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Re: Approval letter for the Butte Priority Soils Operable Unit (BPSOU) Revised Draft Final 2022 Insufficiently Reclaimed Sites Sampling: BRES No. 37 – Josephine Shaft Site Evaluation Summary Report (dated October 16, 2025)
Re: Comment Letter for Draft Blacktail Creek Groundwater Hydraulic Control System Preliminary 30% Remedial Design Report (dated October 28, 2024)
Exhibit 2 “Basement ISWP” 122 W. Daly St. Butte, MT 59701 January 16, 2025 Database Residential Identifier: R-00845
Exhibit 2 “Basement ISWP” 1232 E. Second St. Butte, MT 59701 January 21, 2025 Database Residential Identifier: R-04389
Re: Butte Mine Flooding Operable Unit Berkeley Pit and Discharge Pilot Project – December 2024 Monthly Discharge Monitoring Report
2025 Final Butte Reduction Works (BRW) Smelter Area Mine Waste Remediation and Contaminated Groundwater Hydraulic Control Site Quality Assurance Project Plan (QAPP) for Microbial Analysis and Biotreatability Study
Draft Final Butte Priority Soils Operable Unit (BPSOU) Unreclaimed (UR) Sites New and Mahoney (UR-23) Construction Completion Report (CCR)
A PROPOSED METALS RECOVERY ASSESSMENT PROTOCOL TO EVALUATE MINE WASTE FOR CRITICAL MINERALS AND RARE EARTH RECOVERY PRIOR TO SITE REMEDIATION
The Metals Recovery Assessment (MRA) protocol involves collecting and evaluating information to assess the possibility for recovery of critical or rare earth minerals at mine sites to offset remediation or redevelopment costs associated with land reuse at Superfund or closed mine sites. This protocol provides a tool to implement metals recovery in conjunction with property reuse, and may involve a review of available records, visual inspections of the site, sample collection and discussions with local government officials and community members. The selection for metals recovery would be intended to both achieve metals reduction which may be required for the protection of human health and the environment, and to potentially offset costs of site remediation or reuse. Critical minerals are essential to our daily lives and are key to modern-day technology. Mineral commodities that have important uses and no viable substitutes, yet face potential disruption in supply, are defined as critical to the Nation’s economic and national security. They are vital for a wide range of industries, including aerospace, health care, and defense. They are also vital to the manufacture of clean energy technologies that provide affordable, reliable energy without producing harmful emissions. With the advance of technology and industrial future, the need for critical minerals will only increase. Reprocessing mine waste can be economical for local supply of minerals for economic sustainability and to reduce risk to human and environmental health. This paper will focus on a form of continental water called Acid Rock Drainage (ARD), solid rock tailings and coal tailings to study the idea for recovery metals. The goal of this study is to develop an MRA protocol to provide technical expertise and guidance for developers, landowners, and agencies to evaluate the technical and economic feasibility of remining and extracting critical minerals and Rare Earth Elements (REEs) from mine wastes. We will focus on available data from the Berkeley Pit drainage in Butte and the data from an abandoned mine called the Empire Millsite in Marysville as validation case studies. It is anticipated that implementation of this protocol will produce data for informed decision making; advance reuse, remediation, and recovery innovation; promote opportunity for site revenue and reduced long-term liability and costs; and provide common process for the identification and recovery of critical minerals from mine waste at legacy mining and mineral processing sites. The findings from this review based on the proposed MRA protocol and future research recommendations have defined the Berkeley Pit as a potential site for reprocessing activities and the Empire Millsite as not a potential candidate
THE EFFECTS OF FLOOD IRRIGATION VS. PIVOT IRRIGATION ON GROUNDWATER RECHARGE
Groundwater can be an important resource for river flow support, and this is especially true with the Big Hole River in southwestern Montana which is mainly fed by groundwater late in the summer season. Maintaining the source of groundwater is an important focus both for the Big Hole River Watershed Committee as well as local ranchers. Agriculture uses large quantities of water, and as technology advances many ranchers are turning to the use of pivot lines for irrigation. Historically, flood irrigation was used when surface water was available. Surface water sources include tributary streams as well as diversions from the main channel of a river. Flood irrigation is considered less efficient when compared to pivot line irrigation as a fraction of the applied water is ‘lost’ as infiltration to groundwater. The Melrose Valley primarily utilized flood irrigation methods until pivot line irrigation was introduced. Slowly, the valley farmers and ranchers have transitioned to pivot line. In this study three lysimeters were installed, one in a pivot line irrigated field sowing alfalfa, one in a flood irrigation field sowing grass hay, and the third in an area with no crop or irrigation. The purpose was to quantify how much water from each method passed through the root and vadose zone of the soil profile to potentially become groundwater recharge. Each field site was studied through one growing season. A model for each was made utilizing the program HYDRUS. The models were used to gain an understanding of how surface water may be moving through the soil profile for both fields. Only the flood irrigated field showed any flux, or positive groundwater recharge. Total flux after the active irrigation period reached 62,000 cubic centimeters. Total recharge calculated for the flood field was 28.8 million liters. The pivot irrigated field showed no flux, and so there were no model results to show. The results are an important part of understanding what role irrigation plays in groundwater recharge as well as how surface water travels through the soil profile to become recharge