accompanied 

by an abundance of dissolved oxygen. 

Operating plan Plan submitted by the mining operator that outlines the steps the 

mining company will take to mine and reclaim the site. The 

operating plan is submitted prior to starting mining operations. 

Synonymous with the term mining plan (36 CFR 228). 

Ore A naturally occurring solid material from which a metal or valuable 

mineral can be profitably extracted. 

Ore body A natural accumulation of a metal, gemstone or other valuable 

mineral substance, which is rich enough in concentration that it can 

be mined and processed at a profit. 

Ore reserve Mineral deposits which are valuable and legally, economically and 

technically feasible to extract. 

Organic matter Matter composed of once-living organisms (carbon compounds). 

Organism A living individual of any plant or animal species. 

Orographic effects Pertaining to relief factors such as hills, mountains, plateaus, 

valleys, and slopes; usually used to describe weather patterns. 

Outfall A structure (pipeline) extending into a body of water for the purpose 

of discharging a waste stream, storm runoff, or water. 

Oxide A compound of oxygen with one or more elements or radicals. 
Chapter 6. Glossary 

6-10 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Ozone Form of oxygen (O3) found largely in the stratosphere; a product of 

reaction between ultraviolet light and oxygen, or formed during 

combustion of hydrocarbon fuels. 

Palustrine Of, or relating to, shallow ponds, marshes, or swamps. 

Palustrine forested A forested wetland dominated by woody vegetation more than 20 

feet tall. 

Palustrine scrubshrub A wetland area dominated by woody vegetation less than 20 feet 

tall. 

Peak flow Highest flow; can be quantified as daily or instantaneous. 

Permeability The capacity of a material for transmitting a fluid. Degree of 

permeability depends on the size and shape of the pores, their 

interconnections, and the extent of the latter. 

pH Symbol for the negative common logarithm of the hydrogen ion 

concentration (acidity) of a solution. The pH scale runs from 0 to 

14, with a pH of 7 considered neutral. A pH number below 7 

indicates acidity, and a pH value above 7 indicates alkalinity or a 

base. 

Physiography A science that deals with the features and phenomena of nature; 

physical geography. 

Piezometer A device for measuring moderate pressures of liquids. 

Piezometric head The level to which a liquid rises in a piezometer, representing the 

static pressure of a waterbody. 

Piezometric surface Any imaginary surface coinciding with the hydraulic pressure level 

of water in a confined aquifer, or the surface representing the static 

head of groundwater and defined by the level to which water will 

rise in a well. A water table is a particular piezometric surface. 

Plan of Operations See Operating plan.

Plate filter A filter used to remove gold precipitate from solution. 

Podzolization The process by which the upper layer of a soil becomes acidic 

through the leaching of bases to lower horizons. 

Point source Stationary sources of potential pollutants. In terms of mining, some 

examples of point sources are crushing and screening equipment, 

conveyors, and pond outlet pipes. 

Pollution Human-caused or natural alteration of the physical, biological, and 

radiological integrity of water, air, or other aspects of the 

environment producing undesired effects. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6-11 

Polychaete Any of a class of mostly marine, annelid worms, having on most 

segments a pair of fleshy, leg-like appendages bearing numerous 

bristles. 

Portal The entrance to a tunnel or underground mine. 

Potable water Suitable, safe, or prepared for drinking. 

Potentiometric 

surface 

Surface to which water in an aquifer would rise by hydrostatic 

pressure. 

Precipitation The process of removing solid or liquid particles from a gas or 

smoke; the process of forming a precipitate from a solution; rain, 

mist, snow, and the like. 

Prehistoric Relating to the times just preceding the period of recorded history. 

Prevention of 

Significant 

Deterioration (PSD) 

Under the provisions of the federal Clean Air Act, a proposed new 

source of air pollution may be required to apply for a PSD permit if 

certain emission limits are expected to be exceeded. 

Pristine Pertaining to pure, original, uncontaminated conditions. 

Probable maximum 

flood (PMF) 

A flood calculated to be the largest probable under any 

circumstances. 

Probable maximum 

precipitation (PMP) 

The theoretical physical maximum amount of precipitation that 

could occur at a given point or location. 

Process area The area that encompasses the adit, mill, and processing facilities. 

Process water Water required for use within the mill system. 

Project area The area within which all surface disturbance and development 

activity would occur. 

Public scoping An early and open process for determining the scope of issues to be 

addressed and for identifying the significant issues related to a 

proposed action (40 CFR 1501.7). 

Pyrite A common mineral consisting of iron disulfide (FeS2) with a pale 

brass-yellow color and brilliant metallic luster. It is burned to make 

sulfur dioxide and sulfuric acid. 

Pyritic Relating to or resembling pyrite, a common mineral; iron disulfide. 

Receiving waters A river, lake, ocean, stream, or other watercourse into which 

wastewater or treated effluent is discharged. 

Reclamation Returning an area to a productive land use by regrading and 

reseeding areas disturbed during mining activity. 
Chapter 6. Glossary 

6-12 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Record of Decision 

(ROD) 

A document that discloses the decision on an environmental impact 

statement and the reasons why the decision was made; it is signed 

by the official responsible for implementing the identified action. 

The environmental consequences disclosed in an EIS are considered 

by the responsible official in reaching a decision (40 CFR 1505.2). 

Redox A chemical reaction in which one component loses electrons (is 

oxidized) and another gains electrons (is reduced). 

Residence time The amount of time a receptor organism or object is in contact with 

a source. 

Resident A species that is found in a particular habitat for a particular time 

period (e.g., winter, summer, year-round) as opposed to species 

found only when passing through during migration. 

Richter Scale A numerical (logarithmic) measure of earthquake magnitude. 

Riparian A type of ecological community that occurs adjacent to streams and 

rivers. It is characterized by certain types of vegetation, soils, 

hydrology, and fauna that are suited to conditions more moist than 

those normally found in the area. 

Riprap A layer of large rocks placed together to prevent erosion of 

embankments, causeways, or other surfaces. 

Riverine Of or relating to rivers, creeks, and streams. 

Runoff Precipitation that is not retained on the site where it falls and not 

absorbed by the soil; natural drainage away from an area. 

Salinity A measure of the dissolved salts in sea water. 

Salmonids Fish species (salmon, trout, and char) that belong to the same 

family; salmonidae. 

Saturation The extent or degree to which the voids in a material contain oil, 

gas, or water. Usually expressed in percent related to total void pore 

space. 

Section 10 Permit A permit issued under section 10 of the Rivers and Harbors Act of 

1899. Section 10 requires a permit for any structure or work that 

might obstruct traditionally navigable waters. This permit is issued 

by the U.S. Army Corps of Engineers. 

Section 404 Permit A permit issued under Section 404 of the Clean Water Act. Section 

404 specifies that anyone wishing to place dredged or fill materials 

into the waters of the United States and adjacent jurisdictional 

wetlands must apply to the U.S. Army Corps of Engineers for 

approval. 

Sedentary Not migratory; staying in one place; stationary. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6-13 

Sediment Material suspended in liquid or air; also, the same material once it 

has been deposited by water. 

Sediment basin A pond, depression, or other device used to trap and hold sediment. 

Sediment loading The mass of solid erosion products deposited by or carried in water 

or air. 

Sediment pond Structure constructed by excavation or by building an embankment 

whose purpose is to retain water and allow for settlement of fines 

(suspended solids) and reduction in turbidity. 

Seepage The slow movement of gravitational water through the soil. 

Selenium A nonmetallic, toxic element related to sulfur and tellurium; a byproduct of the electrolytic refining of copper. 

Semiautogenous Produced or created without external help or influence. 

Sensitive species A plant or animal listed by a state or federal agency as being of 

environmental concern; includes threatened and endangered species. 

Settling ponds See Sediment pond.

Short-term impacts Impacts occurring during project construction and operation, and 

ceasing upon project closure and reclamation. 

Significant issues Of the issues raised during the scoping process for an environmental 

impact statement, certain issues are determined to be “significant’ 

by the lead public agency. Determining which issues are significant, 

and thus meriting detailed study in the EIS, is the final step of the 

scoping process and varies with each project and each location. 

Significant issues are used to develop alternatives. 

Slurry A watery mixture or suspension of insoluble matter, such as mud or 

lime. 

Sodium hydroxide A common laboratory reagent that is strongly alkaline when in 

solution with water. 

Solid waste Garbage, refuse, or sludge from a waste treatment plant, water 

supply treatment plant, or air pollution control facility and other 

discarded material, including solid, liquid, semi-solid, or contained 

gaseous material resulting from industrial, commercial, mining, and 

agricultural operations and from community activities. 

Spawn To produce or deposit eggs or sperm; the eggs or sperm product 

(fish reproduction). 
Chapter 6. Glossary 

6-14 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Spill Prevention, 

Containment, and 

Countermeasure 

(SPCC) Plan 

A plan that USEPA requires of facilities storing more than a given 

threshold of fuel or hazardous material. It is a contingency plan for 

avoidance of, containment of, and response to hazardous materials 

spills or leaks. 

Stockpiling Storage of soils or rock material. 

Stormwater Overland flow generated as the result of a storm event. 

Strata A tabular mass or thin sheet of earth of one kind formed by natural 

causes usually in a series of layers of varying makeup; sedimentary 

units. 

Stream channel 

geometry 

The cross section of a stream channel (end view). 

Stream flow The discharge (flow of water) in a natural channel. 

Stream gradient The rate of fall or loss of elevation over the physical length of a 

segment or total stream usually expressed in feet change per feet in 

distance (%). 

Study area The zone around the project area within which most potential direct 

and indirect effects on a specific resource would occur. 

Subaqueous Living, formed, or found under water. 

Subsidence A local lowering of land surface caused by the collapse of rock and 

soil into an underground void or by the removal of groundwater; it 

can result in stability failures such as landslides and mine roof caveins. 

Subsistence use Section 803 of the Alaska National Interest Lands Conservation Act 

defines subsistence use as follows: “The customary and traditional 

uses by rural Alaska residents of wild, renewable resources for 

direct personal or family consumption as food, shelter, fuel, 

clothing, tools, or transportation; for the making and selling of 

handicraft articles out of the non-edible by-products of fish and 

wildlife resources taken for personal or family consumption; for 

barter, or sharing for personal or family consumption; and for 

customary trade.” 

Substrate An underlayer of earth or rock. 

Succession Changes in the plant communities composing an ecosystem as the 

ecosystem evolves from one type to another; e.g., wetland becoming 

grassy meadows. 

Sulfide A compound of sulfur with more than one element. Except for the 

sulfides of the alkali metals, the metallic sulfides are usually 

insoluble in water and occur in many cases as minerals. 
Chapter 6. Glossary 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 6-15 

Sump In the case of an underground mine, an excavation made 

underground to collect water, from which water is pumped to the 

surface or to another sump nearer the surface. 

Surficial Characteristic of, relating to, formed on, situated at, or occurring on 

the earth’s surface; especially, consisting of unconsolidated residual, 

alluvial, or glacial deposits lying on the bedrock. 

Synchronous Recurring or operating at exactly the same periods. 

Tailings The noneconomic constituents of the ground ore material that 

remain after the valuable minerals have been removed from raw 

materials. 

Taxa (taxon) Any group of organisms, populations, or the like considered to be 

sufficiently distinct from other such groups to be treated as a 

separate unit. 

Terrestrial Of or relating to the earth, soil, or land; an inhabitant of the earth or 

land. 

Thermistor A resistor made of semiconductors having resistance that varies 

rapidly and predictably with temperature. 

Threatened species A plant or wildlife species that is officially designated by the U.S. 

Fish and Wildlife Service as having its existence threatened and is 

protected by the federal Threatened and Endangered Species Act. 

Tideland Land that is overflowed by the tide but exposed during times of low 

water. 

Topography The physical configuration of a land surface. 

Toxicity tests Laboratory analyses generally used to determine the degree of 

danger posed by a substance to animal or plant life. 

Trace metals Metals present in minor amounts in the earth’s crust (trace 

elements). 

Transmissivity 

(coefficient of) 

A measure of the ability of an aquifer to transmit water. 

Turbidity Reduced water clarity resulting from the presence of suspended 

matter. 

Understory A foliage layer lying beneath and shaded by the main canopy of a 

forest. 

Visual resources The visual quality of the landscape. The Forest Service manages 

viewsheds as a resource, establishing specific management 

objectives for different areas of Forest Service land. 
Chapter 6. Glossary 

6-16 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

Waste rock Also known as development rock or production rock, waste rock is 

the non-ore rock extracted to gain access into the ore zone. It 

contains no metal values economic to recover. 

Water balance A measure of continuity of water flow in a fixed or open system. 

Watershed The entire land area that contributes water to a particular drainage 

system or stream. 

Waters of the 

United States 

All waters that are currently or could have been used in interstate or 

foreign commerce, including waters that are subject to the ebb and 

flow of the tide; wetlands; and lakes, rivers, streams, mudflats, 

sandflats, sloughs, prairie potholes, wet meadows, playa lakes, or 

natural ponds. 

Weathering The process whereby larger particles of soils and rock are reduced to 

finer particles by wind, water, temperature changes, plant and 

bacteria action, and chemical reaction. 

Wetlands Those areas that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient to support, and 

that under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil conditions. 

Wilderness Land designated by Congress as a component of the National 

Wilderness Preservation System. 

Xanthates A class of chemicals known as “collector” chemicals that attach to 

floating minerals, making them normally capable of adhering to the 

froth in a flotation circuit. 
Chapter 7. Index 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 7-1 

CHAPTER 7. INDEX 

A 

adaptive management, 1-3, 1-34, 1-35, 

1-44, 3-12, 3-146, 3-276, 3-302 

Admiralty Island National Monument, 

1-1, 1-3, 1-14, 1-17, 2-1, 2-2, 2-3, 3-3, 

3-17, 3-134, 3-193, 3-269, 3-281 

air quality, 1-24, 1-26, 3-3, 3-4, 3-6, 3-8, 

3-9, 3-18, 3-20, 3-22, 3-155, 3-166, 3-

303, 3-314 

Angoon, 1-1, 1-10, 1-11, 1-12, 1-14, 

1-15, 2-1, 2-52, 3-3, 3-228, 3-229, 3-

230, 3-235, 3-236, 3-237, 3-238, 3-239, 

3-244, 3-248, 3-250, 3-252, 3-256, 

3-257, 3-258, 3-259, 3-260, 3-261, 

3-262, 3-263, 3-265, 3-271, 3-290, 

3-291, 3-292, 3-293, 3-297, 3-298, 

3-299, 3-300, 3-301, 3-303, 3-304, 

3-305, 3-306, 3-307, 3-308, 3-309, 

3-310, 3-311, 3-313 

aquatic resources (freshwater), 3-84, 

3-103, 3-109, 3-112, 3-304 

aquatic resources (marine), 3-84, 3-88, 

3-305 

B 

benthic organisms, 3-89, 3-101, 3-155 

C 

climate, 3-5, 3-12, 3-25, 3-39, 3-117, 

3-144, 3-159, 3-201, 3-249, 3-296, 

3-301, 3-302 

co-disposal, 1-3, 1-6, 1-8, 2-21, 2-22, 

2-23, 3-29 

cultural resources, 2-38, 2-52, 3-3, 

3-212, 3-248, 3-249, 3-252, 3-253, 

3-254, 3-255, 3-256, 3-268, 3-275, 

3-279, 3-296, 3-297, 3-311, 3-313, 3-316 

cumulative effects, 3-1, 3-293, 3-294, 

3-295, 3-297, 3-298, 3-299, 3-301, 

3-303, 3-304, 3-305, 3-306, 3-307, 

3-309, 3-310, 3-311, 3-312, 3-313 

D 

dry stack, 1-7, 3-25 

E 

employment, 1-6, 2-52, 3-235, 3-257, 

3-258, 3-259, 3-260, 3-265, 3-266, 

3-267, 3-292 

F 

fish (anadromous), 1-14, 1-18, 1-19, 

1-27, 2-10, 2-32, 3-82, 3-84, 3-85, 3-86, 

3-87, 3-88, 3-92, 3-103, 3-105, 3-108, 

3-109, 3-110, 3-111, 3-112, 3-117, 

3-118, 3-123, 3-124, 3-125, 3-131, 

3-132, 3-133, 3-167, 3-170, 3-174, 

3-178, 3-182, 3-268, 3-271 

fish (freshwater), 3-102, 3-105, 3-247 

fish (marine), 1-17, 1-25, 3-96, 3-101, 

3-112, 3-237 

fugitive dust, 1-15, 2-25, 2-28, 2-35, 

2-40, 3-3, 3-6, 3-7, 3-8, 3-9, 3-12, 3-13, 

3-14, 3-15, 3-17, 3-21, 3-54, 3-55, 3-65, 

3-68, 3-69, 3-80, 3-81, 3-83, 3-155, 

3-165, 3-167, 3-185, 3-209, 3-244, 

3-303, 3-315 

G 

geochemistry, 2-36, 2-40, 2-48, 3-3, 

3-24, 3-27, 3-28, 3-35, 3-38, 3-56, 

3-296, 3-297, 3-303, 3-314 

geotechnical stability, 1-6, 2-28, 2-32, 

2-36, 2-40, 2-48, 3-3, 3-22, 3-23, 3-24, 

3-27, 3-81, 3-136, 3-272, 3-296, 3-297, 

3-303 
Chapter 7. Index 

7-2 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

government-to-government consultation, 

1-7, 1-11, 1-22, 3-235, 3-290, 3-293 

groundwater, 1-12, 1-13, 1-14, 1-26, 

2-22, 2-31, 2-37, 2-41, 2-42, 2-44, 2-47, 

3-23, 3-27, 3-36, 3-45, 3-50, 3-51, 3-57, 

3-61, 3-62, 3-64, 3-65, 3-66, 3-68, 3-69, 

3-70, 3-71, 3-72, 3-73, 3-74, 3-75, 3-76, 

3-77, 3-78, 3-79, 3-80, 3-81, 3-82, 3-83, 

3-105, 3-106, 3-108, 3-109, 3-113, 

3-114, 3-131, 3-279, 3-304, 3-314 

H 

Hoonah, 1-11, 1-12, 2-1, 3-3, 3-228, 

3-230, 3-236, 3-237, 3-240, 3-241, 3-

243, 3-244, 3-248, 3-250, 3-257, 3-258, 

3-259, 3-260, 3-261, 3-262, 3-263, 

3-271, 3-291, 3-292, 3-293, 3-297, 

3-311, 3-313 

I 

irretrievable and irreversible 

commitment of resources, 3-313 

L 

land use, 1-17, 1-18, 1-27, 2-27, 2-28, 

2-50, 3-3, 3-117, 3-143, 3-158, 3-210, 

3-211, 3-212, 3-215, 3-218, 3-226, 

3-248, 3-267, 3-273, 3-296, 3-297, 

3-309, 3-316 

M 

mitigation, 1-9, 1-12, 1-13, 1-15, 1-18, 

1-19, 1-22, 1-23, 1-24, 2-1, 2-8, 2-9, 

2-20, 2-27, 2-34, 2-35, 2-36, 2-37, 2-38, 

2-39, 2-42, 2-44, 3-7, 3-12, 3-22, 3-26, 

3-35, 3-38, 3-45, 3-50, 3-79, 3-103, 

3-104, 3-108, 3-110, 3-112, 3-113, 

3-121, 3-124, 3-133, 3-137, 3-139, 

3-145, 3-146, 3-165, 3-166, 3-172, 

3-182, 3-203, 3-206, 3-209, 3-224, 

3-225, 3-244, 3-256, 3-268, 3-276, 

3-303, 3-307, 3-308 

monitoring, 1-8, 1-9, 1-13, 1-15, 1-26, 

2-1, 2-29, 2-34, 2-35, 2-38, 2-39, 2-40, 

2-41, 2-42, 2-43, 2-44, 2-45, 3-3, 3-6, 

3-8, 3-12, 3-14, 3-22, 3-26, 3-36, 3-38, 

3-44, 3-47, 3-48, 3-49, 3-50, 3-52, 3-54, 

3-55, 3-56, 3-64, 3-65, 3-66, 3-69, 3-76, 

3-78, 3-80, 3-81, 3-83, 3-86, 3-90, 3-91, 

3-92, 3-93, 3-95, 3-98, 3-100, 3-101, 

3-103, 3-104, 3-106, 3-107, 3-109, 

3-111, 3-112, 3-113, 3-144, 3-146, 

3-155, 3-156, 3-166, 3-204, 3-273, 

3-276, 3-301, 3-302 

monument resources, 1-14, 2-27, 2-32, 

2-34, 2-52, 3-3, 3-151, 3-267, 3-268, 

3-269, 3-272, 3-275, 3-278, 3-279, 

3-296, 3-297, 3-298, 3-311, 3-312, 3-316 

P 

payroll, 3-258, 3-259, 3-260, 3-265, 

3-266, 3-292, 3-293, 3-316 

periphyton, 1-13, 2-41, 3-91, 3-92, 

3-102, 3-104, 3-106 

population, 2-32, 3-1, 3-93, 3-94, 3-149, 

3-156, 3-157, 3-160, 3-161, 3-171, 

3-173, 3-175, 3-177, 3-179, 3-181, 

3-182, 3-184, 3-186, 3-188, 3-189, 

3-190, 3-191, 3-192, 3-199, 3-200, 

3-201, 3-205, 3-206, 3-237, 3-240, 

3-244, 3-250, 3-257, 3-258, 3-260, 

3-261, 3-262, 3-265, 3-266, 3-267, 

3-269, 3-283, 3-289, 3-290, 3-291, 

3-309, 3-311 

proposed action, 1-1, 1-7, 1-8, 1-10, 

1-12, 1-21, 1-23, 1-25, 2-1, 2-2, 2-3, 2-6, 

2-8, 2-10, 2-11, 2-15, 2-19, 2-25, 2-26, 

2-33, 2-34, 3-1, 3-8, 3-15, 3-20, 3-26, 

3-27, 3-62, 3-64, 3-68, 3-81, 3-83, 

3-103, 3-106, 3-110, 3-123, 3-131, 

3-135, 3-138, 3-139, 3-146, 3-147, 

3-169, 3-174, 3-181, 3-206, 3-208, 

3-213, 3-214, 3-224, 3-225, 3-226, 

3-232, 3-233, 3-247, 3-248, 3-254, 

3-255, 3-266, 3-267, 3-269, 3-277, 

3-278, 3-289, 3-290, 3-293, 3-294, 

3-296, 3-298, 3-301, 3-303, 3-304, 

3-305, 3-306, 3-307, 3-308, 3-309, 

3-310, 3-311, 3-312, 3-313 

purpose and need, 2-3, 2-20 
Chapter 7. Index 

Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 7-3 

R 

recreation, 1-17, 1-18, 1-22, 2-10, 2-15, 

2-51, 3-3, 3-44, 3-151, 3-156, 3-158, 

3-210, 3-212, 3-214, 3-215, 3-218, 3-

219, 3-221, 3-228, 3-229, 3-231, 3-232, 

3-233, 3-234, 3-268, 3-269, 3-270, 

3-271, 3-273, 3-279, 3-282, 3-283, 

3-284, 3-296, 3-297, 3-298, 3-310, 3-316 

roadless areas, 3-210, 3-278, 3-279, 

3-280, 3-281, 3-282, 3-283, 3-284, 

3-285, 3-286, 3-287, 3-288, 3-289, 

3-296, 3-297, 3-298, 3-299, 3-312 

rock quarries, 2-4, 2-6, 2-8, 2-11, 2-24, 

2-25, 3-50, 3-206, 3-300 

S 

scenic resources, 2-51, 3-3, 3-215, 

3-219, 3-228, 3-232, 3-269, 3-274, 

3-279, 3-294, 3-296, 3-297, 3-310, 3-316 

school enrollment, 3-257, 3-262, 3-265 

scoping, 1-7, 1-9, 1-10, 1-11, 1-12, 1-13, 

1-14, 1-15, 1-21, 2-2, 2-32, 3-3, 3-39, 

3-113, 3-140, 3-228, 3-234, 3-248, 

3-257, 3-267, 3-289, 3-290, 3-291, 

3-293, 3-294, 3-299 

sensitive species, 2-50, 3-92, 3-148, 

3-162, 3-164, 3-186, 3-187, 3-188, 

3-189, 3-190, 3-191, 3-192, 3-193, 

3-194, 3-195, 3-196, 3-197, 3-198, 

3-201, 3-203, 3-208, 3-279, 3-281, 

3-283, 3-308 

significant issues, 1-7, 1-10, 1-12, 2-2, 

2-3, 2-8, 2-32, 3-22, 3-123 

socioeconomics, 3-3, 3-257, 3-258, 

3-264, 3-267, 3-291, 3-296, 3-297, 

3-299, 3-311, 3-316 

soils, 2-37, 2-38, 2-42, 2-48, 3-3, 3-15, 

3-23, 3-54, 3-61, 3-114, 3-124, 3-133, 

3-134, 3-135, 3-136, 3-139, 3-144, 3-

145, 3-216, 3-276, 3-279, 3-296, 3-297, 

3-302, 3-306, 3-315 

subsistence, 1-11, 1-20, 2-38, 2-52, 3-3, 

3-90, 3-97, 3-151, 3-158, 3-201, 3-212, 

3-215, 3-228, 3-231, 3-234, 3-235, 

3-236, 3-237, 3-238, 3-240, 3-241, 

3-244, 3-245, 3-247, 3-248, 3-250, 

3-252, 3-258, 3-269, 3-270, 3-271, 

3-273, 3-275, 3-276, 3-279, 3-282, 

3-284, 3-292, 3-293, 3-296, 3-297, 

3-310, 3-316 

Sulfate Reduction Monitoring Program, 

3-31, 3-33 

surface water, 1-12, 1-13, 1-14, 1-15, 

2-6, 2-10, 2-15, 2-22, 2-24, 2-27, 2-29, 

2-31, 2-36, 2-37, 2-40, 2-41, 2-42, 2-44, 

2-46, 2-47, 3-39, 3-42, 3-43, 3-44, 3-45, 

3-47, 3-48, 3-49, 3-50, 3-54, 3-56, 3-57, 

3-61, 3-65, 3-66, 3-68, 3-69, 3-71, 3-78, 

3-80, 3-83, 3-84, 3-96, 3-106, 3-113, 

3-131, 3-165, 3-203, 3-206, 3-209, 

3-244, 3-273, 3-279, 3-304, 3-314 

T 

Tailings Disposal Facility, 1-1, 1-8, 1-9, 

1-10, 1-17, 2-1, 3-1, 3-227, 3-281 

tailings, 1-1, 1-3, 1-5, 1-6, 1-7, 1-8, 1-9, 

1-10, 1-12, 1-13, 1-14, 1-17, 1-26, 2-1, 

2-2, 2-3, 2-4, 2-6, 2-8, 2-10, 2-11, 2-15, 

2-19, 2-20, 2-21, 2-22, 2-23, 2-25, 2-26, 

2-27, 2-28, 2-29, 2-30, 2-31, 2-32, 2-33, 

2-34, 2-35, 2-36, 2-37, 2-40, 2-42, 3-1, 

3-7, 3-9, 3-14, 3-17, 3-23, 3-24, 3-25, 

3-26, 3-27, 3-28, 3-29, 3-30, 3-31, 3-32, 

3-33, 3-34, 3-35, 3-36, 3-38, 3-39, 3-40, 

3-44, 3-45, 3-50, 3-51, 3-55, 3-56, 3-57, 

3-58, 3-59, 3-60, 3-61, 3-62, 3-64, 3-65, 

3-66, 3-68, 3-69, 3-70, 3-72, 3-74, 3-75, 

3-76, 3-78, 3-80, 3-81, 3-82, 3-83, 

3-102, 3-103, 3-108, 3-109, 3-110, 

3-111, 3-112, 3-123, 3-124, 3-125, 

3-136, 3-137, 3-138, 3-139, 3-140, 

3-144, 3-145, 3-146, 3-147, 3-153, 

3-160, 3-171, 3-172, 3-173, 3-175, 

3-176, 3-177, 3-179, 3-181, 3-182, 

3-194, 3-207, 3-210, 3-213, 3-214, 

3-215, 3-216, 3-221, 3-224, 3-225, 

3-226, 3-227, 3-228, 3-232, 3-233, 
Chapter 7. Index 

7-4 Greens Creek Mine Tailings Disposal Facility Expansion Final EIS 

3-234, 3-247, 3-253, 3-254, 3-255, 

3-266, 3-272, 3-273, 3-274, 3-275, 

3-276, 3-277, 3-278, 3-281, 3-288, 

3-295, 3-303, 3-305, 3-309, 3-314 

taxes, 3-264, 3-266 

Tenakee Springs, 2-1, 3-236, 3-237, 

3-244, 3-245, 3-246, 3-271 

threatened and endangered species, 1-25, 

3-3, 3-186, 3-187, 3-194, 3-195, 3-196, 

3-197, 3-198, 3-203, 3-209, 3-281, 

3-283, 3-296, 3-297, 3-298, 3-299, 

3-309, 3-315 

V 

vegetation, 2-30, 2-31, 2-35, 2-37, 2-38, 

2-42, 2-48, 3-3, 3-7, 3-15, 3-43, 3-54, 

3-61, 3-113, 3-114, 3-116, 3-124, 3-133, 

3-134, 3-135, 3-137, 3-139, 3-140, 

3-141, 3-142, 3-143, 3-144, 3-145, 

3-146, 3-147, 3-151, 3-152, 3-154, 

3-156, 3-165, 3-166, 3-167, 3-170, 

3-173, 3-175, 3-177, 3-179, 3-182, 

3-193, 3-194, 3-202, 3-206, 3-212, 

3-216, 3-218, 3-221, 3-224, 3-226, 

3-232, 3-237, 3-270, 3-273, 3-274, 

3-279, 3-294, 3-296, 3-297, 3-306, 3-315 

W 

waste rock, 1-3, 1-6, 1-7, 1-8, 1-9, 1-12, 

1-14, 1-26, 2-1, 2-2, 2-3, 2-4, 2-6, 2-10, 

2-15, 2-20, 2-21, 2-22, 2-23, 2-25, 2-26, 

2-28, 2-29, 2-30, 2-31, 2-35, 2-36, 3-17, 

3-26, 3-29, 3-32, 3-34, 3-45, 3-50, 3-64, 

3-82, 3-91, 3-108, 3-124, 3-136, 3-138, 

3-147, 3-173, 3-207, 3-214, 3-225, 

3-233, 3-247, 3-254, 3-255, 3-266, 

3-272, 3-277, 3-295, 3-303, 3-314 

water quality, 1-12, 1-13, 1-14, 1-15, 

1-19, 1-21, 1-26, 2-2, 2-21, 2-24, 2-25, 

2-26, 2-27, 2-28, 2-31, 2-34, 2-35, 2-36, 

2-37, 2-39, 2-44, 3-27, 3-28, 3-29, 3-33, 

3-34, 3-35, 3-36, 3-38, 3-39, 3-44, 3-45, 

3-46, 3-50, 3-52, 3-54, 3-55, 3-56, 3-57, 

3-58, 3-59, 3-60, 3-61, 3-62, 3-64, 3-65, 

3-66, 3-68, 3-69, 3-72, 3-73, 3-74, 3-77, 

3-78, 3-79, 3-80, 3-82, 3-83, 3-84, 3-85, 

3-91, 3-92, 3-96, 3-98, 3-102, 3-103, 

3-112, 3-113, 3-143, 3-155, 3-157, 

3-158, 3-162, 3-167, 3-168, 3-169, 

3-170, 3-171, 3-172, 3-174, 3-175, 

3-176, 3-180, 3-183, 3-185, 3-204, 

3-205, 3-206, 3-209, 3-273, 3-294, 

3-304, 3-305, 3-308 

wetlands, 1-13, 1-14, 1-17, 1-22, 1-23, 

1-27, 2-2, 2-8, 2-20, 2-31, 2-32, 2-33, 

2-38, 2-48, 3-3, 3-39, 3-43, 3-62, 3-64, 

3-66, 3-68, 3-82, 3-84, 3-106, 3-108, 

3-113, 3-114, 3-115, 3-116, 3-117, 

3-118, 3-121, 3-122, 3-123, 3-124, 

3-125, 3-128, 3-131, 3-132, 3-133, 

3-140, 3-141, 3-143, 3-147, 3-149, 

3-151, 3-152, 3-160, 3-187, 3-193, 

3-213, 3-221, 3-270, 3-279, 3-296, 

3-297, 3-305, 3-307, 3-315 

wilderness, 1-1, 1-14, 1-15, 1-16, 1017, 

1-18, 3-210, 3-215, 3-219, 3-221, 3-224, 

3-228, 3-231, 3-232, 3-234, 3-267, 

3-268, 3-269, 3-271, 3-273, 3-274, 

3-278, 3-279, 3-281, 3-282, 3-300, 3-306