United States
         Environmental Protection
         Agency
Office of Solid Waste
and Emergency Response
Washington DC 20460
EPA/530-SW-85-033
December 1985
                                                        C.
         Solid Waste
           Report To Congress
Wastes from the Extraction and Beneficiation
of Metallic Ores, Phosphate Rock, Asbestos,
      Overburden from Uranium Mining,
                 and Oil Shale

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                                          EPA/530-SW-85-033
          Report To  Congress
Wastes from the Extraction and Beneficiation
of Metallic Ores, Phosphate Rock, Asbestos,
      Overburden from  Uranium Mining,
                and Oil Shale
             December 31,  1985
     U.S.  Environmental Protection Agency
             Office of Solid Waste

                        U.S. Environmental Protection Agency
                        Region 5.Library (PL-12J)
                        77 West Jackson Boulevard, 12tn Hoor
                        Chicago, IL 60504-3590

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON. D.C.' 20460

                           DEC 3 11985
                                              THE ADMINISTRATOR
Honorable George Bush
President of the Senate
Washington, D.C.  20510

Dear Mr. President:

     I am pleased to transmit the Report to Congress on "Wastes
from the Extraction and Beneficiation of Metallic Ores, Phosphate
Rock, Asbestos, Overburden from Uranium Mining, and Oil Shale"
presenting the results of studies carried out pursuant to Sections
8002 (f) and (p) of the Resource Conservation and Recovery Act of
1976, as amended, (42 U.S.C. SS6982 (f) and (p)).

     The Report provides a comprehensive assessment of possible
adverse effects on human health and the environment from the
disposal and utilization of solid waste from the extraction and
beneficiation of ores and minerals.  All metal, phosphate, and
asbestos mining segments of the United States mining industry
are included in the assessment.  Waste categories covered include
mine waste, mill tailings, and waste from heap and dump leaching
operations.

     The Report and appendices are transmitted in one volume.

                                   Sincerely yours,
                                   Lee M. Thomas

Enclosures

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
.f4t  ^.                   WASHINGTON. D.C. 20460

                           DEC 3 11985


                                              THE ADMINISTRATOR


 Honorable  Thomas  P.  O'Neill
 Speaker  of the House of Representatives
 Washington,   D.C.   20515

 Dear Mr. Speaker:

      I am  pleased to transmit  the  Report to Congress on "Wastes
 from the Extraction and Beneficiation of Metallic  Ores, Phosphate
 Rock, Asbestos, Overburden from Uranium  Mining, and Oil Shale"
 presenting the results of studies  carried out pursuant to Sections
 8002 (f) and (p)  of the Resource Conservation and  Recovery Act of
 1976, as amended,  (42 U.S.C.  SS6982  (f)  and (p)).

      The Report provides a comprehensive assessment of possible
 adverse  effects on human health and  the  environment from the
 disposal and utilization of  solid  waste  from the  extraction and
 beneficiation of  ores and minerals.   All metal, phosphate, and
 asbestos mining segments of  the United States mining industry
 are  included in the assessment. Waste categories covered include
 mine waste,  mill  tailings, and waste from heap and dump leaching
 operations.

      The Report and appendices are transmitted in one volume.

                                   .^Sincerely yours,
                                    Lee M. Thomas

 Enclosures

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                               TABLE OF CONTENTS


                                                                     Page

EXECUTIVE SUMMARY                                                   ES-1

SECTION!.    INTRODUCTION                                           1-1

1.1 Scope                                                            1-8
1.2 Contents                                                         1-10

SECTION 2.    OVERVIEW OF THE N ON FUEL MINING
              INDUSTRY                                               2-1

2.1 Nonfuel Mining Segments                                          2-1
2.2 Geographic Distribution                                          2-6
2.3 Mining and Beneflelation Wastes                                  2-10
2.4 Waste Quantities                                                 2-18
2.5 Summary                                                          2-23

SECTION 3.    MANAGEMENT PRACTICES FOR MINING WASTES                 3-1

3.1 Overview of the Mining Waste Management Process                  3-1
3.2 Waste Management Practices                                       3-5
3.3 Waste Siting and Disposal Methods                                3-13
3.4 Mitigative Measures for Land Disposal Sites                      3-20
3.5 Summary                                                          3-52

SECTION 4.    POTENTIAL DANGER TO HUMAN HEALTH AND THE
              ENVIRONMENT                                            4-1

4.1 Waste Characteristics Considered                                 4-2
4.2 Estimated Amounts of Potentially Hazardous Mining Waste          4-42
4.3 Effectiveness of Waste Containment at Mining Waste Sites         4-50
4.4 Structural Instability of Impoundments                           4-61
4.5 Damage Cases                                                     4-63
4.6 Risk Analysis                                                    4-68
4.7 Summary                                                          4-71

SECTION 5.    THE ECONOMIC COST OF POTENTIAL                         5-1
              HAZARDOUS WASTE MANAGEMENT

5.1 Cost Methodology                                                 5-2
5.2 Potential Costs of RCRA Subtitle C Waste Management              5-14

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                             CONTENTS (Continued)


                                                                     Page

SECTION 6.    CONCLUSIONS AND RECOMMENDATIONS                        6-1

6.1 Scope                                                            6-1
6.2 Summary of Conclusions                                           6-1
6.3 Recommendations                                                  6-12

SECTION 7.    SELECTED BIBLIOGRAPHY                                  7-1

APPENDIX A.   SUMMARY OF MAJOR WASTES FROM THE MINING                A-l
              AND PROCESSING OF OIL SHALES

APPENDIX B.   METHODOLOGY                                            B-l

APPENDIX C.   SELECTED CRITERIA ANALYZED FOR TOXIC EFFECTS           C-l

APPENDIX D.   GLOSSARY                                               D-l

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                              EXECUTIVE SUMMARY

     This is the executive summary for the Environmental  Protection  Agency's
Report to Congress on Wastes from the  Extraction  and  Beneficiation of  Metallic
Ores, Phosphate Rock, Asbestos,  Overburden from Uranium  Mining,  and  Oil
Shale.  EPA has prepared this report in response  to the  requirements of
Sections 8002(f) and (p) of the  Resource Conservation and Recovery Act
(RCRA).  Section 8002(f),  a part of RCRA when  it  was  originally  enacted  in
1976, directed EPA to perform a
          detailed and comprehensive study on  the adverse
          effects of solid wastes from active  and
          abandoned surface and  underground mines on  the
          environment, including, but  not limited to, the
          effects of such wastes on humans, water, air,
          health, welfare, and natural resources....
Section 8002(p), which Congress  added  to RCRA  when it amended the Act  in 1980,
required EPA to conduct a
          detailed and comprehensive study on  the adverse
          effects on human health and  the environment, if
          any, of the disposal and utilization of solid
          wastes from the extraction,  beneficiation,  and
          processing of ores and minerals....Such study
          shall be conducted in  conjunction with  the  study
          of mining wastes required by subsection (f)....
     Under the 1980 amendments,  EPA is prohibited from regulating solid  waste
from the "extraction, beneficiation, and processing of ores and  minerals"
under Subtitle C of RCRA until at least 6 months  after the Agency completes
these studies and submits them to Congress. The  purpose of this prohibition
is to exempt these wastes temporarily  from the requirements of the  RGRA
hazardous waste management system.  After submitting  the required studies,
holding public hearings, and providing the public with an opportunity  to
                                     ES-1

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 comment,  the  Administrator must  "determine to promulgate regulations" or
 "determine  such  regulations are  unwarranted" for these mining wastes.
      If EPA decides to regulate  mining wastes as hazardous under RCRA Section
 3004(x),  which Congress added to the Act as part of the Hazardous and Solid
 Waste Amendments of 1984, EPA may modify provisions of these regulations
 pertaining  to liquids in landfills, land disposal restrictions, and minimum
 technology  requirements, as they apply to mining wastes.  In doing so, EPA may
          take into account the  special characteristics of
          such wastes, the practical difficulties associated
          with implementation of such requirements, and
          site-specific characteristics, including, but not
          limited to, the climate, geology, hydrology and
          soil chemistry at the  site, so long as such
          modified requirements  assure protection of human
          health and the environment.
     This report addresses wastes from the extraction and beneficiation of
metallic  ores (with special  emphasis on copper,  gold, iron,  lead, silver, and
zinc), uranium overburden, and the nonmetals asbestos and phosphate rock.  The
Environmental Protection Agency's findings on oil  shales are summarized in
Appendix A  of this report.  EPA selected these mining industry segments
because they generate large quantities of wastes that are potentially
hazardous and because the Agency is solely responsible for regulating the
waste from  extraction and beneficiation of these ores and minerals.   Likewise,
the Agency  excluded from the study wastes generated by the clay,  sand and
gravel, and stone mining segments,  since it judged wastes from these sources
less likely to pose hazards than wastes from the industries  included.   EPA
also excluded uranium mill  tailings wastes, because the Agency has  already
submitted a report to Congress on uranium mill  tailings.   The Agency excluded
wastes from coal  mining  and beneficiation,  because both EPA  and the  Department
                                     ES-2

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of the Interior play a role in their regulation, and it is not clear whether
Congress intended coal mining to be included within the scope of the studies
conducted in response to Sections 8002(f) and (p) of RCRA.  Finally, EPA
excluded large-volume processing wastes.  On October 2, 1985, EPA proposed to
reinterpret the scope of the mining waste exclusion as it applies to
processing wastes, leaving only large volume processing wastes excluded (FR
401292).   Other wastes from processing ores and minerals that are hazardous
would be brought under full Subtitle C regulation after promulgation of the
reinterpretation, and would therefore not be included in the scope of a
subsequent Report to Congress on processing wastes.  The large-volume
processing wastes that remain within the exclusion would be studied and a
Report to Congress prepared to complete EPA's response to the RCRA Section
8002(p) mandate.
     The remainder of this Executive Summary consists of five sections.   First,
we provide an overview of the industry segments covered in this  report.   Next,
we describe management practices for mining wastes.  Then we discuss the
potential  danger to human health and the environment that mining wastes  pose.
Following this, we estimate the costs that regulating mining wastes could
impose under several  scenarios and briefly outline the effects of these  costs
on product prices.  Finally,  we present the Agency's conclusions and
recommendations.

                   OVERVIEW  OF  THE  NONFUEL MINING  INDUSTRY
     The  nonfuel  mining industry is an integral  part of our economy,
providing  a wide range of important products.   The value of raw  nonfuel
1 For the purposes of this report,  the nonfuel  mining industry  is  defined  to
  include uranium, although processed uranium may  be  used  as  a  fuel.
                                     ES-3

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minerals is about 1 percent of the Gross National Product (GNP), and products
made from these raw materials account for about 9 percent of the GNP.
    The number of active mines varies from year to year, depending on economic
factors; in 1980 (the most recent year for which complete data are available
from the U.S. Bureau of Mines), there were about 600 metal  mines and about
12,000 nonmetal mines.  Most of the nonmetal  mines were clay, sand and gravel,
and stone mines, and thus fall outside the scope of this report.  In
the industry segments that this report covers, a few large  mines generally
produce most of the ore and generate most of the waste.
    Ores occur only in certain geologic formations, so much of the mining
within an industry segment is concentrated in a few locations.   Because the
raw ore must be extracted from the earth, and only a small  percentage of the
mined rock is valuable, vast quantities of material must be handled for each
unit of marketable product.  Much of this material  is waste.
    Mine waste is the soil or rock that is generated during the process of
gaining access to the ore or mineral body.  Tailings are the wastes generated
by several physical and chemical  beneficiation processes that may be used to
separate the valuable metal or mineral  from the interbedded rock; the choice
of process depends on the composition and properties of the ore and of the
gangue, the rock in which the ore occurs.  Some low-grade ore,  waste rock, and
tailings are used in dump or heap leaching, a process that  the mining industry
considers a form of beneficiation and one that involves spraying the material
with acid or cyanide to leach out metals.  This process is  most widely
practiced in the copper, silver,  and gold mining segments,  and the associated
wastes are termed dump/heap leaching wastes.   The final waste type is mine
                                     ES-4

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water, water that infiltrates the mine during the extraction process.  Table
ES-1 lists the types and quantities of mining wastes generated by each mining
segment of concern.
    Extraction and beneficiation produce large quantities of waste.  The
segments covered in this report generate 1  to 2 billion tons of waste each
year and have so far produced over 50 billion tons of waste.  Copper, iron
ore, uranium, and phosphate mining operations are responsible for more than
85 percent of this total volume of waste and continue to account for most of
the waste presently generated.  As lower and lower grades of ore are mined,
more waste per unit of product is generated.
    Approximately one-half of the waste generated by the segments of concern
is mine waste, and one-third is tailings.  Most of the mine waste is from
phosphate, copper, iron ore, and uranium mining; the majority of tailings are
from the copper, phosphate, and iron ore segments.  Only the copper, gold, and
silver mining industries presently generate dump or heap leach waste.  The
following section discusses how industry currently manages these wastes.

                          WASTE MANAGEMENT  PRACTICES
    Mine waste, tailings, heap and dump leach wastes, and mine water can be
managed in a variety of ways.   Figure ES-1  provides an overview of waste
management practices.   Waste management practices include recovery operations,
volume reduction, treatment, onsite and offsite use,  and waste siting and
disposal.   For mine waste and tailings, disposal  constitutes the major
practice;  about 56 percent of mine wastes are currently managed by disposal  in
piles, and about 61  percent of tailings are managed in tailings ponds.   About
30 percent of mine waste and tailings are used on site in leaching operations,
                                     ES-5

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                         Table ES-1  Waste Generation
                       (MmIons of Metric  Tons in  1982)
Mining
Industry
segment
Metals:
Copper
Gold
Iron
Lead
Molybdenum
Silver
Uranium
Zinc
Other metals
Subtotal
Nonmetals:
Asbestos
Phosphate
Subtotal
TOTAL
Mine
waste

124
39
102
2
24
20
73
1
23
408

4
294
298
706
Tailings

178
24
75
9
6
6
NA
6
3
307

2
109
111
418
Leaching
wastes

200 (dump)
11 (heap)
_
_
_

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                                                                       RECYCLE
      NPDES
   PERMITTED
   DISCHARGE
V
                                                                       CRUDE ORE
                                                                          MILL
                                                                      (BENEFICATION)
  OTHER
  ONSITE
UTILIZATION
              MINE
             WATER
                   MINE
                   WASTE
                                                                                                                        OFFSITE
                                                                                                                       UTILIZATION
  OFFSITE
UTILIZATION
                                                                                                                ONSITE
                                                                                                              UTILIZATION
                   ONSITE
                UTILIZATION
                                                                                      SOLID
                                                                                      WASTE
                                            LIQUID
                                            WASTE
                                                                                  TAILINGS
                                                                                    POND
                                                 Figure ES-1  The mining waste management process

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construction of tailings impoundments,  and road construction.   Present
disposal and utilization practices for  all metal  and nonmetal  industry
segments are presented in Table ES-2.   A discussion of waste management
practices follows.
     Several methods are available to  treat,  change, or reduce wastes before
disposing of them.  In operations using cyanide,  it may be possible to oxidize
the cyanide before disposal.  It may also be possible to remove pyrites from
tailings, thus reducing, although not  eliminating, their potential  for forming
acid.  Finally, water can be removed from tailings, creating a thickened
discharge.
     Extraction and milling wastes can  also be used off site;  the most common
use of these wastes is in road construction.   Researchers are investigating
other uses for both mine wastes and tailings, such as use in soil supplements,
in wallboard and brick/block products,  and in ceramic products.  However, it
is unlikely that use of mining wastes  will increase greatly in the future,
because in most cases their commercial  potential  is not sufficient to overcome
the economic disadvantages, such as high transportation costs, associated with
their use.
     Mine water can also be used on site in the milling process as makeup
water or for dust control, cooling, or drilling fluids.  In most cases,
however, the amount of mine water exceeds the quantity that can be used.
     The majority of the solid waste generated in mining is not reduced by any
of the methods described above and must be disposed of.  Siting disposal
facilities in appropriate locations is  fundamental to environmental
protection, and other management methods are available for ameliorating waste
disposal problems.
                                     ES-8

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            Table ES-2  Present Mining Waste Disposal
                    and Utilization  Practices
                 (Millions of Metric Tons/Year)
Practice                            Waste type and volume
                              Mine waste         Mill tailings

Pile                             569
Backfill                          86                     21
Onsite utilization               313                    141
Impoundments                      -                     267
Off site utilization               43                      8
TOTAL                          1,011                    437
                              ES-9

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     During active site life,  during closure,  and in the post-closure  period,
facilities could employ engineering controls to prevent erosion,  to  keep
leachate out of the ground water,  or to remove contaminants  introduced into
ground water.  However, EPA data on management methods  at mining  facilities
indicate that only a small percentage of mines currently monitor  their ground
water, use run-on/runoff controls  or liners, or employ  leachate collection,
detection, and removal  systems.  EPA has not determined the  circumstances
under which these waste measures would be appropriate at mine  waste  and mill
tailing disposal sites.

             POTENTIAL DANGER TO HUMAN HEALTH  AND THE ENVIRONMENT
     The potential  dangers posed by wastes from nonfuel  mining and beneficia-
tion vary greatly and depend on  the industry segment; the beneficiation
process; and site-specific geologic, hydrologic,  and climatic  factors.   Some
rock is naturally high in metals or radionuclides.   Some beneficiation
processes use acids and cyanides.   Mine waste, tailings, and mine water can
contain these materials and also be acidic or  alkaline.   Hazardous substances
could leak into the environment, polluting the soil  and surface and  ground
water and endangering receptor populations.
     The Agency has not yet performed a quantitative risk assessment.   Risk
analysis can provide a quantitative estimate and allow  EPA to  distinguish
between the risk posed by current, past, and alternative management  practices.
Additionally, it will enable the Agency to evaluate how site-specific  factors
such as hydrology, proximity to  surface water, climate, distance  from  human
populations, type and sensitivity  of aquatic populations, closeness  to
drinking water supplies, and the chemical and  physical  composition of  the
waste itself affect risk.
                                     ES-10

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     EPA evaluated the potential  dangers posed by mining wastes by testing for
the RCRA characteristics of corrosivity and EP toxicity and by assessing the
level of several other substances in these wastes.  A substance was considered
corrosive if the pH was equal  to or less than 2 (acidic) or equal  to or
greater than 12.5 (alkaline).   A substance was determined to be EP toxic if,
using a specified leaching procedure, it exceeded the National Interim Primary
Drinking Water Standards (NIPDWS) for an EP toxic metal by a factor of 100.
     Only samples from copper dump leach met the RCRA characteristic for
corrosivity because of low pH, but pH values were quite low (more than 2 and
less than or equal to 4) for many samples from the copper and other metals
industry segments and for one sample from the molybdenum segment.   Only one
sample, from the "other" metals industry segment, met the RCRA characteristic
for corrosivity because of high pH.  In addition, one sample each from the
gold and silver industry segments, three from the copper industry segment, and
four from the other metals segment had relatively high (more than 10 and less
than or equal to 12.5) pH values.  EP toxic results were obtained for at least
one sample from copper dump/heap leachate, gold tailings and mine waste, lead
mine waste and tailings, silver tailings and mine waste, and zinc  tailings.
EPA's water quality criteria for the protection of aquatic life are generally
set at levels at lower concentrations than those established by the NIPDWS.
     Another potential threat to organisms and the environment is acid
formation.  Wastes with the highest acid formation potential  are in the
copper, gold, and silver industry segments, although the degree of potential
harm varies with the mineral content of wastes and soils (some wastes and
soils have neutralizing chemicals), amount of precipitation (more increases
the potential for acid drainage), and other factors not evaluated.
                                    ES-11

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     Of the other potentially hazardous constituents considered,  cyanide was
detected in copper and gold tailings ponds and gold heap leachate.   Radioactive
material was found in uranium and phosphate mine waste samples and  in phosphate
tailings.  Although only asbestos mining wastes were tested in this study for
asbestos content, effluent guideline data suggest that asbestos may be present
in wastes generated by some metal mining industry segments.  EPA  has
insufficient data to evaluate the hazard, if any, posed by asbestos contained
in metal mining wastes.
     Based on these sampling results, EPA estimates that the copper mining
segment generates 50 million metric tons of RCRA corrosive waste  annually.
The gold, lead, silver, and zinc industry segments generate a total of 11.2
million metric tons of RCRA EP toxic waste annually.  EPA estimates that 182
million metric tons of copper dump leach are generated annually,  and that the
gold and silver segments generate a total of 9.3 million metric tons of
tailings and 14 million metric tons of heap leach annually.  High acid
formation potential waste is estimated at 95 million metric tons  a  year.  The
phosphate and uranium mining industries generate approximately 443  million
metric tons of radioactive waste (with a radioactivity level of more than
5 picocuries/gram, the level established as a "cleanup" standard  under the
1983 standards for Protection Against Uranium Mill Tailings).  There are also
5 million metric tons of asbestos-containing waste (asbestos content greater
than 1 percent by weight) generated each year.  Estimated amounts of
potentially hazardous wastes are reported in Table ES-3.
     Of the estimated 1,340 million metric tons of waste generated annually by
metal, asbestos, and phosphate mining, 61 million tons are estimated to be
hazardous under current RCRA Subtitle C characteristics.  Adding  wastes with
                                     ES-12

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                   Table ES-3  Estimated Amounts of Wastes with
                               RCRA Hazardous Characteristics  and  Other
                               Wastes Potentially Subject to Regulation
                               as Hazardous Wastes Under RCRA
Category
Annual  amount
(millions of
 metric tons)
   Source
Potential  danger
RCRA Characteristics

Corrosive
EP toxic
Other Categories

Precious metal
recovery wastes
Heap leaching
wastes
Dump leaching
wastes
Radioactive
wastes ( 5 pCi/g)

Acid
formation

Asbestos
     50
     11
     14a




    182a



    352
     91

     95


      5
                       7553
Copper leach
dump liquor

Gold, silver, lead,
zinc wastes
                 Gold, silver
Gold, silver
Copper dump leach
wastes
Phosphate,
uranium

Copper mill
tailings

Asbestos mines
and mills
Ground-water
acidification

Toxic metal
ground-water
contamination
Cyanide contamination
of surface and
ground water

Cyanide contamination
of surface and
ground water

Massive release of
toxic metals and
low pH liquids

Radon
emissions

Release of low pH
liquids after closure

Cancer
a The total annual amount of waste is not equal  to the sum of hazardous waste
  in each category because some wastes are in more than one category.  For
  example, 50 million metric tons of copper dump leach waste are also  corrosive,
  and 4 million metric tons of gold tailings are both EP toxic and  contaminated
  with cyanide.
                                     ES-13

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high acid formation potential,  those that contain asbestos,  those that are
potential candidates for listing because they commonly have  high  levels of
cyanide (greater than or equal  to 10 mg/1),  and radioactive  wastes (radium-226
greater than or equal to 5 picocuries/gram)  would increase this total  to 755
million metric tons of potentially hazardous waste generated by these  mining
industry segments each year.
     EPA conducted a study to determine whether mining waste management
facilities leak and, if they  do, whether they release constituents that are of
concern.  Surface water and/or ground water  was monitored at eight
representative active mine sites.  Results indicate that constituents  from
impoundments do enter ground  water at most sites, but significant increases in
the concentrations of hazardous constituents were rarely demonstrated.
     Damage cases, however, show that mine runoff and seepage have adversely
affected surface and ground water in several mining districts.   Sudden and
chronic releases of cyanides, acids, and metals have reduced fish populations
and the number of other freshwater organisms.  However, some of these
incidents were caused by waste management practices that are no longer in use.

             THE ECONOMIC COST OF POTENTIAL RCRA WASTE MANAGEMENT
     EPA examined the wide range of potential costs that regulating mining
wastes as hazardous under RCRA could impose on facilities and segments of the
mining industry.  To examine this range, EPA estimated the incremental costs,
those over and above the costs the industry already incurs to manage wastes,
for eight regulatory scenarios of varying stringency.  EPA constructed these
eight scenarios by  taking all combinations of four different sets of manage-
ment standards and  two criteria  for determining whether wastes are hazardous.
                                     ES-14

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 The estimation  procedure applied specific information from 47 mines to develop
 costs  at  these  mines and then extrapolated these results to the universe
 covered in  this report.
     The  management standards that EPA examined ranged from imposing the full
 set of RCRA Subtitle C regulations (the most expensive set of management
 standards,  Scenario 1) to requiring only a limited set of requirements:
 permits,  a  leachate collection system, a ground-water monitoring system, a
 run-on/runoff system, and post-closure maintenance (Scenario 4).  Under the
 first  criterion for determining whether wastes were hazardous, waste streams
 failing the Subtitle C characteristics tests for EP toxicity and corrosivity
 and cyanide  wastes from gold metal  recovery operations were included as
 hazardous (Scenario A).  Under the second criterion, all  wastes captured under
 the first set were included, as well  as (1) wastes from gold and silver heap
 leach  operations, (2) wastes with high acid formation potential, and (3) copper
 dump leach wastes (Scenario B).  Both hazardous waste criteria captured only
 wastes from the copper, gold, silver, lead, and zinc mining segments.
     Estimated  costs could be very  substantial, depending on the management
 standards and criteria for defining hazardous waste.   Under the most costly
combination  (the unlikely scenario  imposing the full  set  of RCRA regulations
and the most restrictive criterion  for determining whether waste is hazardous,
Scenario IB), the annualized costs  for the mining  segments  covered  by  the
assessment were $850 million per year, while  for the least costly combination
 (maintenance and monitoring), the annualized  cost  was $7  million per year.
 (Annualized costs resemble mortgage payments,  in that they  spread the  present
value of total  costs into equal  payments  over the  time period  EPA estimates
the affected mines will  be productive.)
                                    ES-15

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     As the previous paragraph demonstrates,  costs  vary  substantially  across
the different cost scenarios.   Generally,  the highest cost scenarios are
several times more expensive than the intermediate  cost  scenarios;  these,  in
turn, are several  times more expensive than the least expensive.  The
additional  waste management costs incurred by adding Scenario B wastes to  the
wastes to be regulated are also substantial;  the costs of managing  all
Scenario B wastes would be two to four times higher than the costs  of  managing
only the Scenario A wastes, for any given  management standard.
     The potential costs of regulation also vary widely  for the five
individual  metal mining segments, both across segments and scenarios.   Under
all scenarios, the copper industry would incur the  largest cost,  while the
gold industry would bear the second highest lifetime cost.
     The additional effects of regulation  on some segments of the mining
industry could be substantial.  For a low-cost scenario, average  affected
facilities in the zinc segment (the segment most affected by regulatory costs
as a percent of direct product cost) would incur costs as high as 5 percent of
direct product costs, while under a high-cost scenario a zinc facility could
incur costs of 10 percent.  Under a high-cost scenario,  RCRA compliance costs
as a percent of direct product cost for the average affected facility  were 21
percent in the lead industry and ranged upward of 120 percent in  the copper
industry.

                                  CONCLUSIONS
Structure and Location of Mines
     EPA focused  on segments producing and concentrating metallic ores,
phosphate rock, and asbestos, totalling fewer than 500 active sites during
1985.  These sites are predominantly in sparsely populated areas west of the
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Mississippi  but have great diversity in size,  product value,  and volumes  of
material  handled.  Several segments are concentrated primarily in one state:
the iron  segment is mainly concentrated in Minnesota, lead  in Missouri, copper
in Arizona,  asbestos in California, and phosphate in Florida.
Waste Quantities
     Aggregate waste quantities generated were 1.3 and 2 billion metric  tons
per year  in  1982 and 1980, respectively.   The  accumulated waste (for segments
other than coal) is estimated to be approximately 50 billion  metric  tons.
Waste-to-product ratios are generally higher in mining industry segments  than
in other  industrial segments.  Some individual  mines and mills handle more
materials than many entire industries, but 25  percent of the  mines studied
handled less than 1,000 metric tons per year.
Potential Hazard Characteristics
     Of the  1.3 billion metric tons of wastes  that EPA estimates will be
generated by extraction and beneficiation in 1985, about 61 million  metric
tons (5 percent) exhibit the characteristics of corrosivity and EP (extraction
procedure) toxicity.  Another 23 million metric tons (2 percent) are
beneficiation wastes contaminated with cyanide.  Also, there  are 182 million
metric tons  (14 percent) of copper leach dump  material and  95 million metric
tons (7 percent) of copper mill tailings with  the potential for release  of
acidic and toxic liquids.  If waste with radioactivity content greater than 5
picocuries per gram is considered hazardous, the hazardous  volume is 443
million metric tons (34 percent) from the phosphate and uranium segments; if
waste with radioactivity greater than 20 picocuries per gram  is considered
hazardous, the total is 93 million metric tons (7 percent).   Four asbestos
mines generated about 5 million metric tons (less than 1 percent) of waste
with a chrysotile content greater than 5 percent.
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Evidence of Environmental  Transport
     At mine sHes, ground-water monitoring is  difficult and  expensive,  and
generally is not conducted on a large scale.  From short-term monitoring
studies at eight sites, EPA detected seepage from tailings  impoundments, a
copper leach dump, and a uranium mine water pond.   However, EP  toxic  metals  of
concern did not appear to have migrated during  the 6- to 9-month  monitoring
period.  Other ground-water monitoring studies  have detected  sulfates,
cyanides, and other contaminants from mine runoff, tailings pond  seepage, and
leaching operations.
Evidence of Damages
     Incidents of damage {contamination of drinking water aquifers,
degradation of aquatic ecosystems,  fish kills,  and related  reductions of
environmental quality) have been documented in  the phosphate, gold,  silver,
copper, lead, and uranium segments.  There are  13 mining sites  on the National
Priorities List (Superfund), including five gold/silver, three  copper,  three
asbestos, and two lead/zinc mines.  The asbestos Superfund sites differ  from
other sites in that these wastes pose a hazard  via airborne exposure.  It is
not clear, from the analysis of damage cases and Superfund  sites, whether or
not current waste management practices can prevent damage from  seepage  or
sudden releases.  However, it is clear that some of the problems  at  abandoned
or Superfund sites are attributable to waste disposal  practices not  currently
used by the mining industry.
Waste Management Practices
     Site selection for the mine, as well  as its associated beneficiation and
waste disposal facilities, is the single most important aspect  of
environmental protection in the mining industry.  Most mine waste is  disposed
of in piles, and most tailings in impoundments.   Mine water is  often  recycled
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through the mill  and used for other purposes on site.   Offsite utilization of
mine waste and mill tailings is limited (2 to 4 percent).   Some management
measures (e.g., source separation, treatment of acids  or cyanides,  and waste
stabilization) now used at some facilities within a segment of the mining
industry could be more widely used.  Other measures applied to hazardous waste
in nonmining industries may not be appropriate.  Soil  cover borrowed from
surrounding terrain may create additional  reclamation  problems in arid regions.
Potential Costs of Regulation
     For five metal mining segments, total annualized  costs range from
$7 million per year (for a scenario that emphasizes primarily basic maintenance
and monitoring, for wastes that are hazardous by RCRA characteristics) to over
$800 million per year  (for an unlikely scenario that approximates a full RCRA
Subtitle C regulatory approach, emphasizing cap and liner containment for all
wastes considered hazardous under the current criteria, plus cyanide and acid
formation wastes).  About 60 percent of the total projected annualized cost at
active facilities can be attributed to the management  of waste accumulated
from past production.  Those segments with no hazardous wastes (e.g., iron)
would incur no costs.  Within a segment, incremental costs would vary greatly
from facility to facility, depending on current requirements of state laws,
ore grade, geography, past waste accumulation, percentage of waste with
hazardous characteristics, and other factors.

                                RECOMMENDATIONS
     Section 8002(f) of RCRA requires EPA to conduct a study of the adverse
effects of mining waste and to provide "recommendations for Federal...actions
concerning such effects."  Based on our findings from this study, we make
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several preliminary recommendations for those wastes and industry segments
included in the scope of the study.  The recommendations are subject to change
based on continuing consultations with the Department of the Interior (DOI)
and new information submitted through the public hearings and comments on this
report.  Pursuant to the process outlined in RCRA §3001(b)(3)(C), we will
announce our specific regulatory determination within 6  months after
submitting this report to Congress.
     First, EPA is concerned with those wastes that have the hazardous
characteristics of corrosivity or EP toxicity under current RCRA regulations.
EPA intends to investigate those waste streams.  During  the course of this
investigation, EPA will  assess more rigorously the need  for and nature of
regulatory controls.  This will require further evaluation of the human health
and environmental exposures mining wastes could present.   EPA will  assess the
risks posed by mining waste sites and alternative control options.   The Agency
will  perform additional  waste sampling and analysis, additional  ground-water
or surface water monitoring and analysis, and additional  analysis of the
feasibility and cost-effectiveness of various control  technologies.
     If the Agency determines through the public comments, consultation with
DOI and other interested parties, and its own analysis,  that a regulatory
strategy is necessary, a broad range of management control options consistent
with protecting human health and the environment will  be considered and
evaluated.  Moreover, in accordance with Section 3004(x), EPA will  take into
account "the special characteristics of such waste, the  practical difficulties
associated with implementation of such requirements and  site specific
characteristics...," and will comply with the requirements of Executive Orders
12291 and 12498 and the Regulatory Flexibility Act.
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     Second, EPA will  continue gathering information  on those  waste streams
that our study indicates may meet EPA's criteria for  listing as hazardous
wastes requiring regulation—dump leach waste, because of its  high metal
concentrations and low pH, and wastes containing cyanides.  Although these
waste streams are potential candidates for listing as hazardous wastes,  we
need to gather additional  information similar to the  information gathered  for
the rulemaking for corrosive and EP toxic wastes.   When we have gathered
sufficient information, we will announce our decision as to whether to
initiate a formal rulemaking.  If the Agency finds it necessary to list  any of
these wastes, we will  also develop appropriate management standards in the
same manner as we did those developed for corrosive and EP toxic wastes.
     Finally, EPA will continue to study radioactive  waste and waste with  the
potential  to form sulfuric acid.  The Agency is concerned that radioactive
wastes and wastes with the potential  for forming acid may pose a threat  to
human health and the environment, but we do not have  enough information  to
conclude that they do.  We will continue to gather information to determine
whether these wastes should be regulated.  If EPA finds that it is necessary
to regulate these wastes, the Agency will develop the appropriate measures of
hazard and the appropriate waste management standards.
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                                   SECTION 1
                                 INTRODUCTION

    This report is required by Sections 8002(f)  and (p)  of the Resource
Conservation and Recovery Act (RCRA), which  directs the  Environmental
Protection Agency (EPA) to perform studies  of wastes generated in  the  mining,
beneficiation, and processing of ores and minerals and to report the results
of these studies to Congress.  This report  is based on literature  reviews  and
contractor studies, including numerous analytical  testing results  on the
wastes.  EPA's RCRA Docket contains copies  of the source materials that  the
Agency used in preparing this report.
    Because Congress has amended the Act several  times in ways that changed
the requirements for mining wastes, and because  EPA regulations continue to
evolve both in response to legislation and  as EPA collects additional
information, a brief legislative and regulatory  history  provides a useful
context for this Report to Congress.
    When first enacted in 1976 (P.L. 94-580), RCRA contained a broad
definition of solid waste that included "solid,  liquid,  semi-solid, or
contained gaseous material  resulting from...mining...operations."    [emphasis
added] (Section 1004(27)).
    Section 8002(f) of the original Act directed EPA to  conduct a
     detailed and comprehensive study on the adverse effects of
     solid wastes from active and abandoned  surface and
     underground mines on the environment,  including, but not
     limited to, the effects of such wastes  on humans, water,
     air, health, welfare,  and natural  resources,  and on the
     adequacy of means and measures currently employed by the
     mining industry, Government agencies, and others to dispose
     of and utilize such solid wastes to prevent or
     substantially mitigate such adverse effects.
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The study was to include an analysis of:
     1.   The sources and volume of discarded material
          generated per year from mining;
     2.   Present disposal practices;
     3.   Potential danger to human health and the environment
          from surface runoff of leachate  and air pollution by
          dust;
     4.   Alternatives to current disposal methods;
     5.   The cost of those alternatives  in terms of the impact
          on mine product costs; and
     6.   Potential for use of discarded  material as a
          secondary source of the mine product.
The Act did not specify a date for the completion of this study.
     On December 18, 1978, EPA proposed regulations to implement Subtitle C of
RCRA, including rules for identifying and  listing hazardous wastes and for
managing these wastes.  Based on the language in the House Committee Report
accompanying the House Bill, which was the predecessor to the Act, EPA
specifically excluded as a hazardous waste "overburden resulting from mining
operations and intended for return to the  mine site" unless the overburden was
specifically listed.  The Agency proposed  to list waste rock and overburden
from uranium mining and overburden and slimes from phosphate surface mining
because of concern about their radioactivity.  The proposal also considered
any other mining wastes that were ignitable, corrosive, reactive, or EP toxic
as hazardous waste.
     In addition, the proposal included distinct management standards for
"special wastes," which "occur in very large volumes" and for which "the
potential hazards...are relatively low" (43 FR 58992, December 18, 1978).  The
Agency proposed less stringent standards  for these wastes than for other
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hazardous wastes, pending the development of additional  information  and a
subsequent planned rulemaking.  Certain mining wastes  were among the special
wastes.  They included phosphate mining, beneficiation,  and processing  wastes;
uranium mining waste; and other mining waste that was  ignitable, corrosive,
reactive, or EP toxic.
     On May 19, 1980, EPA promulgated interim final  regulations implementing
Subtitle C of RCRA.  The Agency retained the exclusion for overburden that was
returned to the mine site; however, the Agency dropped the two proposed
listings, because the regulations "eliminated the part of the proposed
exemption that would allow exempted overburden to be brought within  RCRA
jurisdiction through specific listing as a hazardous waste" (45 FR 33100, May
19, 1980).  EPA also promulgated interim final listings for three specific
mining waste streams:  (1) flotation tailings from selective flotation  from
mineral metals recovery operations, (2) cyanidation wastewater treatment
tailings pond sediment from mineral metals recovery operations, and  (3) spent
cyanide bath solutions from mineral metals recovery operations.  Before the
first of these listings became effective, however, EPA withdrew this listing
based on technical comments from the regulated community.
     These promulgated standards did not have distinct and less stringent
management standards for mining wastes.  Between the time of the proposal  and
the promulgation of the interim final rule, EPA modified the EP toxic and
corrosivity criteria for hazardous wastes, and the Agency therefore
anticipated that a smaller quantity of mining wastes would be classified as
hazardous based on results of tests for these two characteristics.  However,
EPA judged that wastes so classified would clearly exhibit sufficient toxicity
to be of concern.  "Thus the concern over the inapplicability of the proposed
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regulations to hazardous special  wastes, due to the potentially large volume
and low level of hazard of these  wastes, is not a valid concern in the final
regulations" (45 FR 33174, May 19, 1980).   The preamble also noted that there
was no current provision that would permit deferring the regulation of mining
wastes until the results of the Section 8002(f) study were available.  EPA did
point out, however, that Congress was considering legislation that would amend
RCRA to require deferral until  the study was complete.
     Congress then amended RCRA in the Solid Waste Disposal  Act of 1980
(P.L. 96-482), enacted on October 21, 1980.  Among other things, the
amendments prohibited EPA from regulating solid waste from the "extraction,
beneficiation, and processing of ores and minerals, including phosphate rock
and overburden from the mining  of uranium ore" as hazardous  wastes under
Subtitle C of RCRA until at least 6 months after the Agency  completed and
submitted to Congress the studies required by Section 8002(f) and by a new
section, 8002(p).
     Section 8002(p) requires EPA to perform a comprehensive study on the
disposal, and utilization of solid waste from the extraction, beneficiation,
and processing of ores and minerals, including phosphate rock and overburden
from uranium mining.  This new  study, to be conducted in conjunction with the
study of mining wastes required by Section 8002(f), mandated an analysis of:
     1.   The source and volumes  of such materials generated
          per year;
     2.   Present disposal  and  utilization practices;
     3.   Potential danger, if  any, to human health and the
          environment from the  disposal  and reuse of such
          materials;
     4.   Documented cases in which danger to human health or
          the environment has been proven;
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     5.    Alternatives to current disposal  methods;
     6.    The costs of such alternatives;
     7.    The impact of these alternatives on the use of
          phosphate rock and uranium ore,  and other  natural
          resources; and
     8.    The current and potential  utilization of such
          material s.
     The amendments also required the Administrator, "after public hearings
and opportunity for comment, either to determine to  promulgate regulations"
for mining wastes or "to determine that such regulations are unwarranted."
These determinations must be published in  the Federal Register.
     Finally, the amendments specified that EPA could control radiation
exposures caused by mining wastes under RCRA.  Section 3001(b)(3)(B)(iii)
authorized the Administrator to
     prescribe regulations...to prevent radiation exposure which
     presents an unreasonable risk to human health from the use
     in construction or land reclamation (with or without
     revegetation) of (I) solid waste from the extraction,
     beneficiation, and processing of phosphate rock or (II)
     overburden from the mining of uranium ore.
     On November 19, 1980, EPA published an interim final  rule to implement
the 1980 RCRA Amendments.  Specificially,  EPA excluded from regulation under
Subtitle C of the Resource Conservation and Recovery Act "...solid waste from
the extraction, beneficiation and processing of ores and minerals (including
coal), including phosphate rock and overburden from the mining of uranium ore"
(45 Fed. Reg. 76618, codifield at 40 CFR 261.4(b)(7)K  The Agency interpreted
the scope of the exclusion very broadly:
     Until the Agency takes further rulemaking action on this
     matter, it will interpret the language of today's amend-
     ments, with respect to the mining and mineral processing
     waste exclusion, to include solid waste from the explora-
     tion, mining, milling, smelting and refining of ores and
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     minerals.  This exclusion does not,  however,  apply  to
     solid wastes, such as spent solvents,  pesticide wastes,
     and discarded commercial  chemical  products,  that are not
     uniquely associated with  these mining  and allied process-
     ing operations (45 FR 76619, November  19, 1980).

    EPA solicited public comment on its interpretation to assist in determin-

ing the appropriate scope of the statutory  exclusions.

     In particular, EPA questions whether Congress intended to
     exclude (1) wastes generated in the  smelting, refining and
     other processing of ores  and minerals  that are further
     removed from the mining and beneficiation of such ores and
     minerals, (2) wastes generated during  exploration for
     mineral deposits, and (3) wastewater treatment and  air
     emission control sludges  generated by  the mining and
     mineral processing industry.  EPA specifically seeks
     comment on whether such wastes should  be part of the
     exclusion.  EPA also seeks comment on  how it might
     distinguish between excluded and non-excluded solid wastes
     (45 FR 76619, November 19, 1980).

     The Hazardous and Solid Waste Amendments of 1984, enacted in November of

that year as P.L. 98-616, represent the culmination of the House and Senate

reauthorization hearings begun in early 1983.  Of chief  concern to the mining

industry are amendments that provide EPA flexibility in  applying bans on land

disposal and certain requirements for obtaining permits  under Subtitle C of

RCRA to the mining industry.

     The amended statute provides, under Section 3004(x), that if mining

wastes become subject to regulation as hazardous wastes  under Subtitle C, the

Administrator of EPA, in promulgating regulations, is authorized to modify the

requirements of subsections (c), (d), (e),  (f), (g), (o), and (u) of Section

3004 and subsection 3005(j), which relate to:

     1.   Liquids in landfills,

     2.   Prohibitions on land disposal,

     3.   Solvents and dioxins,

     4.   Disposal into deep injection wells,
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     5.   Additional  land disposal  prohibition  determinations,

     6.   Minimum technological  requirements,

     7.   Continuing releases  at permitted facilities,  and

     8.   Interim status surface impoundments.

     The Administrator is authorized to  take  into  account the special

characteristics of mining and beneficiation wastes,  "the practical

difficulties associated with implementation of  such  requirements, and  site-

specific characteristics, including, but not  limited to, the climate,  geology,

hydrology, and soil  chemistry at the site, so long as such  modified

requirements assure protection of human  health  and the environment."

     The Conference Report accompanying  H.R.  2867  (which in its  final  amended

form was passed by both Houses of Congress as P.L. 98-616)  provides

clarification:

          This Amendment recognizes that even if some of the special study
          wastes [which include mining wastes as specified  in Sections 8002
          (f) and (p)] are determined to be hazardous it may not be necessary
          or appropriate because of their special  characteristics and  other
          factors, to subject such wastes to  the same requirements that are
          applicable to other hazardous  wastes,  and  that protection of human
          health and the environment does not necessarily imply  the uniform
          application of requirements developed  for  disposal of  other
          hazardous wastes.  The authority delegated to the Administrator
          under this section is both waste-specific  and requirement-specific.
          The Administrator could also exercise  the  authority to modify
          requirements for different classes of  wastes.  Should  these  wastes
          become subject to the requirements of Section 3005 (j), relating to
          the retrofit of surface impoundments,  the  Administrator could modify
          such requirements so that they are not identical  to the requirements
          that are applied to  new surface impoundments  containing such
          wastes.  It is expected that before any  of these  wastes become
          subject to regulations under subtitle  C, the  Administrator will
          determine whether the requirements of Section 3004 (c), (d), (e),
          (f), (g),  (o), and (u), and Section 3005(j) should be  modified
          [H.R.  Report 98-1133, pp.  93-94, October  3,  1984].


    On October 2, 1985, EPA proposed (50 Fed. Reg. 401292)  to reinterpret the

scope of the mining waste exclusion as it applies  to processing  wastes,
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leaving within it only large-volume processing wastes,  such  as  slag from
primary metal smelters and elemental  phosphorus plants, red  and brown muds
from bauxite refineries, and phosphogypsum from phosphoric acid plants.   Those
other wastes from processing ores and minerals that are hazardous  would  be
brought under full  Subtitle C regulation after the  promulgation of the rein-
terprete ti on, and would therefore not be included  in the scope  of  a subsequent
Report to Congress on processing wastes.  The large-volume processing wastes
that remain within the exclusion would be studied  and a Report  to  Congress
prepared to complete EPA's response to the RCRA Section 8002(p) mandate.
    Thus, EPA must submit a Report to Congress under RCRA Sections 8002(f) and
(p) and then publish its findings in  the Federal Register before any waste
covered by the mining exclusion can be regulated under Subtitle C  of RCRA.  No
such restrictions, however, apply to  wastes not included within the scope of
the exclusion.

                                   1.1 SCOPE
    This report addresses waste from  the mining and beneficiation  of metallic
ores, with special  emphasis on copper, gold,  iron,  lead, molybdenum, silver,
and zinc; uranium overburden; and the nonmetals asbestos, phosphate rock, and
oil shales.  (Appendix A to this report addresses wastes from the  mining and
beneficiation of oil  shales.)  EPA selected the mining  industry segments  to be
covered in this report on the following basis.  First,  the Agency  excluded
wastes that are the primary responsibility of other regulatory  agencies.
Thus, this report does not address uranium mill  tailings or  the mining and
beneficiation of coal.  The Uranium Mill Tailings  Radiation  Control  Act  of
1978 (UMTRCA) (P.L. 95-604) requires  proper disposal  of "residual  radioactive
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material," including mill  tailings and residual  stocks of unprocessed ores  or
low-grade materials.  UMTRCA directed EPA to prepare a Report to Congress on
uranium mill  tailings, and the Agency has done so.    Under UMTRCA,  EPA
determines "standards of general  application," and  the Nuclear Regulatory
Commission writes the implementing regulations and  enforces them for active
mills.  Uranium mill tailings are defined as "byproduct material" by the
Atomic Energy Act and, as  such,  do not constitute a "solid waste" as defined
by RCRA Section 1004(27).   Therefore, they are not  subject to RCRA
requirements.
    The Surface Mining Control and Reclamation Act  of 1977 (SMCRA)  (P.L.
95-87) applies to surface  coal mining reclamation activities.   Under RCRA,  the
Administrator of EPA must review any regulations under SMCRA that are
applicable to coal  mining  wastes and overburden. However, the Secretary of
the Interior, with concurrence from the Administrator of EPA,  is responsible
for promulgating regulations that effectuate the purposes of Subtitle C of
RCRA with respect to "coal  mining wastes or overburden for which a  surface
coal mining and reclamation permit is issued or approved under the  Surface
Mining Control and Reclamation Act of 1977."
    The Agency also excluded from the scope of this report wastes generated in
the processing of ores or  minerals.   EPA will  address large-volume  wastes
(such as slag and phosphogypsum)  generated by these processes  in a  subsequent
report.  EPA will also evaluate other nonmetal  mining wastes (in addition to
asbestos and phosphate) and wastes from inactive or abandoned  mines at a later
time.
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                                 1.2 CONTENTS
    This report consists of seven sections and four appendices.   The following
paragraphs briefly discuss each of the remaining sections of the report.
    Section 2, OVERVIEW OF THE NONFUEL MINING INDUSTRY,2 presents a summary
of the mining and beneficiation of ores and minerals and provides information
on the number of mines, their geographic distribution,  and the quantity of
waste generated in mining and beneficiation.
    Section 3, MANAGEMENT PRACTICES FOR MINING WASTES,  provides an overview of
the mining waste management process and discusses specific waste management
practices and mitigative measures for the land disposal  of mining waste.   For
some segments of the industry, the section provides information on the
proportion of mine facilities that currently practice these mitigative
measures.
    Section 4, POTENTIAL DANGER TO HUMAN HEALTH AND THE ENVIRONMENT, presents
information on the characteristics of the wastes that pose a potential threat
to human health and the environment.   It estimates how much mining industry
waste would fail  current RCRA hazardous waste characteristics, and how much
would be hazardous under an augmented set of characteristics.   It then
provides the results of EPA's monitoring of ground water at selected sites.
It also discusses the structural  stability of impoundments used to manage
mining waste.  Next, it presents  damage cases.   Finally,  it describes how risk
analysis could be used to quantify the effects that current and alternative
practices have on human health and the environment.
    Section 5, THE ECONOMIC COST  OF POTENTIAL RCRA WASTE MANAGEMENT, first
presents the methodology EPA used to determine the potential  cost of
regulating mining wastes under RCRA,  using four different regulatory scenarios
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and two different sets of hazard criteria.   The section then  presents the
results of the analysis in terms of total  potential  costs,  the potential  costs
to various mining sectors, and the potential  costs to the  affected  mines.
    Section 6, CONCLUSIONS AND RECOMMENDATIONS, summarizes the conclusions
reached in the other sections of the report and presents EPA's recommendations.
    Section 7, SELECTED BIBLIOGRAPHY, lists the sources that were used in this
report as well as some references that contain valuable information related to
mining waste.
    This report also contains four appendices:
    •    Appendix A, SUMMARY OF MAJOR WASTES FROM THE MINING AND PROCESSING OF
         OIL SHALES, summarizes a report on high-volume wastes generated by
         the mining and processing of oil  shales.  This information was not
         included in this Report to Congress because the United States oil
         shale industry is not yet operating on a commercial  scale.  The
         entire oil shale report is available in the EPA docket.

    t    Appendix B, METHODOLOGY, describes the methdology used by EPA to
         assess current industry waste management practices and to estimate
         the amount of hazardous mining waste generated annually.

    •    Appendix C, SELECTED CRITERIA ANALYZED FOR TOXIC EFFECTS, contains
         tables comparing levels of metals measured by the EP toxicity test
         allowed by various  EPA standards and criteria; tables on arsenic,
         cadmium, chromium,  lead, mercury, selenium, and cyanide toxicity to
         aquatic biota are also included.   In addition, this appendix
         summarizes radiation effects and effects of asbestos exposure on
         various biological  species, and the effects of decreasing pH on  fish.
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•    Appendix D, GLOSSARY, provides definitions of mining-related and
     other technical  terms referred to in the text.
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                             SECTION 1   FOOTNOTES
1   US EPA 1983a.
    For the purposes of this report,  the nonfuel mining industry  is  defined as
    including uranium although processed uranium may be used  as fuel.
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                                  SECTION 2
                    OVERVIEW OF  THE  NONFUEL MINING  INDUSTRY

    The nonfuel  mining industry  is an integral  part of  our economy.   It
provides a diversity of products, including the lead used in  storage
batteries, ammunition, and pigments; copper for electrical  equipment  and
supplies; iron for the construction and transportation  industries;  zinc for
galvanizing and other uses; silver for photographic materials;  gold for
electronic equipment, jewelry, and medicinal  use;  and the uranium used by
electric utilities.   This sector also produces  nonmetallic minerals such as
asbestos for use in  insulating materials and phosphates used  to produce
industrial chemicals and fertilizers.   The total  metal ore production in
the United States was worth more than $5.8 billion, and the total  value of raw
                                                   2
nonfuel minerals was more than $21 billion in 1983.   This value accounted
for 1 percent of the Gross National  Product (GNP),  while products made from
                                                                            3
these raw materials  account for approximately 9 percent of the  GNP annually.
                          2.1  NONFUEL MINING SEGMENTS
    There were 580 metal  mines and 12,117 nonmetal  mines active  in 1980 (the
most recent year for which complete data are available from the  U.S.  Bureau  of
       4
Mines).   The number of active mines varies from year  to year, depending on
factors such as the level  of U.S.  economic activity, the costs of production
in the mining industry, the demand for products derived from nonfuel  minerals,
and prices in international markets.  In general, the  number of  mines in
operation has decreased over the past several  years; however, a  reasonable
estimate for 1983 indicates that between 400 and 500 metal  mines operated in
                                       2-1

-------
the segments covered here.   Table 2-1  lists  the number of active nonfuel mines
in 1980, 1981, and 1982 for the mining industry segments covered in  this
report:  all metal mines,  except gold  placer operations, appear in the metals
category, and all  asbestos and phosphate  mines appear in the  nonmetals
category.  The metal mining segments include copper, gold,  iron ore, lead,
molybdenum, silver, uranium, zinc, and a  group of "other" metals.  The metals
in the "other" category have been grouped in order to avoid disclosing
confidential business information; they include antimony, bauxite, beryllium,
mercury, nickel, the rare earth metals, titanium, and vanadium.  Because
domestic tin and manganiferous ore mines  have been minor sources of  ore since
1982, these segments are not covered  in this report.  Platinum also  is not
covered  in  this report because no platinum mines  have been  active  since 1982.
    Although mines are classified on  the  basis of their predominant  product,
they may also produce large quantities of other materials as  coproducts.   For
example, in 1978, U.S. zinc mines produced 72 percent of all  zinc;  100  percent
of all cadmium, germanium, indium, and thallium;  and 3.1, 4.1, and 6.1  percent
of all gold, silver, and lead mined in the United States, respectively.   In
the same year, copper mines produced over 30 percent of the silver,  35  percent
of the gold, and  100 percent of the rhenium, selenium,  palladium,  tellurium,
and platinum mined  in this country.   Thus, a copper mine may also produce
gold and silver as coproducts.  Table 2-2 summarizes the products  and
coproducts  for selected metal mining segments.
    In most mining  segments, a few large mines produce  most of the product.
Table  2-3  shows the number of mines in each segment, categorized by volume of
material handled.   This volume includes the amount of  earth and rock that must
be removed to  reach the ore.  About half of all   U.S. metal  mines active in
1982 were  small,  handling less than 10,000  tons of material each.   These 213
                                       2-2

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          Table 2-1   Number of Active Mines  in  the  Industry  Segments
                Covered in This Report in 1980,  1981,  and 1982*
Mining
industry
segment
Metals:
Bauxite (aluminum)
Copper
Goldb
Iron ore
Lead
Silver
Titanium
Tungsten
Uranium
Zinc
Other metal sc
Number of
mines
1980

10
39
44
35
33
43
5
29
265
20
21
Number of
mines
1981

10
44
107
31
29
75
5
29
195
17
18
Number of
mines
1982

8
32
101
26
17
63
5
23
128
14
21
               Subtotal                     544           560            438

         Nonmetals:
Asbestos
Phosphate rock
Subtotal
TOTAL
4
44
48
592
4
43
47
607
3
33
36
474
<* Excludes wells, ponds, and pumping operations.
b Excludes placer operations.
c Includes antimony, beryllium,  mercury,  molybdenum,  nickel,  platinum,
  rare-earth metals, and vanadium.

Source:  Adapted from BOM 1981 a, BOM 1982,  and  BOM 1983.
                                      2-3

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            Table 2-2  Product As a Percentage  of Total  Output
                  for Selected U.S. Metal Mines  in 1978
Primary
mine
product
Copper
Gold
Lead
Silver
Zinc
Total9

Copper
98.8
._ b
0.8
0.3
0.1
100.0

Gold
36.7
55.6
0.1
4.1
3.1
99.6
Product or
Coproduct
Lead Silver
—
—
90.
3.
6.
99.
b 31.7
b 1.7
3 8.7
4 53.7
1 _iil
8 99.9

Zinc
1.3
..b
25
0.9
72
99.2
a Totals may not equal 100 percent due to rounding.
b Indicates less than 0.5 percent.
Source: Adapted from BOM 1981 a.
                                       2-4

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                  Table 2-3  Mines in the Industry Segments Covered in this Report in 1982,
                                      by  Volume  of Material  Handled*.15
ro
i
en

Mining
industry
segment
Metals:
Bauxite (aluminum)
Copper
GoldC
Iron ore
Lead
Si 1 ver
Titanium
Tungsten
Uranium
Zinc
Other metalsd
Subtotal
Nonmetal s:
Asbestos
Phosphate rock
Subtotal
TOTAL
a Includes product
Total
number
of
mines

8
32
101
26
17
63
5
23
128
14
21
438

3
	 33
36
474
and waste,
Less
than
1,000
tons

._
3
41
__
7
32
—
18
16
*.«
5
122


^____
--
122
but excl
1,000
to
10,000
tons

1
1
28
2
1
14
--
2
34
1
7
91


—
1
92
udes wells,
10,000
to
100,000 1
tons

5
5
11
4
--
6
--
2
52
2
2
89

3
—
3
92
ponds, and
b These data are reported in short tons; one short ton equals
C FyrluHpc nl arpr nnpratinnc.
100,000
to
,000,000
tons

2
1
14
6
2
10
1
1
24
9
2
72


	 4
4
76
pumping
1,000,000
to
10,000,000
tons

„
15
6
8
7
1
4
--
2
2
5
50


	 23
23
73
operations.
More
than
10,000,000
tons

..
7
1
6
--
--
--
--
--
__
--
14

_.
	 5
5
19

1.1 metric tons.
       d  Includes  antimony,  beryllium, mercury, molybdenum, nickel,  rare-earth metals,  and  vanadium.


       Source:   BOM  1981 a.

-------
small mines handled only 10 percent of  the  material handled by  the  14 largest
mines.

                     2.2 GEOGRAPHIC DISTRIBUTION  OF MINES
    Because ores occur only in  certain  geologic formations, most of the mining
in each industry segment is concentrated  in a  few locations.  Copper mining is
centered in three states:  Arizona, Utah, and  New Mexico.  Other states where
copper is mined as a coproduct  of silver, zinc, and lead production are
Montana, Tennessee, and Missouri, respectively.   Some copper mines and mills
are close to large cities (Tucson and Salt  Lake City), but most active
operations are in sparsely populated (four  people per square kilometer,
compared with a national average of 25  people  per square kilometer) parts of
Arizona.
    Nevada, South Dakota, and Montana were  responsible for 85 percent of the
primary gold production in 1983 (excluding  gold produced by Alaskan placer
operations).  Other primary gold-producing  states are California, Colorado,
Idaho, New Mexico, and Utah. Gold is also  produced as a coproduct  of silver
and copper mining in Utah, Nevada, and  Arizona.   Placer mines in Alaska and
gold heap leaching operations in Nevada are located in areas far removed from
population centers.
    Almost all iron ore is mined in Minnesota  and Michigan, although Texas,
Missouri, Utah, Wyoming, and California combined  are responsible for
approximately 5 percent of all  iron ore production.  Primary lead production
in the United States is confined to Missouri,  where lead mining is
concentrated in the Mark Twain  National Forest (the average population density
in the southeastern part of the state is  five  people per square kilometer).
Lead  is also recovered as a coproduct from  some western mining  operations.
Colorado is the primary molybdenum-producing state.   Although  silver is mined
                                       2-6

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in many states,  its production as a  primary  metal  is concentrated  in  sparsely
populated areas  of Idaho,  Montana, Nevada, and Utah.   Primary  silver
production accounted for 70 percent  of U.S.  silver output  in 1983,  an increase
of 54 percent since 1978 (see Table  2-2).  The remainder was produced as  a
coproduct of copper, gold, lead, and other metals  mining activities.
    Uranium mining is concentrated in sparsely populated parts of  New Mexico,
Wyoming, Colorado, and Utah.  Zinc is produced in  Tennessee, New York,
Missouri, New Jersey, Idaho, and Colorado; Missouri produces 21  percent of  all
U.S. zinc as a coproduct of lead production.  Zinc is  also a coproduct of
silver production.  Zinc mining in Tennessee and New York  is located in
moderately populated areas  (45 people per square kilometer in  Tennessee and 16
people per square kilometer in New York).   The largest Tennessee zinc mining
district is 50 kilometers from Knoxville.
    The mining of metals in the other metals category  is generally restricted
to the metal ore-producing  states mentioned above.  Additionally,  California
produces tungsten and rare  earth metals, and Arkansas  produces bauxite for
metallurgical uses.
    Asbestos mining is  restricted to California and Vermont.   The  asbestos
mine in Vermont and one of  the mines in California are in  areas of moderate
population density.  Phosphate mining is concentrated in Florida,  North
Carolina, and Idaho.  In  Idaho, phosphate mining occurs in a sparsely
populated area; but  in  Florida, most phosphate operations are about 65
kilometers east of  Tampa, in  an area with a population density of 68 people
per square kilometer.   Table  2-4  summarizes the number of operating mines and
percentage of 1983  production  in  each state,  arranged by EPA region,  for the
nonfuel mining  segments covered in  this report.   Note that for some  products,
a few  mines  are responsible for  the majority  of all primary production.  For
                                        2-7

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                            Table  2-4  Active Mines and Percentage of  Production  by  State3 in 1983
ro
oo
States arranged
by EPA region
I
Vermont
II
New Jersey
New York
III
Pennsylvania
IV
Fl ori da
N. Carolina
Tennessee
V
Michigan
Minnesota
VI
N. Mexico
Texas
VII
Missouri
VIII
Colorado
Montana
S. Dakota
Utah
Wyoming
Copper Gold1* Iron ore Lead Molybdenum Silver Uranium Zinc Asbestos Phosphate
1(25)
1(8)
2(27)
1(8)
20(74)
	 -- -- 	 1(11)
1(1) - -- - -- - -- 7(51) -- 4(3)
2(25)
9(70)
2(11) 6(3) - — — 5(1) 20(25)
2(1) -- -- - 6(5)
1(2) 7(100)
20(4) -- -- 2(100) 5(6) 28(15) 1(6)
1(3) 16(10) -- -- - 9(17) -- - -- 1(1)
1(19) - - -- 	
1(17) 1(2) 3(1) -- - 3(8) 23(13) - -- 1(1)
2(1) — -- — 22(40)

-------
                                                    Table 2-4  (Continued)3
    States arranged
     by EPA region      Copper    Gold**      Iron ore  Lead    Molybdenum   Silver     Uranium
                                                               Zinc
                               Asbestos  Phosphate
    IX
  Ari zona
  Cal i form* a
  Nevada

    X
  Alaska
  Idaho
  Washington

TOTAL NUMBER
OF MINES
                        20(68)
 4(<1)
16(2)
45(56)
                                   8(3)
                                              1(4)
 1(1)
10(14)
                                         11(55)
                                                                                       1(3)
2(75)
                                           5(11)
                        25(100)  117b(100)   20(100)    7(100)   2C(100)      51(100)    100(100)     12(100)  3(100)    32(100)
(£)
    a Numbers in parentheses represent the percentage of primary  product production.   Percentages may  not  add  to 100
      because of rounding.
    " Excludes placer operations.
    c 1982 data.
    Source:  Charles River Associates 1985,  based on data from BOM.

-------
example, two mines produce 75 percent of all  U.S.  asbestos,  nine mines produce
70 percent of all  iron ore, and seven mines are responsible  for all  lead ore
production.

                     2.3  MINING AND BENEFICIATION WASTES
    In the nonfuel mining industry,  the valuable portion of  the crude ore is a
small fraction of the total volume of material  that must be  handled to obtain
it (Table 2-5).  For example, over 6,900 units  of material must be handled to
obtain one marketable unit of uranium.   The high ratio of "material  handled"
to "marketable product" is due primarily to the low percentage of metal  in the
ore and to the mining methods and processes that must be employed.  As shown
in Table 2-5, no metal  exceeds 5 percent of the crude ore in which it is
embedded, except iron.   Aluminum in metallurgical  bauxite presents a similar
picture.  As high-grade ore reserves continue to dwindle, these percentages
are likely to become even smaller.  The fact that the materials handled
consist largely of waste or unusable materials  distinguishes these mining
industry segments from many other process industries where waste materials
make up a relatively small  portion of the materials processed to produce a
final product.
    Several stages in the production of valuable products from minerals and
ores require the handling of large volumes of material, much of which is
waste.  Overburden and waste rock must be removed to expose  the ore.  The ores
are then extracted (mined) and then transported to a nearby  mill, where they
are beneficiated (concentrated or dressed).  Mining and beneficiation
processes generate four categories of large-volume waste: mine waste,
tailings, dump and heap leach waste, and mine water.
    Mining includes a variety of surface and underground procedures.  Surface
                                       2-10

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               Table 2-5  Ratio  of  Material  Handled  to  Units  of
                  Marketable Metal  and Estimated Percentage
                              of Metals  in  Ore
Mining
industry
segment
Copper
Gold
Iron ore
Lead
Mercury
Molybdenum
Silver
Tungsten
Uranium
Zinc
Ratio of material
handled to units of
marketable metal a»b
420:1
350,000:1
6:1
19:1
NA
NA
7,500:1
NA
6900:1
27:1
Typical
percentage of
metal in orec
0.6
0.0004
33.0
5.0
0.5
0.2
0.03
0.5
0.15
3.7
NA indicates not available.

a Excludes material  from development and exploration  activities.


Source:  BOM 1983, and ° estimated by Charles River Associates 1985.
                                          2-11

-------
mining methods include quarrying,  and open-pit,  open-cut,  open-cast,  dredging,
and strip mining.  Underground mining creates adits  (horizontal  passages) or
shafts by room-and-pillar, block caving,  timbered stope,  open stope,  and other
methods.  Hydrometallurgical  processes include heap, dump, vat,  and in situ
leach mehods.  (See Appendix D, Glossary,  for a  description of mining
methods.)  The vast majority of nonfuel  ores are mined on the surface.  Only
antimony, lead, and zinc mining are solely underground operations.   As shown
in Table 2-6, the industry segments that employ both methods handled more ore
in surface mines than in below-ground mines (with the exception of silver) in
1982.
    Surface mining generates more waste than underground  mining.  Table 2-7
compares the waste and crude ore handled by the industry  segments that mine
both above and below ground.    (Reliable data were not available for iron
ore.)  As shown, the volume of waste as a percentage of the total amount of
crude ore ranges from 9 to 27 percent for underground mines.  In surface
mining,  the amount of waste ranges from 2 to 10 times the total volume of
crude ore.  Gold surface mining creates nearly 12 times as much waste per unit
of ore as underground gold mining; silver generates 59 times as much.  All
mining methods used by the industry segments covered in this report generate
mine waste.   It  should be emphasized, though, that  the typical percentage of
metal in an  ore  (excluding overburden and waste rock) is usually very low
(from a  few  percent to a  fraction of a percent).
    Mine waste is  the soil or  rock that mining operations generate during the
process  of gaining access to an ore or mineral body, and includes the
overburden (consolidated  or unconsolidated material overlying the mined  area)
from  surface  mines, underground mine development rock (rock  removed while
sinking  shafts,  accessing, or  exploiting  the ore body), and  other waste  rock,
                                        2-12

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            Table  2-6  Percentage of Crude Ore Handled at Surface
                 and Underground Mines in 1982, by Commodity
Mining industry segment           Surface mines          Underground mines
     Metals:

     Antimony                          —                      100.0
     Bauxite (aluminum)               100.0
     Beryllium                        100.0
     Copper                            87.6                     12.4
     Gold3                             92.0                      8.0
     Iron ore                          98.9                      1.1
     Lead                              —                      100.0
     Mercury                          100.0
     Molybdenum                       100.0b                     W
     Nickel                           100.0
     Rare earth metals                100.0
     Silver                            36.0                     64.0
     Titanium                         100.0
     Tungsten                          W                       100.0C
     Uranium                           68.8                     31.2
     Vanadium                         100.0
     Zinc                              -                      100.0

          Average percent mined        69.7                     30.4

     Nonmetal s:

     Asbestos                         100.0
     Phosphate rock                   100.Ob                    —
          Average  percent mined       100.0                      0

     Average  percent mined,
       metals and  nonmetal s            72.8                     27.2
 W  indicates  information withheld  by Bureau of Mines to protect confidential
   business information.
 a  Excludes placer  operations.
 b  Includes underground operations; the  Bureau of Mines does not publish
   these  data separately.
 c  Includes surface operations;  the Bureau of Mines does not publish these
   data separately.

 Source:   Adapted from BOM 1983.
                                            2-13

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            Table 2-7  Material Handled at Surface and Underground
                 Mines in 1982,  for Selected  Industry  Segments
                         (in  thousands  of  metric  tons)
Mining
industry
segment
Copper
Gold
Silver
Uranium

Crude
ore
156,004
21,768
2,186
6,848
Surface
Waste
321,985
48,797
19,319
72,197
Underground
Waste/
crude ore
ratio
2.06
2.24
8.84
10.54
Crude
ore
22,040
1,896
3,891
3,111
Waste
1,968
369
584
848
Waste/
crude ore
ratio
0.09
0.19
0.15
0.27
Source:  Adapted from BOM 1983.
                                     2-14

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including the rock interbedded with the ore  or mineral  body.   The  particle
size of mine waste ranges from small  clay particles  (0.002 mm diameter)  to
boulders (0.3 m diameter).   Mine waste piles cover areas ranging from 2  to  240
hectares, with a mean area of 51 hectares (1 hectare equals 2.471  acres),
according to a U.S. Bureau of Mines (BOM) survey of 456 waste piles  in the
copper, lead, zinc, gold, silver, and phosphate industry segments.
    After the ore is mined, the first step in beneficiation is generally
grinding and crushing.  The crushed ores are then concentrated to free the
valuable mineral and metal  particles (termed values) from the matrix of less
valuable rock (called gangue).  Beneficiation processes include physical/
chemical separation techniques such as gravity concentration, magnetic
separation, electrostatic separation, flotation, ion exchange, solvent
                                                            g
extraction, electrowinning, precipitation, and amalgamation.   The choice  of
beneficiation process depends on properties of the metal or mineral  ore and
                                              *
the gangue, the properties of other minerals or metals in the same ore,  and
the relative costs of alternative methods.  All processes generate tailings,
another type of waste.
    Tailings are the waste materials remaining after physical or chemical
beneficiation operations remove the valuable constituents from the ore.
Tailings generally leave the mill as a slurry, consisting of 50 to 70 percent
(by weight) liquid mill effluent and 30 to 50 percent solids (clay,  silt,  and
sand-sized particles).
    More than half of all mine tailings are disposed of in tailings  ponds.
Use of  tailings ponds is the primary method by which wastewater is treated in
the metals ore mining segment.  Also, settling ponds are typically used at
mineral mining and processing operations.  Pond size and design vary by
industry segment and mine location.  Some copper tailings ponds in the
                                       2-15

-------
southwest cover 240 to 400 hectares (one exceeds 2,000 hectares),  while some
small lead/zinc tailings ponds cover less than 1  hectare.   Based on a BOM
survey of 145 tailings ponds in the copper, lead, zinc,  gold,  silver, and
phosphate industries, the average size of these ponds is approximately 200
         9
hectares.   Many facilities use several  ponds in series, which improves
treatment efficiency.  Multiple-pond systems offer other advantages as well,
as the tailings themselves are often used to construct dams and dikes.
    Technological  advances since the turn of the century have  made it
economically feasible to beneficiate ore taken from lower-grade ore deposits
(i.e., those with a much lower material-to-waste ratio).    For example,
froth flotation beneficiation processes  have had a tremendous  effect on mine
production and on the amount and type of mine waste generated.  Not only have
these advances increased mining production, but the volume of  waste generated
also has risen dramatically.   The tailings from froth flotation operations are
generally alkaline, because the froth flotation process  is most efficient at a
higher pH.  The metals in the alkaline tailing solids are  therefore often
immobile, unless the conditions in the solids change over  time.
    Dump leaching,  heap leaching and in  situ leaching are  other processes used
to extract metals from low-grade ore.   In dump leaching, the material  to  be
leached is placed directly on the ground.  Acid is applied,  generally by
spraying, although  many sulfide ores will generate acid  during wetting.   As
the liquid percolates through the ore,  it leaches out metals,  a process that
may take years or decades.  The leachate, "pregnant" with  the  valuable metals,
is collected at the base of the pile and subjected to further  processing  to
recover the metal.   Dump leach piles often cover hundreds  of hectares, rise to
60 meters or more,  and contain tens of millions of metric  tons of  low-grade
ore (overburden), which becomes waste after leaching.  The dump leach site is
                                       2-16

-------
often selected to take advantage of impermeable  surfaces  and  to utilize the
natural slope of ridges and valleys for the  collection  of pregnant  leach
solutions.  Loss of leach solution is kept to  a  minimum in order  to maximize
metal recovery.
    Heap leaching operations are much smaller  than  dump leach operations,
generally employ a relatively impermeable pad  under the leach material  to
maximize recovery of the leachate, and usually take place over a  period of
months rather than years.   Heap leaching is generally  used for ores  of higher
grade or value.  For gold ore, a cyanide solution is used as a leaching
solution, rather than acid.  When leaching no  longer produces economically
attractive quantities of valuable metals, and  the sites are no longer in use,
the spent ore is often left in place or nearby without  further treatment.
    In situ leaching is employed in shattered or broken ore bodies  on the
surface or in old underground workings.  Leach solution is applied  either by
piping or by percolation through overburden.  Leach solution is then  pumped
from collection sumps to a metal recovery or precipitation facility.   In situ
leaching is most economical when the ore body  is surrounded by an impervious
layer, which minimizes loss of leach solutions.   However, when water  is
sufficient as a leach solution, in situ leaching is economical even in
pervious strata.
    Leaching processes are used most often in  gold (cyanide leach), uranium
(water leach in situ), and copper operations (sulfuric  acid).
    The final waste type, mine water, is water that infiltrates  a mine and
must be removed to facilitate mining.  The quantity and quality  of the mine
water  handled varies  from mine to mine; quantities may range from zero to
thousands of liters per  ton of ore mined.  The number of mine water ponds at
mine sites in the industry segments covered in this report is usually between
       j   .  11
one and six.
                                       2-17

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                             2.4  WASTE  QUANTITIES
    Table 2-8 presents an estimate of the cumulative amount of tailings and
mine waste generated by the mining and beneficiation of metallic ores,
phosphate rock, and asbestos from 1910 through 1981.  As shown, nearly
49 billion metric tons of waste have been generated by the mining and
beneficiation of eight metals and two nonmetals.  Copper, iron ore, and
phosphate rock have produced over 85 percent of the total volume of waste.
    Mining and beneficiating nonfuel ores and minerals generated approximately
                                           12
2,000 million metric tons of waste in 1980.     The waste handled in the U.S.
mining industry declined to 1,300 million metric tons for the industry as a
whole in 1982.    The industry segments covered in this report are
responsible for more than 90 percent of this nonfuel mining waste.   The 1980
and 1982 estimated waste volumes for each segment are shown in Table 2-9.  The
copper mining segment alone generates approximately half of the waste produced
by the metal  mining segments, and one-third of the total waste.  The phosphate
mining industry is responsible for almost all  waste from the nonmetal  mining
segments, and more than 25 percent of all mining waste discussed.  Iron ore
and uranium mining also generate large volumes of waste.
    The waste for each mining segment is broken out by waste type for 1980 and
1982 in Tables 2-10 and 2-11, respectively.   (Mine water quantities are
variable and difficult to estimate accurately, and are not shown on these
tables.)  The waste tonnages shown in Tables 2-10 and 2-11  are estimates based
on primary production data.  Over half of all  mining waste generated in these
years was mine waste, and tailings accounted for slightly less than one-third
of the total  amount of waste.
    The phosphate rock, uranium, copper, and iron ore mining segments were, in
that order,  the largest generators of mine waste in 1980, accounting for over
                                       2-18

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                  Table 2-8  Estimated Cumulative  Mine Waste
            and Tailings Generated by the Mining and  Beneficiation
                of Metallic Ores,  Phosphate  Rock and  Asbestos,
                  1910  Through 1981  (millions of metric tons)
    Mining
    industry
    segment
Tailings
Mine waste
Total waste
    Metals:

    Copper
    Gold
    Iron ore
    Lead
    Molybdenum
    Silver
    Uranium
    Zinc

    Nonmetals;

    Phosphate rock
    Asbestos

    TOTAL
   ,900
    350
   ,000
    480
    500
     50
    180
    730
   2,200
      40
  14,430
  17,000
     400
   8,500
      50
     370
      30
   2,000
      70
   5,500
  	30

  33,950
   23,900
      750
   11,500
      530
      870
       80
    2,180
      800
    7,700
  	70

   48,380
Source:  Estimated by Charles River Associates  1985,  based on  Coppa  1984,  BOM
         various years,  and BOM 1980a.
                                     2-19

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         Table 2-9  Estimated Volume of Waste Generated by the Mining
                 and  Beneficiation of Metallic Ores, Asbestos,
              Phosphate  Rock, and Overburden  From Uranium  Mining3
                        (millions of metric tons/year)
         Mining industry segment              1980               1982


         Metals;

         Copper
         Goldb
         Iron ore
         Lead
         Molybdenum
         Si 1ver
         Uranium (mine waste only)
         Zincc
         Other metalsd

               Subtotal                      1,514                926

         Monmetal s:
Asbestos
Phosphate rock
Subtotal
TOTAL
7
500
507
2,021
6
403
409
1,335
a Excludes mine water.
b Excludes placer operations.
c About 4 million metric tons of saleable products are extracted before
  tailings disposal.
d Includes antimony, bauxite, beryllium, manganiferous ore, mercury,
  platinum, rare earth metals, tin,  tungsten, and vanadium.

Source:  Estimated by Charles River Associates 1985 based on BOM 1981 a and
         1983.
                                       2-20

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        Table 2-10  Estimated Volume of Waste Generated by  the Mining
             and Beneficiation of Metallic Ores,  Phosphate  Rock,
             Asbestos, and Overburden  from Uranium Mining in  1980a
                           (millions  of metric tons)
Mining
industry
segment
Metals:
Copper
Gold*>
Iron ore
Lead
Molybdenum
Silver
Uranium
Zinc
Other metal sd
Subtotal
Nonmetals:
Asbestos
Phosphate rock
Subtotal
TOTAL

Mine waste

282
25
200
1
15
10
298
1
24
856

5
348
353
1,209
Waste
Tailings

241
10
150
10
31
3
NA
5C
5
455

2
152
154
609
production
Dump and
heap leach
wastes

200 (Dump)
3 (Heap)
--
--
—

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        Table 2-11  Estimated Volume of Waste Generated by the Mining
              and Beneficiation  of  Metallic  Ores,  Phosphate  Rock,
             Asbestos,  and  Overburden  from Uranium Mining  in 1982a
                           (millions of metric  tons)
                                         Waste production
Mining
industry
segment
Dump and
heap leach
Mine waste Tailings wastes


Total
Metals:

Copper
Goldb
Iron ore
Lead
Molybdenum
Si 1ver
Urani urn
Zinc
Other metal sd

      Subtotal

Nonmetals:
408
               178
                24
                75
                 9
                 6
                 6
                NA
307
               200 (Dump)
                11 (Heap)
                
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93 percent of the total  in that category.   These  four  segments were  also  the
largest generators of mine waste in 1982,  generating nearly  84  percent  of the
total.
    More than 89 percent of tailings wastes were  generated by copper, iron
ore, and phosphate rock  production in 1980; this  percentage  was almost  87
percent in 1982.  Dump and heap leaching are confined  to the copper,  silver,
and gold segments.  The  gold segment generated less than 2 percent of all
leaching waste in 1980,  but this increased to more than 5 percent in 1982.
This twofold rise in the volume of gold leaching  waste was caused by an
increase in the use of the heap leaching method in this segment, a trend  that
is likely to continue because of the increased value of the  gold and the
decline in prices of many other metal commodities.
    The wastes generated by the nonfuel mining industry are  generally disposed
of on site, and thus the geographic distribution  of active mining waste
management sites corresponds closely to the distribution of  mine sites.
Transportation or treatment of these wastes beyond that practiced in
connection with wastewater treatment and disposal  is not commonly practiced in
most segments.  Accordingly, the principal mining states, i.e., Arizona
(copper), Minnesota (iron ore), New Mexico and Wyoming (uranium), and Florida
(phosphate rock), are the states that produce the majority of all mining
waste.

                                 2.5  SUMMARY
    The major categories of waste are mine waste  and mine water from mining
operations, dump and heap leach wastes from leaching operations, and mill
tailings from the beneficiation (concentration) of ores.  In situ leaching of
rock or in mines is performed in place.  Annual waste  generation totaled  2
                                       2-23

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billion metric tons in 1980 and  1.0 billion metric  tons  in  1982 for the metal
mining segments and the phosphate  and asbestos  mining  industries.  Several
mining segments are geographically restricted:  lead  (100 percent  in
Missouri); molybdenum (100 percent in Colorado);  asbestos (75 percent  in
California); phosphate (74 percent in Florida); iron  (70 percent in
Minnesota); and copper (68 percent in Arizona).   In both 1980 and  1982, the
three segments generating the largest amounts of  waste were copper, phosphate,
and iron.
                                       2-24

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                             SECTION 2 FOOTNOTES
 1  BOM 1983.
 2 BOM 1983.
 3 U.S.  Department of  Commerce  1985.
 4 All mines  are not censused every year.  Other mines in the nonmetals
   industry segments include abrasives, asphalt, barite, boron minerals,
   diatomite, feldspar,  fluorspar, graphite, greensand marl, gypsum, kyanite,
   lime, mica (scrap), perlite,  potassium salts, pumice, salt, sodium
   carbonate, stone, sulfur, talc, vermiculite, and wollastonite.  Clay
   and sand and gravel mines accounted  for approximately 95 percent of all
   nonmetal mines in 1982.
 5 BOM 1981 a.
 6 See also US EPA 1982a.
 7 Mountain States Research and Development, Inc. 1981.
 8 Mining and beneficiation methods  are discussed in detail in EPA's final
   Development Document  for Effluent  Limitations Guidelines and Standards for
   the Ore Mining and  Dressing  Point  Source Category.
 9 BOM 1981b.
10 Martin and Mills 1976.
11  PEDCo Environmental,  Inc. 1984.
12 Charles River Associates 1984a, based on BOM 1981a.
13 BOM 1984.
14 Charles River Associates 1985a.
                                       2-25

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                                   SECTION 3
                    MANAGEMENT PRACTICES FOR MINING WASTES

             3.1  OVERVIEW OF THE MINING WASTE MANAGEMENT PROCESS
    Mine waste, tailings, heap and dump leach waste, and mine water can be
managed in a variety of ways.  Figure 3-1 provides an overview of the mining
waste management process.  As shown in the figure, mine waste may be used on
or off site, disposed of in mine waste piles, or used in leach operations to
recover additional valuable constituents from the ore.  Similarly, tailings
may be used on or off site, disposed of in tailings ponds,  or used in leach
operations to recover valuable constituents in the tailings that are still
present after milling processes have been completed.  Tailings also may
contain residues of the reagents used in flotation processes.  These reagents
include forms of cyanide (used in the leaching of gold and silver and in the
separation of sulfide minerals), sulfuric acid used and formed in copper dump
leaching, and various organic and inorganic compounds used in copper, lead and
               2
zinc flotation.
    Mine water may be discharged to surface streams {often after treatment)
via National Pollutant Discharge Elimination System (NPDES) permitted
outfalls, used as milling process makeup water (recycled), or used on site for
other purposes (e.g., dust control, drilling fluids, sluicing solids back to
the mine as backfill, etc.).
    The recovery of valuable constituents from mine water (e.g., Ix treatment
for uranium), from mill  process solids, or from extraction from dump leach
liquors could possibly be considered to be waste treatment processes, in that
                                       3-1

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                                                                   RECYCLE
  NPDES
PERMITTED
DISCHARGE
  OTHER
  ONSITE
UTILIZATION
      I   WATER    I
MINE
X
1
1
r

. V
BACKFILL
                         OFFSITE
                       UTILIZATION
                                                                        RECOVERY
                                                                         (LEACH
                                                                       OPERATIONS)
                                             Figure 3-1  The mining waste management process

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such recovery extracts metals or constituents that would otherwise  be
potentially hazardous or constituents of waste prior to disposal.   However,
the mining industry considers these processes to be extraction or
beneficiation processes because they recover valuable products from materials
that have metal concentrations below those in ore of a grade suitable or
economical for milling and smelting.
    Table 3-1 presents the volumes and percentages of mine waste and tailings
that are currently managed according to the various practices shown in
Figure 3-1 and mentioned above.  The table shows that more than half of all
mine waste and tailings is disposed of in piles and ponds, respectively.
Most onsite utilization of mine waste and tailings involves the dump leaching
of copper mine waste and the use of sand tailings to build tailings
impoundment dams in all industry segments.
    The remainder of this section is divided into three parts.  Section 3.2
describes waste management practices other than actual disposal.  The section
includes a discussion of recovery operations, process changes for waste volume
reduction, waste treatment methods, onsite utilization of mine water, and
offsite use of mine waste and mill tailings.  It shows that although several
alternatives to onsite land disposal of mining industry wastes are available,
their effectiveness in reducing the amount of mining industry wastes is
1 i mi ted.
    Section 3.3 describes some general considerations for locating waste
disposal  sites and specific aspects of waste disposal for tailings, mine
waste, leached material, and mine water.
    Section 3.4 examines the measures that can be used to limit or mitigate
the hazards posed by mining industry wastes that are disposed of on site.
                                       3-3

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                 Table  3-1  Current Waste Management Practices



Waste type
Mine waste




Tailings






Management
practi ce
Pile
Onsite utilization
Backfill
Off site utilization
Total
Ponds
Onsite utilization
Backfill
Off site utilization
Total
Vol ume
(in millions
of metric tons
per year)
569
313a
86
43
1,011
267
141b
21
8C
437

Percent
of waste
generated
56
31
9
4
100
61
32
5
2
100
alncludes dump leach operations and starter dams for tailings
   impoundments.

^Includes the sand fraction used in building tailings
   impoundment dams.

clncludes 4 million metric tons of Tennessee zinc tailings
   sold as construction materials or soil  supplements.

Source:  Charles River Associates 1984a,  based on U.S.  Bureau  of Mines data,
                                       3-4

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These measures are particularly important because most of the large volume of
mining industry wastes will ultimately remain on or near the site.  The
mitigative measures considered are broadly categorized under inspection and
detection measures, liquid control systems, and corrective action measures.

                        3.2  WASTE MANAGEMENT  PRACTICES
    Waste management practices include process modifications for waste or
potential hazard minimization, recovery operations, treatment prior to land
disposal, onsite use of mine water, and offsite use of mine waste and mill
tailings.  Each of these practices is discussed below.
3.2.1  Process Modifications for Waste Minimization
    Although there are no practical means of reducing the volume of solid
waste produced by mining and beneficiation operations, some changes in
beneficiation processes can lead to changes in the chemical  composition of  the
tailings released into tailings impoundments.   For example,  pilot studies have
been conducted in which nontoxic reagents were substituted for cyanide
compounds in the beneficiation of copper ores.  Sodium sulfide and sodium
bisulfide may be used as alternatives to sodium cyanide  (see 47 FR 25693,
June 14, 1982).   Similarly, alkalinity in the  beneficiation  circuits  can be
maintained by reagents less toxic  than ammonia.   Lime is the reagent  of choice
in most instances,  although some scaling has been reported.
    Two copper mills  have circuits separating  pyritic material  from sulfide
ores to improve subsequent copper  recovery.  The pyrites are currently
discharged to the tailings impoundments,  but they could  be segregated.   If
pyrites were not codisposed of with other gangue material, there would be a
reduction in the potential  for acid formation  after closure  of the tailings
impoundment.   However,  the alkaline tailings and pond water  may act to reduce
this potential.

                                       3-5

-------
    The thickened discharge method of tailings  management involves  partially
dewatering the tailings slurry and discharging  it from a  single point.   This
results in a gently sloping, cone-shaped deposit.   The water removed from the
tailings can be treated and discharged or returned to the milling circuit.
The dewatering costs associated with this method are offset by reduced
earthwork costs.   A disadvantage of the thickened discharge technique in some
circumstances is that no water is stored with the tailings, which may mean
that the dewatered slurry piles become sources  of fugitive dust.  The particle
size distribution of the waste and the drying characteristics of the disposal
area are important factors in determining the potential for fugitive dust
emissions.  Earthquake activity may also affect the stability of the dewatered
slurry piles, depending on the location.  The thickened discharge method is
currently used to dispose of sand tailings in the Florida phosphate industry
                                               4 5
segment, and could be applied to other sectors. '
    Biological acid leaching, a new process under development in Canada, may
be a feasible substitute for current dump leaching practices.  Unlike dump
leaching operations, the new process does not convert the sulfur in the ore  to
sulfuric acid; instead, it converts it to elemental sulfur, which is both less
hazardous to the environment and potentially saleable.  The process is still
in the pilot development stage; the economic and technical feasibility of
large-scale operations of this type have not yet been demonstrated.
3.2.2  Recovery  Operations
    Leaching is  a  process used to recover metal values from low-grade ore or
tailings, and is a common practice in  some mining  segments  (i.e., copper,
gold,  silver, and  uranium).  There are  several   types  of leaching operations
practiced,  including in situ, dump,  heap, and  vat  leaching.  Acid solutions
are commonly used  for  leaching in the  copper segment  of the mining  industry.
                                       3-6

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Cyanide solutions are used to leach both gold and silver wastes as well  as
ores.  The precious metals in cyanide leach solutions are removed in the
process, and the partially spent cyanide solution is recycled back to the
process for reuse.  Leaching of phosphate rock and uranium wastes are also
practiced.   In situ leaching in the uranium segment is practiced with water
as the leach solution.
    The purpose of using leaching techniques is to recover valuable metals
from ores that would otherwise be uneconomical  to mine.  In situ and dump
leaching techniques may cause environmental  problems, in that an impermeable
layer is not always placed or located between the low-grade ore and the
surrounding soil, especially at older operations.  However, it is in the
miner's best interest to capture as much of the leachate in order to recover
the metal  values.  The benefits of leaching are improved natural  resource
utilization and increased production of valuable metals such as gold, silver,
and copper.  The drawbacks of leaching, especially dump and in situ leaching,
are that potentially corrosive (low-pH) or toxic (cyanide and/or toxic metals)
products may seep into the ground below these operations.  In ores that would
naturally form acid drainage, leaching operations allow recovery of metals
from ores that would naturally release these metals over a period of time.
    In the copper, gold, and silver industries, technical efficiency and
economic factors have made the recovery of mineral  values by leaching
processes economically feasible.  Overburden, tailings, and other wastes will
continue to be "remined" in the future, if extraction efficiencies continue to
improve and if product prices exceed extraction costs.
                                       3-7

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    Techniques other than leaching have been developed to recover valuable
constituents from mine and mill  wastes.  Flotation can be used with copper
                                                          g
mine waste, taconite (iron) tailings,  and zinc mine waste.
    Pilot-scale research projects have also shown that it is technically
feasible to use a high gradient magnetic separation process to produce an
anorthosite concentrate, assaying at more than 28 percent alumina (Al20.j),
from copper tailings.  However, this has not proved economically competitive
                                                        g
with alumina produced from bauxite by the Bayer process.
3.2.3  Waste Treatment
    Various oxidation systems have been developed to destroy cyanide compounds
prior to discharge; however, most of the cyanide in cyanide leach processes is
recycled back to the process for reuse.  One system uses sodium hypochlorite
and sodium hydroxide; another uses chlorine and sodium hydroxide.    Other
processes have been used,  including hydrogen peroxide oxidation, potassium
permanganate, and chlorine dioxide.  Destroying the cyanide used to leach
metals may be feasible,  using the new  peroxide-thiosulfate process currently
being developed by  the Bureau of Mines (BOM).     In this method, hydrogen
peroxide and  sodium thiosulfate convert  free and weakly complexed cyanide to
thiocyanate.  After the  remaining complexed cyanide is precipitated and
flocculated,  the  solution  is filtered.   Copper,  iron, and  other  base metals
associated with the gold and silver ore  are removed along with the cyanide.
However, thiocyanates have been  shown  to have  latent  toxic effects on  fish;
 thiocyanate  apparently  accumulates  in  fish, only to be released  in lethal form
                           12
when  the fish are stressed.
     Cyanide  levels  in froth  flotation  wastewater are  generally low, and  are
 the result of using cyanide  to  depress pyrites in the circuit.   Ultraviolet
 radiation  (from the sun) and simple aeration  are often adequate  to reduce the
 cyanide levels to detection  levels.

                                        3-8

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    Neutralization is a technically feasible method of treating corrosive
acidic wastes.  Chemical  agents commonly used for this purpose include
quicklime, limestone, hydrated or slaked lime,  caustic soda,  soda ash, and
                 13
hydrated ammonia.
    The Effluent Limitations Guidelines and New Source Performance Standards
for the ore mining and dressing point source category endorse the use of lime
to maintain discharges within the 6.0 to 9.0 pH range.  In fact, the permit
issuer may allow the pH level in the final  effluent to exceed 9.0 slightly, if
that is required to meet discharge limitations for copper, lead, zinc,
mercury, and cadmium.
    Treatment of acidified mine waste or tailings is often a necessary
prerequisite for revegetation.  Hydrated lime or quicklime is used to increase
the pH to 9.0 rapidly.  For a slower but longer-lasting response, agricultural
lime (limestone) is used.  The lime is added in quantities great enough to
neutralize the sulfuric acid that will be released by the future oxidation of
                                           14
pyritic material in the mine or mill waste.
3.2.4  Onsite Use of Mine Water
    Water generated by mine dewatering may be used in the milling process as
makeup water (treatment may or may not be required), or used on site for dust
control, sluicing solids to the mine as backfill or in cooling or drilling
fluids.  Depending on the water balance at a facility, managing the mine water
may involve a combination of these uses.  A large number of mining and
beneficiation operations use mine water in the mill.  In some cases, all of
the water required by the mill operation is obtained from mine drainage, which
eliminates the need for wells and a mine water treatment system, or greatly
reduces the volume of mine water discharged.  Using mine water containing
                                       3-9

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relatively high concentrations of soluble metals for beneficiation makeup
water is an effective treatment practice, because flotation circuits, which
are typically alkaline, reduce the solubility of metals and thereby facilitate
their recovery.  In most cases, however, not all of the mine water is used in
the beneficiating operations, because operators have little or no control over
the quantity of water that infiltrates the mine.  The unused portion of the
mine water is generally stored in impoundments and discharged after treatment,
in accordance with the provisions of an NPDES permit.
3.2.5  Offsite Use of Mine Waste and Mill Tailings
    Waste utilization practices include agricultural  lime replacement, road
and building construction, and the production of bricks, ceramics, and
wallboard.  These methods are discussed below and summarized in Table 3-2.
    The most widespread use for these wastes is in the production of concrete
and bituminous aggregates for road construction.  Other applications in road
construction include the use of these wastes in road bases, as embankments,
and to make antiskid surfaces.  Approximately 50 percent of the zinc tailings
in Tennessee are sold for aggregate production.
    Tennessee zinc tailings also may be used as a substitute for mortar or
agricultural limestone; nearly 40 percent of these tailings are sold for these
purposes.  Tailings from mills processing zinc ores in New York and the Rocky
Mountain states are not suitable as soil supplements, because these tailings
have lower concentrations of calcium carbonate and higher concentrations of
lead and cadmium.  Similar concerns constrain the use of lead tailings in
Missouri.16
    Tailings from asbestos and molybdenum mining operations have been used in
asphalt mixes for roads and parking lots.  Phosphate, gold, and silver
                                       3-10

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                                        Table 3-2  Uses of Mine Waste and Tailings
Use Asbestos
Material Use
Soil Supplement
Wall Board Production 3
Brick/Block Production 1
Ceramic Products
Anti-Skid Aggregate
Embankments
General Aggregate
Fill or Pavement Base
Asphalt Aggregate 2
Concrete Aggregate
Gold &
Copper silver



1 1


3 3
3
3 3

3
Iron ore/
taconi te



1

3
3
3
3
3
3
Lead Molybdenum






3
3
3
3 3
3
Phosphate




1
1




1
Uranium Zinc

1







1 3
3
•_,   Development Stage

    1.   Bench-scale research  project
    2.   Full-scale demonstration  project
    3.   Full-scale, sporadically  practiced
    Source:   Based on Seitter and  Hunt  1982.

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tailings of sand and gravel  size have been mixed with cement to form concrete
for use in road construction.   Lead,  zinc, and iron  ore tailings have been
used for both concrete and bituminous aggregates.  Mixtures of crushed waste
rock, including waste material  from copper, iron ore, lead, gold, and silver
mines, have become embankments, fills, or pavement bases for many highways.
Topsoil must be deposited over fills and embankments made with these materials
to control erosion and permit the growth of vegetation.  Taconite tailings
have proved valuable as thin (less than 25 mm) road  surface overlays, because
they greatly enhance skid resistance.
    The use of tailings to produce bricks, blocks, and ceramic products has
not yet passed the bench-scale research stage.  Copper mill tailings can be
used in brick production if pyrites are first removed.  Lightweight blocks
made from taconite tailings have good structural characteristics but have not
been marketed.
    The most important constraints on the use of mining wastes are imposed by
energy, economic, and logistic considerations.  Material/metal recovery from
mining wastes is economically attractive only when the price of the material
recovered exceeds the costs of extraction.  In recent years, mine product
prices have been generally depressed, and extraction costs, especially
energy-related costs, have risen.  Similarly, using mining wastes to produce
bricks or to construct roads is affected by such market constraints as
transportation costs and competition with other sources located nearer to
potential users.    Mining wastes, therefore, are competitive only when they
can be marketed or  used  in the geographical area close  to  the originating mine.
     Uses  of mining  wastes do not and will  not keep  pace with  the approximately
1  to  2 billion metric tons of  these wastes that may be  generated each year.
Long-term management of  mining waste disposal sites will continue to be
                                       3-12

-------
necessary for the foreseeable future.  However, research on the cost-effective
utilization of mining wastes is justified, because any new use that becomes
widely practiced will help reduce the magnitude of the mining waste disposal
problem.

                    3.3  WASTE SITING AND DISPOSAL METHODS
    For technical and economic reasons, most mining waste is finally disposed
of on the land.  The primary considerations for locating a waste disposal area
are discussed below.  Specific waste disposal  methods for mining wastes are
also described.
3.3.1  Location and Siting
    The topography, geography, and hydrogeology and, in some cases,
meteorology, as well as population density of the geographical area in which a
mine is located, affect the siting of the waste disposal area, the extent to
which mitigative practices are required, and the types of mitigative systems
that can be selected.  The extent of the ore body, the quantity of waste to be
generated, and the method of mining are also considered when siting a disposal
area.
    Owners and operators of mines built before 1970 generally located waste
sites at the shortest and most easily traversed distance from the mine or
mill, usually in a ravine or gully.  Owners and operators of mines constructed
since 1970 (when Federal and state environmental regulation greatly increased)
have also considered the potential pollution problems associated with
particular sites, such as siltation of surface waters, production of fugitive
dust emissions, and contamination of ground water.  Disposal locations chosen
based on these considerations may have small upgradient drainage areas to
                                       3-13

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reduce erosion potential, or may be underlain by impermeable strata to
minimize percolation into ground water.
3.3.2  Waste Disposal Methods for Tailings
                                                                       18
    Waste disposal methods for tailings include:  tailings ponds, stope
backfilling, below-grade disposal, and offshore disposal.  As was shown in
Table 3-1, more than half of the tailings are disposed of in tailings ponds.
The size and design of the ponds vary widely by industry segment and
location.  Tailings disposal methods are discussed below.
    (1)  Tailings Impoundments.   Tailings impoundments have been used at ore
mills in the United States since the early 1900s.   In recent years, they have
become increasingly important and may account for as much as 20 percent of the
                                         1 g
construction cost of a mine/mill  project.    Some ore bodies may not be
exploited, because suitable sites for tailings disposal  are not available
within a practical distance.
    Tailings impoundments may serve several  purposes.  They retain water,
making it available for recycling to the mill  flotation  circuits and other
processes requiring water.  They act as equilization basins, which assist in
wastewater treatment process control and reagent addition control.  They also
protect the quality of surface waterways by preventing the release of
suspended solids and dissolved chemicals.  In  fact,  tailings impoundments in
arid regions may permit a mill to achieve "zero discharge," eliminating the
need for a point source discharge permit.
    The design and construction  of a tailings  impoundment reflect the
characteristics of the ore,  the  mine/mill, and the environment,  especially the
local  topography.   Three methods of dam building are commonly used:
downstream, upstream, and centerline.   Figure  3-2  depicts these  methods.
                                       3-14

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                      UPSTREAM METHOD
      PERIPHERAL TAILINGS
      SPIGOT OR CYCLONE
                      PERIMETER DIKES
                      (NATURAL SOILS OR TAILINGS)
            POND WATER
                 TAILINGS


                          STARTER DIKE
                          (NATURAL SOILS)

                     DOWNSTREAM METHOD
      IMPERVIOUS CORE
      (OPTIONAL)

      TAILINGS OR
      WATER
       STARTER DIKE
       (NATURAL SOILS)
                       RAISES (NATURAL SOILS,
                       TAILINGS, OR MINE WASTE)
                      DRAIN
                      (OPTIONAL)
                     CENTERLINE METHOD
PERIPHERAL TAILINGS
SPIGOT OR CYCLONE
 TAILINGS
                             IMPERVIOUS CARE (OPTIONAL)

                             RAISES (NATURAL SOILS,
                             TAILINGS, OR MINE WASTE)

        STARTER DIKE
        (NATURAL SOILS)
                                          DRAIN
                                          (OPTIONAL)
Source: Vick 1981
          Figure 3-2  Tailings dam construction methods
                             3-15

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A common element in all  three types is that they  are  usually  raised
sequentially as the level  of tailings and/or effluent in the  impoundment
rises, in order to distribute construction costs  more evenly  over the life of
             20
the facility.
    With the downstream construction method, the  embankment building material
is added successively to the downstream side of the previously placed
embankment, and the crest thus moves downstream.   This system is costly but is
compatible with any type of tailings and can be used for water storage.  The
upstream method is less costly but is not well  suited to large inflows and
water storage.  The centerline method involves  raising the dam in steps, with
                                                            21
the centerline of the crest remaining above the starter dam.
    The starter dam or dike is typically built  with natural soils, but mine
waste can also be used.  Subsequent increments  are added from the coarse,
sandy fraction of the tailings.  This use of tailings constitutes the largest
component of the 141 million metric tons of onsite utilization of tailings
shown in Table 3-1.  Installation of internal filters and drains lowers the
water level within  the sand dam and reduces the danger of overtopping,
                                                                22
instability, or breaks induced by seismic (earthquake) activity.    Other
protective measures include reduction of the catchment area by maintaining
diversion ditches around the  impoundment and careful control  of water inflow
                                                                23
and outflow to allow for seasonal and mill operation variations.     In
summary, many tailings ponds  and impoundments require some degree of  seepage
to maintain  their structural  integrity.
    Upstream embankments are widely used by the copper industry in the
southwest.   Earthquake activity and high precipitation along  the West Coast
have  fostered use of downstream and centerline dams.  Downstream dams are  also
favored  by  the lead industry  in Missouri and the phosphate industry  in  Florida.
                                       3-16

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     (2)  Stope Backfilling.  This method, also referred to as sandfilling,
involves converting a portion of the coarse fraction of tailings into a slurry
and  then injecting the slurry into the mined-out portions of stopes.  Stope
backfilling is currently practiced or is being considered as a method of
disposing of such diverse materials as copper tailings, spent shale from oil
                                                                        24
shale retorts, and tailings from Wyoming trona (sodium carbonate) mines.
     The major disadvantages of stope backfilling are the introduction of
additional water into the mine, which results in occasional  spills of
tailings, and the importation of supplemental waste material  to make tailings
embankments when too much coarse fraction has been removed from the tailings.
The  primary drawback to backfilling with fines (materials with small particle
sizes) is the risk of poor drainage of the backfill  material.  In addition,
although no supporting monitoring data are available, backfilling of tailings
into underground mines may have an adverse impact on ground-water quality.
For  example, metals or other constituents may leach from the coarse tailings
and  reach the ground water when seepage from the backfilled  stopes
       25
occurs.    This possibility increases when the coarse tailings contain
pyrites, which generate sulfuric acid that decreases pH and  increases the
solubility of most toxic metals.
    Stope backfilling as a tailings management alternative is not used on a
national scale, because most of the industry segments covered in this report
excavate their ores using surface mining techniques.
     (3)  Below-Grade Disposal.   This method of tailings disposal  consists of
placing tailings in an excavated pit (in lieu of above-grade  impoundments) so
that at closure, the entire deposit is below the level  of the original  land
surface.  This method currently is unique to the uranium industry,  which uses
                                       3-17

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it to reduce the likelihood of erosion.  The embankments of conventional
above-grade surface impoundments are subject to erosion and failure that could
result in the release of tailings to the downgradient area.  Below-grade
disposal avoids both of these potential problems.   This disposal  method is
                                         26 27
costly unless mined-out pits can be used.   '    This method could be used
for operations involving open-pit mining if a series of mined-out pits is
available to receive mill  tailings (or retorted shale).
    (4)  Offshore Disposal.  In the past,  offshore disposal has been a
euphemism for dumping tailings into a large lake or the ocean without regard
for environmental  consequences.  Recently, more responsible proposals have
shown that if the tailings are chemically  innocuous, are sufficiently coarse
to settle rapidly with a minimum amount of turbidity, and are piped to
deep-water areas to avoid the most biologically productive nearshore zones,
offshore disposal  may have reasonably small environmental  impacts in certain
specific cases.  Even so,  offshore disposal is not a widely accepted
alternative within regulatory agencies in  the United States and Canada, and
few mines have been located near the ocean in the  past.  Technical  arguments
notwithstanding, recent experience indicates that most developed countries
                                               28
will  not approve offshore disposal of tailings.
3.3.3  Waste Disposal  Methods for Mine Waste
    As was shown in Table 3-1, an estimated 56 percent of the mine waste
removed to gain access to an ore body is disposed  of in mine waste piles near
or adjacent to the mine.  The overburden from open pit mines is usually
discarded on the outside slopes of the pit.  Approximately 9 percent of the
mine  waste is disposed of  as part of the normal mining practice of immediately
backfilling previously excavated areas; the trend  in the mining industry is
                                       3-18

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toward increasing this percentage.   In surface mining,  however,  backfilling  is
only used when the overburden can be placed into adjacent areas  that have been
excavated.  With some underground mining methods, waste rock is  backfilled
into previously mined sections as it is excavated, which eliminates the time
and expense of hauling the material  to the surface for  stockpiling.  These
mining methods include cut-and-fill  stoping and square-set stoping.  These
methods provide structural stability to the mined areas, in addition to
                                     29
serving as a means of waste disposal.
3.3.4  Waste Disposal Methods for Dump Leach/Heap Leach Material
    Whether or not active dump leach and heap leach operations are considered
to be process operations rather than solid waste disposal practices, solid
waste material remains after the completion of these operations.  The current
practice  is to transport overburden and low-grade copper ore for dump leach
processes  (or waste and low-grade precious metal ore for heap leach
operations) to leaching beds, where the dumped material is spread by
bulldozers.  Equipment travel on the leach dump compacts the top layer of the
material;  this layer  is then scarified to facilitate infiltration of the leach
solution.  This process of layering and subsequent scarifying of the leach
dump may  continue for 50 years or more.    The leached waste material is not
removed from the site of the operation, due to the immense size of these piles.
3.3.5  Waste Disposal Methods for Mine Water
    Water produced from mine dewatering may be discharged directly or
indirectly (after treatment such as settling) to a surface stream, used in the
milling process as makeup water  (treatment may or may  not be required), pumped
to a  tailings pond,  or used on site for dust control,  cooling,  or as drilling
fluids, etc.  (see Section 3.2.4).  Depending on  the water balance of the
                                       3-19

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particular mine facility, mine water management may involve one or a
combination of these methods.
    Treatment of mine water in onsite impoundments is the management practice
used when discharge or total  recycling are not possible.   Such treatments
include simple settling, precipitation, the addition of coagulants and
flocculants, or the removal of certain species (e.g., radium-226 removal by
coprecipi tation with barium chloride in mine water ponds in the uranium
industry).  Most mine water ponds are relatively small, shallow, excavated,
unlined impoundments.  The number of impoundments and their size depends on
the volume of mine water handled and the treatment methods used.  Larger
impoundments or several impoundments in series are used to provide sufficient
retention time for effective treatment.  Discharge from mine water treatment
                                                                    31
ponds is usually to a surface stream via an NPDES-permitted outfall.

               3.4  MITIGATIVE MEASURES FOR LAND DISPOSAL SITES
    Even if greater use is made of waste utilization and alternative waste
disposal methods, the greatest portion of mining wastes will still be disposed
of in land disposal facilities such as waste piles, tailings ponds, and
settling impoundments.  However, various measures are available to detect or
mitigate the problems associated with the land disposal of mining wastes.
These measures may be classified into four general types:
    1.   Detection and inspection measures determine whether problems are
         developing.  These activities include ground-water monitoring  and
         visual inspection of other systems, erosion control,  dam stability,
         and runoff control.
                                        3-20

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    2.   Liquid control measures control  the potential  for liquid to come into
         contact with mining waste, and thus minimize surface water pollution
         and the amount of liquid available for leachate formation.
    3.   Containment systems prevent leachate from entering the ground water
         and posing a threat to human health and the environment.   Two types
         of containment systems are considered here:  containment systems
         designed to prevent leachate from entering the ground water (such as
         liners and systems designed to control plumes of contaminated ground
         water) and corrective action measures.
    4.   Security systems prevent entry to the waste management area by
         animals or by unauthorized persons.  These systems protect the
         general public and prevent activities that might damage onsite
         control systems.
    The waste management measures that are most relevant to individual  waste
management sites depend, in part, on the  operational phase of the waste
management site.  Three operational phases are distinguished here:
    1.   Active site life is the period during which waste is being  added to
         the disposal  site.  A disposal  site may be closed even though the
         mine itself remains active.
    2.   Closure is the period immediately following active site life,  in
         which various activities are undertaken to ensure adequate  protection
         of human health and the environment during the post-closure phase,
         and to minimize maintenance activities in the post-closure  phase.
    3.   Post-closure is the period following closure during which  there are
         no further additions of waste to the site.   The main post-closure
         activities are the monitoring of the site for leaks and the
                                       3-21

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         maintenance of liquid control, containment,  and security systems
         established during site life or at the time  of closure.
Corrective action occurs after a plume of contaminated ground water or another
environmental hazard is discovered.   This may occur during active site life,
at the time of closure, or during the post-closure phase.
    The remainder of this section describes various mitigative measures appro-
priate to the management of mining waste during the active life of the site,
the closure period, and the post-closure phase, and discusses appropriate
corrective measures.  Some of the measures described  can be substituted for
each other.  In most cases, the ability of these measures, or combinations of
measures, to limit threats to human health and the environment depends on
specific site conditions; in addition, many of these  measures have yet to be
applied in the mining waste context.   The discussion  below describes the
purposes and limitations of various  management techniques, but data are not
available to allow the efficacy of these techniques to be  quantified.   Table
3-3 shows the various measures discussed in this section,  classified by
operational phase of the site.
    Where possible, EPA has estimated the percentage  of mines in  some industry
segments where the following mitigative measures are  currently used:  ground-
water monitoring, run-on/runoff controls for storm water,  liners  for tailings
ponds, secondary leachate collection  and removal, and closure procedures.   EPA
produced these estimates using the methodology described in Appendix B.
3.4.1  Mitigative Measures During Active Site Life
    During the active life of a waste disposal  facility, waste is continually
being added to the waste material already at the site.   The ongoing nature of
the disposal  process at active sites  makes certain mitigative measures
                                       3-22

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             Table 3-3  Mitigative Measures  by  Stage  of Site  Life
Stage of
site life
Mitigative measure
Purpose
Active
site life
Closure
Hydrogeologic evaluation and
  ground-water monitoring
Run-on/runoff control
Liners
Cutoff walls
Leachate collection, removal,
  and treatment systems
Security systems
                   Continue measures initiated
                     during active site life
                   Wastewater treatment
                   Pond sediment removal
                   Dike stabilization
                   Waste stabilization
                   Installation of leachate
                     collection, removal  and
                     treatment systems at surface
                     impoundments
                   Final  cover
                                                    Detection  of contaminants
                                                    Liquid  control
                                                    Containment
                                                    Containment

                                                    Liquid  control
                                                    Security of control  systems
                                                      and protection of  public
                                                      health
                                 All  purposes mentioned
                                   above
                                 Liquid control
                                 Waste removal
                                 Liquid control
                                 Liquid control
                                 Liquid control
                                 Liquid control
Post-closure
                   Ground-water monitoring
                   Inspect/maintain all
                     existing systems
                                 Detection of contaminants

                                 All  purposes mentioned
                                   above
Corrective
action
                   Interceptor wells
                   Hydraulic barriers
                   Grouting
                   Cutoff walls
                   Collection
                                 Containment
                                 Containment
                                 Containment
                                 Containment
                                 Treatment
Source:  Meridian Research, Inc.  1985.
                                     3-23

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inappropriate for use at such sites.   For example,  methods  such  as  caps  or
covers that are designed to control  the volume of liquids  percolating into the
site cannot be used.   Similarly,  liners and containment  systems  that  underlie
the waste area can most easily be put in place at new facilities.   However,
other mitigative measures, such as those discussed below,  can  be used at
existing active waste disposal  sites.
3.4.1.1  Ground-Water Monitoring  and Hydrogeological  Evaluation
    The objectives of hydrogeological  evaluation  and  ground-water monitoring
at a waste disposal  or tailings pond facility  are (1) to identify potential
pathways of leakage and contaminant transport  by  ground  water;  (2)  to
determine whether contamination of the ground  water has  occurred and,  if so,
the extent of contamination; and  (3) if necessary,  to generate  the  data  needed
to select and implement a mitigative strategy.  At new facilities,  the first
step in this process  is to evaluate the pollution potential  of effluents from
         32
the site.    A thorough hydrogeological evaluation  and ground-water
monitoring program are then conducted to characterize background or natural
conditions at the site.  In some  cases, it may be necessary, prior  to siting
the monitoring wells, to simulate baseline and potential ground-water pathways
                                                 33
by means of hydraulic or solute transport models.    Particularly in  areas
close to dams or dikes, hydrogeological evaluations are  necessary to  determine
probable seepage paths and to establish flow rates to be used  in the  design  of
dikes, cutoff walls,  and liners.   Ground-water monitoring is also an  important
means of evaluating the initial and long-term  effectiveness of the  engineering
and site preparation  measures used at a particular site.
    Depending on the specific characteristics  and requirements of a given
site, monitoring programs range in complexity  from a  simple determination of
                                       3-24

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the presence or absence of a particular waste constituent in  a  few wells  to  an
extensive analysis of many constituents in many wells,  using  well  clusters
                                                                      34  35
open at different depths, aquifer tests, and geophysical  measurements.   '
The complexity of an effective ground-water monitoring  program is  directly
related to the size of the waste management project,  the  nature of the waste
materials, and the characteristics of the local  hydrogeology.
    Using ground-water monitoring to assess conditions  at a site has some
limitations.  Because a monitoring well characterizes only one  point in an
aquifer, results obtained at the well may not be representative of site
conditions, especially in geologically complex areas.  Another  limitation of
ground-water monitoring is that some knowledge of site  conditions, such as
ground-water flow rate and direction, is necessary before the monitoring wells
can be placed properly.  In addition, because ground-water flow is extremely
slow, long-term monitoring over several months or years may be required to
characterize the situation accurately.  In some circumstances,  the flow
patterns of ground water through fractures may be sufficiently complex to
                                                    36  37
frustrate even the most intensive monitoring effort.   '
    Waste disposal facilities in the mining industry are so large  that
horizontal and vertical distances between hydraulically upgradient, and
therefore unimpacted, areas and areas that are downgradient,  and therefore
likely to be impacted, can be very great.  The variation in natural conditions
over such large distances (thousands of meters) can greatly complicate
hydrogeological studies.  In some cases, the presence of several active,
inactive, or abandoned waste disposal sites or mines in the area also
complicates ground-water quality and flow patterns, making ground-water
                                                       38 39
monitoring and hydrogeologic evaluation more difficult.  *
                                       3-25

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    Nevertheless, hydrogeologic evaluation and ground-water monitoring remain
the only methods for determining whether there is a danger of offsite movement
of contamination from mining wastes.   Because of the size and complexity of
many mining waste sites, the need for detailed hydrogeologic evaluation and
careful interpretation of ground-water monitoring results may be greater than
for other types of hazardous waste management facilities.
    Tables 3-4 and 3-5 show the extent to which ground-water monitoring,
practiced voluntarily or in compliance with State regulations and adequate to
satisfy current RCRA requirements, is performed at heap/dump leach operations
and tailings ponds in the various mining industry segments.  (Ground-water
monitoring is not normally performed at mine waste disposal sites.)
Ground-water monitoring of gold and silver heap leach operations adequate to
satsify current RCRA requirements is currently practiced at all  of the gold
and silver mine sites studied by EPA where there are heap leach  operations.
Ground-water monitoring adequate to satisfy RCRA requirements is currently
practiced at two of the nine copper dump leach operations studied by EPA.
    Monitoring of ground water is also practiced at all  of the gold and silver
tailings ponds and at 2 of the 12 copper tailings ponds  studied  by EPA.  It is
not performed at any of the lead or zinc tailings ponds  studied  by EPA.
3.4.1.2  Run-on/Runoff Controls
    Run-on/runoff controls can be divided into three categories:  diversion
methods, containment systems, and runoff acceleration practices.  Diversion
systems prevent offsite water from entering the site and causing erosion and
flooding.  Containment involves the collection of onsite stormwater or dike
seepage in holding or evaporation ponds for the treatment necessary for final
disposal or to prepare the waste for recycling.
                                       3-26

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           Table 3-4  Extent of Ground-Water Monitoring of Heap/Dump
                        Leach  Waste,  by  Industry  Segment
              Number of mine
            sites in data base
 Mining       that generate
industry        heap/dump
 segment       leach waste
  Number of mine
sites that monitor
 ground water at
 heap/dump leach
waste operations9
     States requiring
 ground-water monitoring
   or having mine sites
that monitor ground water
 at heap/dump leach waste
       operations"'0
Copper
Gold
9
5
2 (22%)
5 (100%)
Arizona, New Mexico
Montana, Nevada, Colorado,
Si 1ver
    1 (100%)
New Mexico, South Dakota

Nevada
a Sites are identified as having ground-water monitoring  only when  such
  monitoring is adequate to satisfy  current  RCRA  requirements.

b This column includes only those states  where  ground-water monitoring
  requirements are at least as stringent  as  required  by RCRA.

c This column includes only the states  generating large amounts  of  mining
  industry waste in the affected industry sectors.

Source:  Charles River Associates 1984  and 1985c.
                                     3-27

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                  Table 3-5  Extent of Ground-Water Monitoring
                     of Tailings Ponds, by Industry Segment
Number of
mine sites
Mining in data
industry that generate
segment tailings
Copper 12
Gold 7
Lead 6
Phosphate 8
Si 1 ver 8
Zinc 6
Number of States requiring
mine sites ground-water monitoring
that monitor or having mine sites
ground water at that monitor ground water
tailings ponds3 at taili'-gs pondsb»c
2 (17%) New Mexico, Colorado,
California, Arizona
7 (100%) Arizona, South Dakota,
Nevada
0
1 (13%) Florida, North Carolina
8 (100%) Montana, Idaho,
Colorado, Utah
0
a Sites are identified as having ground-water monitoring  only when  such
  monitoring is adequate to satisfy  current  RCRA requirements.

b This column includes only those states  where ground-water monitoring
  requirements are at least as  stringent  as  required  by RCRA.

c This column includes only the states generating large amounts  of  mining
  industry waste in the affected industry segments.

Source:  Charles River Associates 1984 and 1985c.
                                     3-28

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    Surface water diversion ditches consist of canals,  channels,  or pipes that
totally or partially surround waste piles, tailings embankments,  pits, or
ponds to divert the surface water around them and back  into the natural  stream
channel downgradient to the waste area.  The most important functions of ditch
systems are to minimize downstream environmental  damage, relieve  dike stresses
to reduce the chance of failure, diminish erosion of the waste embankment, and
                                                              40  41
reduce the volume of water requiring environmental monitoring.  '    Perimeter
ditches also help to recover supernatant for recycling, collect and drain dike
seepage, and collect onsite storm runoff for transport  to a containment
treatment system.  When wastewater requires treatment before release, a
suitable ditch network is constructed to prevent uncontaminated offsite or
onsite runoff from mixing with onsite wastewater streams.
    Table 3-6 shows the extent for which mine waste piles studied by EPA have
run-on/runoff controls for storm water adequate to satisfy current RCRA
requirements.  Run-on controls for mine waste that are  adequate to satisfy
RCRA exist only at three mines studied by EPA in the gold industry sector.
Runoff controls exist at these same three mines and at one silver mine in
Colorado.
3.4.1.3  Liners
    Lining the entire waste area and the upstream slope of the embankment may
prevent seepage.  Liners can be formed from natural earthen (clay) materials,
synthetic materials, or a combination of these.  Commercial bentonite can be
added to fine-textured soils to reduce their permeability to very low levels.
Synthetic liner materials include soil cements, treated bentonite, petroleum
derivatives, plastics, elastomers, and rubber.  These liners are generally
more expensive than liners made of earthen materials, and careful earthwork is
                                       3-29

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               Table 3-6  Extent of Run-on/Runoff Controls for Stormwater
                           for Mine  Waste,  by  Industry Segment
States requiring run-on/

Mining
industry
segment
Copper
Gold

Lead
Phosphate
Si 1 ver
Uranium
Zinc
No. mines
in data base
that generate
mine waste
13
11

7
18
9
9
7
No. mine
sites with
run-on
controls3
0
3 (21%}

0
0
0
0
0
No. mine
sites with
runoff
control s°
0
3 (27%)

0
1
1 (11%)
0
0
runoff
having mi
Run-ont
controls

Montana,
Cal i form'





controls or
ne sites with
Runoff*-
controls

Montana,
a California

N. Carolina
Col orado


a Sites are identified as having run-on controls  only  when  these  controls  are adequate
  to satisfy current RCRA requirements.

b Sites are identifed as having runoff controls only when these controls are  adequate
  to satisfy current RCRA requirements.

c These columns include only the states generating  large amounts  of mining industry
  waste in the affected industry segments.

Source:  Charles River Associates 1984 and  1985c.
                                     3-30

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required to prepare the ground surface even when these synthetic  materials  are
used.  If appropriate earthen liner materials are not readily available,
synthetic liners may be more economical.   Liner materials must be resistant to
the potential  corrosive effects of the waste and to damage from sunlight  (if
the liner is not covered immediately after placement).
    Although both synthetic and natural  liners can be used cost-effectively in
relatively small disposal  areas, they have not been used in the very large
waste facilities that are typical  of mining industry waste sites  (some of
which cover a square kilometer or more);  and they may in fact not be feasible
              43
at such sites.    Experience is inadequate to evaluate the performance of
liners at large-area, large-volume sites.   Lining large areas with synthetic
(membrane-type) liners would require many liners to be fastened together  to
form a single large liner; each seam represents a point of potential failure.
If a liner underlying such a large waste area failed, it would be impossible
          44
to repair.
    Installing liners at existing disposal areas in this industry would
require moving billions of tons (approximately 50 billion tons) of material
that has been deposited over the years.   Many active disposal sites have  been
used for many years, and the areas are continually built up.  Movement of
these materials to new lined sites severely affects the cost of operations  at
these sites.
    Table 3-7 shows the extent of the current use of tailings pond liners
adequate to satisfy current RCRA requirements, for mines studied by EPA.   Mine
waste piles are not normally lined.  According to Table 3-7, the majority of
tailings ponds at mine sites studied by EPA in the silver and zinc industry
segments are currently lined.  Tailings ponds at mines studied by EPA in  the
                                       3-31

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       Table  3-7   Extent of Tailings Pond Liner Use, by Industry Segment
Mining
industry
segment
Copper
Gold
Lead
Phosphate
Si 1 ver
Zinc
Number of
mines in
data base that
use tailings
pond liners
12
6
6
18
8
6
Number of
mine sites
having lined
tailings ponds3
0
1 (17%)
0
0
6 (75%)
4 (67%)
States requiring liners
or having mine sites with
lined tailings ponds** »c

Nevada


Idaho, Utah
Tennessee
a Sites are identified as having lined tailings  ponds  only when  the  liner
  is adequate to satisfy current RCRA requirements.

k This column includes only those states  where liner requirements  are  at
  least as stringent as those required by RCRA.

c This column includes only the states generating  large  amounts  of mining
  industry waste in the affected industry segments.

Source:  Charles River Associates 1984 and 1985c.
                                     3-32

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copper, lead, and phosphate industry segments are not lined.  One of the six
tailings ponds at mines studied by EPA in the gold industry segment is
currently lined.
    Regulations promulgated in 40 CFR Part 192 required that new uranium mill
tailings impoundments be lined.  Synthetic liners have been installed at three
uranium mill tailings impoundments and natural liners exist at other uranium
tailings impoundments.
    Many mines studied by EPA have impermeable pads under heap leach piles.
Figure 3-3 shows an impermeable pad under a gold heap leach pile.  These pads
aid in the collection of valuable leachate and reduce the pollution potential
at these sites.
3.4.1.4  Cutoff Walls
    Seepage outflow can be minimized by placing impermeable blankets or zones
in the embankment or foundations, as illustrated in Figure 3-4A.   A cutoff wall
of the type shown in Figure 3-4B can be used in cases where a relatively
impervious layer underlies a pervious layer at a shallow depth.   The impervious
core below the embankment will  cut off the flow through the shallow, pervious
portion of tine foundation.  A cutoff wall  is usually placed toward the  upstream
portion of the embankment section to allow drained conditions under as  much of
                                      45
the embankment section as practicable.     However, if total  cutoff of
seepage is desired (illustrated in Figure 3-4C),  the cutoff wall  can be
installed far downstream,  and the seepage can  be removed from the drainage
trench, pumped back  to the impoundment,  and then returned to the  mill,  or it
can be pumped to a treatment plant and  then released into a  natural  channel.
A small amount of seepage will  percolate downward, even through nearly
impervious natural materials,  from any  unlined portion of the waste  disposal
                                       3-33

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T
~5m
_L
                  IMPERMEABLE PAD
                  (CLAY, ASPHALT, CONCRETE
                  OR PLASTIC SHEETING)
PREGNANT SOLUTION TANK
                                                                                    *. MAKE UP
                                                                                   t  SOLUTION
                                                                                        (NaCN)
                           BARREN SOLUTION
                                                                             GOLD RECOVERY
                                                                                 PROCESS
                                                                                  GOLD
Source: PEDCo Environmental, Inc. 1985
                         Figure 3-3  Impermeable pad under a gold heap leach pile

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                      IMPERMEABLE
                         ZONE
                     A. BLANKET AND CORE METHOD
                                               CUTOFF WALL
                   B. FOUNDATION CUTOFF WALL METHOD
                       SAND AND GRAVELS
          W BEDROCK
                                                    TO MILL OR
                                                    TREATMENT
                                                      PLANT
                 C. CUTOFF WALL AND OPEN TRENCH METHOD
Source: PEDCo Environmental, Inc. 1984
          Figure 3-4 Some methods used to minimize seepage outflow
                                 3-35

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area; additional  monitoring wells  may  be  required  in  such  cases.   When  the
foundation consists of a thick  pervious  layer  or several pervious  layers
separated by strata or impervious  materials, a drainage  trench  can be used  to
remove some of the seepage.
3.4.1.5  Leachate Collection,  Removal, and  Treatment
    During active site life, it is necessary to collect, remove, and treat
leachate from lined waste piles to prevent  the leachate  from  building up  above
the liner.  Leachate collection prevents  high  moisture content  at  the base  of
the pile from deforming the structure  of  the pile.  For  small lined areas of
facilities, an adequate leachate collection system may consist  of  a sump  with
a pump to collect the waste and pipe it  to  a lined impoundment  for treatment.
In larger facilities, a zone of sand,  gravel,  or coarse  rock  may be placed
below the waste and drained.  Such a system may be augmented  by perforated
pipe to increase capacity, and may also  include collector  trenches in cases in
which the system emerges onto a broad, level area.  Collector trenches  may  be
useful even when no liners are used.  Collected leachate must be treated  and
disposed of by such treatment methods  as  neutralization  and precipitation,  as
discussed above.
    At heap or dump leach operations,  secondary leachate collection systems,
consisting of leachate collection sumps  and ditches,  serve to interrupt
liquids escaping the primary recirculating leaching system.  The extent of
adequate secondary leachate collection and removal  from  heap/dump  leach waste
and from tailings ponds is shown in Tables  3-8 and 3-9,  respectively.   Of the
gold mines studied by EPA, only one had  a secondary leachate  collection and
removal system in place that was adequate to satisfy  current RCRA requirements
for such systems.  Secondary collection  and removal of leachate from tailings
                                       3-36

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         Table 3-8  Extent of Secondary Leachate Collection and Removal
                 from  Heap/Dump  Leach  Waste,  by  Industry  Segment
Mining
industry
segment
Copper
Gold
Si 1 ver
Number
of mines
in data base
that generate
heap/dump
leach waste
9
5
2
Number of
mine sites
that collect and
remove leachate
from heap /dump
leach waste3
0
1 (20%)
0
States requiring
secondary leachate
collection and removal or
having mine sites that
collect and remove leachate
from heap/dump leach waste" >c

New Mexico, Nevada

a Sites are identified as having secondary leachate collection and removal
  systems only when the system is adequate to satisfy current RCRA requirements.

b This column includes only those states where leachate collection and
  removal requirements are at least as stringent as those required by  RCRA.

c This column includes only the states generating large amounts of mining
  industry waste in the affected industry segments.

Source:  Charles River Associates 1984 and 1985c.
                                     3-37

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         Table 3-9  Extent of Secondary Leachate Collection and Removal
                    from Tailings Ponds, by Industry Segment

Mining
industry
segment
Copper
Gold
Number
of mines in
data base
that generate
tailings
12
7
Number of mine
sites that collect
and remove
leachate from
tailings ponds3
0
2 (29%)
States requiring
secondary leachate
collection and removal or
having mine sites that
collect and remove leachate
from tailings pondsb»c

California, South Dakota,
Lead
Phosphate
Silver

Zinc
 6
18
 8
                                                     Nevada
0
0
2 (25%)

0
Montana, Colorado, Idaho,
Utah
a Sites are identified as having secondary leachate collection  and removal
  systems only when the system is adequate to satisfy  current RCRA requirements.
b This column includes only those states where leachate collection and
  removal requirements are at least as  stringent as those  required by  RCRA.
c This column includes only the states  generating large amounts of mining
  industry waste in the affected industry segments.
Source:  Charles River Associates 1984  and 1985c.
                                     3-38

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ponds are practiced only at two gold mine sites studied by EPA, as shown in
Table 3-9.
3.4.1.6  Security Measures
    During the active site life phase of operations, the mining industry
implements security measures that range from posting "No Trespassing" signs to
installing comprehensive systems of locked gates and fencing and using
security guards.  Fencing material ranges from chain link to barbed wire.   The
extent of the security measures employed depends on the severity of the
hazards existing at the mine site, the value of the material being mined or
milled, and the proximity of the mine site to populated areas.   Posting
security guards has an additional  benefit, because these employees can also be
assigned facility inspection duties, such as checking runoff dikes.  At active
and inactive asbestos waste disposal sites, existing EPA regulations (40 CFR
Part 61) require security measures.
3.4.2  Mitigative Measures at Closure
    The mitigative methods described above for the active site  life phase
remain applicable during the closure phase.  In addition, other activities  may
be necessary or desirable.  For example, tailings impoundments  may be
dewatered and stabilized; these are essential steps if a cap and cover are  to
be added.  A cap and cover can be placed over the site to minimize contact  of
the waste with the environment and to protect the waste from rainfall, which
increases the volume of leachate formed.
3.4.2.1  Wastewater Treatment
    The wastewater that remains onsite after active mining and  milling
operations have ceased may be treated and then discharged or be transported to
a licensed disposal  site.
                                       3-39

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3.4.2.2  Wastewater Pond Sediment Removal
    The sediment that is collected in wastewater treatment and retention ponds
often contains settled solids created during the mining or milling processes,
precipitated metals, and process chemicals such as flotation reagents.
Assessment of the potential hazards must be made during the active life of the
mine and at closure, in order to properly dispose of and manage these wastes.
The quality of these sediments varies widely, and some sediments may require
removal at closure to reduce potential  hazards, while other sediments may pose
little or no risk to humans or the environment.
3.4.2.3  Dike Stabilization
    A major consideration in the closure of a waste disposal  site or area is
the structural integrity of the dike(s) constructed to confine the
waste.  '    Various methods of slope stabilization, such as slope
modification and/or placement of waste rock (rip-rap), topsoil, vegetation,
and chemical stabilizers, may be used during the active or final  closure
phases of the life of the impoundment to minimize erosion and siltation.
Closure of a diked impoundment may require an assessment of the ability of the
dike system to withstand additional  loads, which may include the weight of
several layers of a capping system (clay, drainage layer, and topsoil  cover)
and of the construction equipment used to place and compact the final
      49
cover.    The long-term control of water behind the dike is a major factor
in the stability of dikes and prevention of catastrophic failure.
3.4.2.4  Waste Stabilization
    Since wastes remain in place after closure of the waste piles and ponds,
proper consolidation and stabilization of the wastes are necessary to ensure
long-term support for the final cover when it is emplaced.   The initial  step
                                       3-40

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in stabilizing tailings is dewatering the wastes.  At some sites (e.g., copper
tailings ponds located in the arid Southwest), passive dewatering using
natural evaporation and drainage mechanisms may be sufficient to remove
free-standing water and to dewater the tailings.  At other sites, active
dewatering using pumps to remove liquids within the impoundment or from ponds
on the impoundment surface may also be required in conjunction with passive
dewatering mechanisms.  The liquids collected during dewatering operations may
require treatment before they are discharged or disposed of.
    The wastes within the impoundment must also be capable of bearing the
loadings imposed by the final cover system and the construction equipment used
to apply this system.   Tests can be used to estimate the anticipated amount of
waste settlement and any differential settling across the waste site likely to
                             50
be caused by increased loads.    The results of these tests may indicate the
need for further dewatering, for redistribution of the wastes or compaction of
the material  (e.g., mechanical  compaction such as with a sheepfoot roller), or
for implementing methods of minimizing differential settlement.
3.4.2.5   Installation of Leachate Collection, Treatment, and Removal Systems
          for Lined Surface Impoundments
    In order for these systems to be effective in collecting leachate, the
post-closure needs of the system must be integrated into the initial design of
the impoundment.
3.4.2.6  Final Cover System
    The proper installation of a final  cover system over the exposed surfaces
of the waste impoundment, mine waste pile, leach dumps,  etc., helps ensure
control of erosion, fugitive dust, and surface water infiltration;  promotes
proper drainage; and creates an area that is aesthetically pleasing and
                                       3-41

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amenable to alternative land uses.   This cover system typically  consists of
the following components:
     •    A low-permeability clay layer or synthetic membrane overlying the
          waste material;
     t    A middle drainage layer of moderate to high permeability;  and
     t    A top cover of topsoil  and vegetation, except  in  the arid  regions of
          the Western United States, where a rock cover  is  more  effective for
          preventing erosion and  breaching.51,52
     The function of the low permeability material  overlying the waste  is to
prevent the infiltration of precipitation,  minimize leachate generation, and
prevent the migration of potentially hazardous waste constituents from  the
waste into the ground water.    To  prevent excessive leachate buildup,  the
low permeability layer should be  at least as impermeable as the  liner,  if
present.
     If the final cover system is to be vegetated,  a drainage layer  of  sand or
gravel  having low hydraulic conductivity is  laid over the impermeable cap.
This layer is graded (at least 2  percent) to allow the precipitation
infiltrating the vegetative cover to drain  rapidly,  thus minimizing  the
hydraulic head on the clay cap or synthetic  liner.   Then, depending  on  the
gradation, this layer is overlaid by a filter to prevent clogging.
     Except in arid regions, the  top layer of the cover  system consists of
topsoil capable of sustaining vegetation.  Two feet of soil  are  considered
adequate to accommodate the root  systems of  most nonwoody vegetative covers
and to provide a degree of protection from root damage to the underlying
                        54
clay or synthetic liner.    Wide  variance in cl imatological  factors  and soil
conditions, and therefore in subsequent growing conditions,  affects  the level
of effort required to revegetate  mined land  successfully.  For example, much
                                       3-42

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less work is required at a Florida phosphate mine, where conditions are
favorable (fertile soils, adequate water, and long growing seasons) than at a
southwestern copper facility, where a combination of poor soils (e.g.,  high in
salts and sulfides, low in nutrients) and an arid climate may require managers
to introduce nonnative plant species, install irrigation systems,  and provide
constant maintenance to develop and sustain the vegetative cover.   Revegeta-
tion also requires extra effort at sites in mountainous terrain where erosion
rates are often high, growing seasons are short, and winters are long and
severe.
     Tables 3-10 through 3-12 show the number of mine sites studied by  EPA
where some types of closure activity are performed.   Mines in many of the
industry segments stabilize their wastes, install  some kind of cap, and
revegetate during the closure phase.  For example, mine waste piles generated
by the gold industry in California are contoured for stability and
revegetated.  For tailings generated by the phosphate industry in  North
Carolina, reclamation consists of covering the tailings with sand  to increase
stability, adding topsoil, and revegetating.   Similarly,  closure of tailings
piles at sites in the gold and silver industries in  Montana consists of
compacting, grading, capping the tailings with rock  and topsoil, and
revegetating.  Although waste stabilization,  capping, reclamation, and
revegetation appear to be common waste management practices in many industry
segments, installing a final cover, consisting of a  low-permeability clay
layer or a synthetic membrane overlying the waste material,  is not a
                                                55
mitigative practice used in the mining industry.    However, asbestos waste
piles must be covered daily, as required by EPA regulations in 40  CFR Part 61,
if there are visible emissions to the outside air.
                                       3-43

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      Table 3-10  Closure Activities  for Mine  Waste,  by  Industry  Segment
Mining
industry
segment
Gold
Phosphate
Si 1 ver
Uranium
Number
of mines in
data base
that generate
mine waste
6
11
5
6
Number of mines
performing
some types of
closure
activity
2 (33%)
11 (100%)
4 (80%)
6 (100%)
States requiring some
types of closure activity
or having mine sites that
perform some types of
closure activity9
California, Colorado
Florida, Idaho
Idaho, Colorado, Utah
Colorado, Wyoming
a This column includes only the states generating large  amounts  of mining
  industry waste in the affected industry segments.

Source:  Charles Rivers Associates 1984 and 1985c.
                                     3-44

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            Table 3-11  Extent of Closure Activities for Heap/Dump
                       Leach Waste, by Industry Segment
Mi ni ng
industry
segment
Copper
Gold
Si 1 ver
Number
of mines
in data base
that generate
heap/dump
leach waste
8
5
1
Number
of mines
performing
some types of
closure
activity
1 (13%)
0
0
States requiring some
types of closure activity
or having mine sites that
perform some types of
closure activity*
Utah


a This column includes only the states generating large amounts  of mining
  industry waste in the affected industry  segments.

Source:  Charles River Associates 1984 and 1985c.
                                     3-45

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           Table 3-12  Closure  Activities  for Tailings  Impoundments,
                             by  Industry  Segment
Mining
industry
segment
Copper
Gold
Lead
Phosphate
Si 1 ver
Zinc
Number
of mines
in data base
that generate
tailings
4
7
4
12
4
3
Number of mines
perf ormi ng
some types of
cl osure
activity
1 (25%)
3 (43*)
0
12 (100%)
4 (100%)
1 (33%)
States requiring some
types of closure activity
or having mine sites that
perform some types of
closure activity3
Utah, New Mexico
South Dakota, California,
Arizona, Montana, Nevada

Florida, Idaho,
North Carolina
Idaho, Colorado, Utah
Nevada, Montana

3 This column includes only the states generating large amounts of mining
  industry waste in the affected industry sectors.

Source:  Charles River Associates 1984 and 1985c.
                                     3-46

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3.4.3  Mitigative Measures During  Post-Closure
     At certain sites  during the post-closure phase,  it  is  necessary to
continue to support the  waste management methods applied during the active and
closure phases of site life.   Many post-closure activities, such as
inspection, are routine  during active  site life but require special effort to
maintain once the site has been closed.  For example,  inspection activities
after site closure should be part  of a program of regularly scheduled visits.
     Inspection and detection activities during the post-closure period may
consist of the following:
     •    Assessment of  the density, cover, and composition of vegetation
          species to evaluate revegetation success;
     •    Visual  or photographic inspection to detect  rill  and gully erosion;
     •    Analysis of  data on ground-water quality to  define contaminant
          migration and  dilution and to determine the  effectiveness of liners,
          cutoff walls,  or other containment systems;
     •    Evaluation of  data  on ground-water level to  define ground-water
          recovery rates and  levels;
     •    Visual  or photographic inspection of stream  and drainage channels to
          determine migration rates and patterns;
     •    Monitoring of  subsidence; and
     •    Visual  and photographic  inspection after severe meteorological
          events (severe precipitation or drought) or  other natural phenomena
          (e.g.,  earthquakes).  56,57
     Maintenance conducted during  the  post-closure period may consist of the
following:
    •    Reseeding areas that have not been successfully revegetated;
    t    Repairing or  replacing security fences, gates,  locks, and warning
         signs;
    •    Maintaining collection and treatment systems;
    •    Maintaining monitoring wells  and replacing them as necessary;
                                      3-47

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    t    Replacing rip-rap to control  the migration of stream and drainage
         channels and the effects of flooding;
    •    Replacing top soil  and rock covers to control rill  and gully erosion;
         and
    •    Eliminating trees and other deep-rooted vegetation  that may damage
         covers and liners.58*59
3.4.4  Corrective Action Measures
    The corrective action measures described below may be necessary if a plume
of contaminated ground water above some threshold limits has been detected.
In this phase, the two major activities are additional hydrogeologic
evaluation and controlling the plume.   These processes are described below.
Corrective action measures have not normally been performed at mining
facilities in the past.
3.4.4.1   Hydrogeol ogi cal Evaluation
    Once ground-water contamination has been detected by the ground-water
monitoring system, an extensive hydrogeol ogi cal  evaluation is usually needed
to determine the size, depth, and rate of flow of the contaminated plume.  The
methods and limitations of hydrogeol ogi cal  evaluations in the corrective
action stage are similar to those that apply to these evaluations during
active site life.
3.4.4.2  Interceptor Wells
    Seepage losses through the deep pervious foundation of a waste disposal
facility can be reduced by installing  interceptor wells at points that
intersect the plumes of contaminated seepage in the saturated zone.
Comprehensive hydrogeol ogi cal explorations and evaluations are required to
site these wells properly.  The intercepted seepage may be pumped directly to
a mill or pond if water balances permit, or it may be treated before being
returned to the mill or discharged.
                                       3-48

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3.4.4.3  Hydraulic Barriers
     Interceptor wells may be used in combination with a hydraulic barrier
system established downgradient to the embankment, as shown in Figure 3-5.   A
hydraulic barrier system is usually made by installing a line of pumping wells
downgradient to the leaking embankment, and a line of injection wells
downgradient to the pumping wells.  The injection wells supply fresh water,
while the pumping wells extract ground water.  Pump effluent is typically a
mixture of native ground water, plume water, and injected fresh water.  The
use of hydraulic barriers is effective at sites where the subsurface is
generally homogeneous.  The use of hydraulic barriers is not a common practice
in these segments, and their effectiveness must be demonstrated.
3.4.4.4  Grouting
     If a waste presents a serious pollution hazard to ground water,  grouting
the foundation rock may be warranted.   The grouting process consists of
pumping a fluid grout mixture (usually a water-cement compound) through drill
holes into crevices and joints in rock to tighten the embankment foundation.
Chemical grout is used to seal  porous  materials and cracks that are  too small
to accept a water-cement grout.   Grouting must be thorough, because  even a  few
ungrouted joints in permeable rock formations can render the grouting effort
ineffective.
    Figure 3-6 illustrates a grout curtain being used in conjunction with
extraction wells.   This grouting process is often not very reliable, because
it is difficult to ensure a completely impermeable grout curtain.  Generally,
grout curtains cannot be used to control  deep vertical  seepage  within the
curtain's boundaries.   In some cases,  grout curtains can reach  depths of
60 meters; however, both the cost and  unreliability of these systems increase
                                         fi?
rapidly  at depths  greater than 30 meters.
                                       3-49

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                                                     LINE OF
                                                  PUMPING WELLS
    LINE OF
INJECTION WELLS
                                                                               • x
                   PERVIOUS FOUNDATION
                                              PHREATIC SURFACE
Source:  PEDCo Environmental, Inc. 1984
                  Figure 3-5  Hydraulic barrier for seepage collection
                                      3-50

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           EXTRACTION WELL
EXTRACTION WELL
                                        ORIGINAL WATER TABLE
                                       CONTAMINATED
                                            ZONE
                             IMPERMEABLE LAYER (CLAY OR SHALE)
Source: PEDCo Environmental, Inc. 1984
               Figure  3-6  Grout curtains and extraction wells for seepage control
                                          3-51

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3.4.4.5  Cutoff Walls
    Cutoff walls are often used as  seepage  or ground-water  pollution  control
systems because they are effective  and relatively  inexpensive.   Sheet piling
cutoff walls can extend 24-30 meters in depth, but they have  a  relatively
short effective life (less than 20  years) and are  difficult to  construct to
achieve a low permeability barrier.  More effective cutoff  walls can  be
constructed by digging narrow trenches to a depth  of 9-15 meters and
backfilling them, either with a soil-ben ton ite or  a soil-cement-ben ton ite
mixture that hardens into a homogeneous and very low-permeability barrier.
The effective use of cutoff walls is highly dependent on the  site's
hydrogeologic properties, in that a naturally impermeable rock  and/or soil
must underlie the waste within the  cost-effective  trenching depth.  If an
impermeable layer does not exist, cutoff walls will  be ineffective in stopping
migration of pollutants.  This technology  is not applicable to  all mines,  and
is not a common practice in this industry.

                                 3.5  SUMMARY
    Of the waste currently generated by the mining industry segments  of
concern, 56 percent is disposed of on site, 9 percent is backfilled,
31 percent may be considered to be  utilized on site (principally in the
leaching of copper dump wastes and in starter dams for tailings impoundments);
and 4 percent is utilized off site  (as fill and aggregate for road
construction).  Most tailings are disposed of in impoundments;  but 5  percent
are backfilled, and 2 percent are used off site (in construction, as  soil
supplements, etc.).  Most mine water is recycled through the mill and used on
site for other  purposes  (e.g., dust control) or treated and discharged.  Few
                                       3-52

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methods are available to reduce the amount of solid  waste  generated  by mining
and milling, but process modifications can reduce  the water content  and
potential  toxicity of these wastes.  Many methods  are available  to design,
site, maintain, and close disposal  facilities in an  environmentally  acceptable
manner.  Commonly used mitigative measures include ground-water  monitoring  at
leach operations only; and, for many types of operations,  stabilization  of
waste, installation of some kind of cap, and revegetation  during the closure
phase.  Available corrective action methods, not widely used in  the  mining
industry,  include interceptor wells, underground barriers  to prevent the
spread of contaminated ground water, and liners to contain the leachate.
                                       3-53

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                             SECTION 3 FOOTNOTES
 1   Tailings are often disposed of in  ponds  because,  as  described  in
    Section 2, they leave the mill  as  a  slurry.
 2  Greber et al.  1979.
 3
    Charles River Associates 1985a.
 4  Vick 1981.
 5
    Goodson and Associates 1982.
 6  Curtin 1983.
 7  Seitter and Hunt 1982.
 8  Seitter and Hunt 1982.
 9  Seitter and Hunt 1982.
    Charles River Associates 1985b.
11   Schiller 1983.
12  Heming 1984.
    PEDCo Environmental,  Inc.  1984.
14  USDA Forest Service  1979.
15
    PEDCo Environmental,  Inc.  1984.
16  Wixson et al.  1983.
17  Seitter and Hunt 1982.
18  A stope is an excavation from which  ore  has  been  mined  in  a  series
    of steps.
19  Vick 1981.
20  Vick 1981.
21
    Goodson and Associates 1982.
22  Klohn 1981.
                                     3-54

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                       SECTION 3 FOOTNOTES (Continued)
23  Portfors 1981.
24  Vick 1981.
25  US EPA 1982a.
26  Vick 1981.
27  EPA 1982a.
28  Vick 1981.
29
    PEDCo Environmental, Inc.  1984.
    Goodson and Associates 1982.
    PEDCo Environmental, Inc.  1984.
32  TFI 1984.
    U.S. Nuclear Regulatory Commission  1983.
34  BOM 1985.
    Geological Society of America 1971.
oc
    U.S. Nuclear Regulatory Commision 1983.
    New Mexico Energy and Mining Department 1979.
38
    New Mexico Energy and Mining Department 1979.
39  Pacific Northwest Laboratories 1983.
40  BOM1980b.
41  Lucia 1982.
42  Edwards et al. 1983.
43  DOE 1985.
44  DOE 1985.
45  BOM 1980.
    U.S. Nuclear Regulatory Commission 1983.
                                       3-55

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                       SECTION 3 FOOTNOTES (Continued)
47  Lucia 1982.



48  DOE 1985.

49
^  DOE 1985.


50  DOE 1985.



51  DOE 1985.

52
    U.S. Nuclear Regulatory  Commission 1983.



53  DOE 1985.


54  DOE 1985.


55
    Charles River Associates 1984.

56
°   DOE 1985.


57
    U.S. Nuclear Regulatory  Commission 1983.

CO

D   DOE 1985.

59
    U.S. Nuclear Regulatory  Commission 1983.


60  BOM 1985.


61  BOM 19805.


62  Greber et al.  1979.
                                     3-56

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                                  SECTION 4
             POTENTIAL DANGER TO HUMAN HEALTH AND THE ENVIRONMENT

    This section assesses the potential  danger to human  health and the
environment associated with wastes generated by the mining industry.   It
identifies the hazardous chemical and physical characteristics of these
wastes, estimates the amount and type of mining waste possessing these
characteristics, describes mining waste damage case studies compiled  by
EPA, and discusses the effectiveness of mining waste management systems.
    In this section, EPA is responding to the requirements of Sections 8002(f)
and (p) of RCRA for analyses of the "potential dangers to human health and the
environment from surface runoff of leachate," the "potential  danger,  if any,
to human health and the environment from the disposal and reuse" of mining
waste, and "documented cases in which danger to human health or the environ-
ment has been proved."  Over a period of years, EPA has conducted these
analyses with the support of consulting firms and individual  experts.
    The studies sponsored by EPA involved waste sampling at 86 mines  in 22
states; chemical analyses of solid and liquid samples (and leachates  from
the solid samples); and monitoring of ground water at seven of eight
representative sites  (and surface water of five of the sites).
    Reports on mining industry damage cases were obtained from state files and
from information in EPA's files on sites on the National Priorities List for
Superfund cleanup.  The damage case analysis  focused on the range and severity
of contamination problems associated with mine and mill  waste disposal at
active, inactive, abandoned, and Superfund sites.
                                      4-1

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    EPA is currently analyzing the amounts and rates of toxic releases from
mine and mill wastes.  This is an essential  prerequisite to studies on
exposures and effects, and is required for any quantification of risks to
human health and the environment posed by these wastes.

                     4.1   WASTE  CHARACTERISTICS  CONSIDERED
    Mining wastes may contain constituents,  such as heavy metals,  other toxic
elements, radionuclides, cyanide compounds,  and asbestos, that may be
dangerous to human health and the environment.  In addition, some mine wastes
are corrosive (acidic) and others have a high potential  for forming acid.
    Table 4-1 presents the waste characteristics evaluated for this report,
the criteria used to determine whether or not mining wastes have these
characteristics, and the rationale for choosing these criteria.   As the table
indicates, EPA evaluated two general  categories of waste characteristics for
this report:  RCRA Subtitle C Hazardous Waste Characteristics and Other
Potentially Hazardous Characteristics.  The  following sections discuss the
waste characteristics evaluated, the  sampling methodology, and the sampling
results obtained by EPA at selected mine sites.
    To evaluate the hazardous characteristics of mining waste for this report,
EPA's Office of Solid Waste (OSW) subdivided mining industry segments into the
following mining region-commodity categories:
    •    New Mexico Uranium;
    •    Wyoming Uranium;
    t    Other Uranium;
    •    Florida Phosphate;
    •    Idaho Phosphate;
    t    Other Phosphate;
                                      4-2

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               Table 4-1  Waste Characteristics,  Hazard Criteria,
                    and Bases  for  Criteria Used to Assess the
               Hazard Potential  of Mining and Beneficiation Wastes
       Waste
  characteristic
                                     Hazard
                                    criterion
                                                                Basis for
                                                                criterion
t  RCRA Subtitle C Hazardous Waste Characteristics

   -  Corrosivlty

   -  EP Toxicity
                              pH  42.0 or pH  ^12.5

                              Metals in EP Extract:
                              Mercury  >0
                              Cadmium  >1
                              Selenium >1
                              Silver   >5
                              Arseni c  >5
                              Chromium >5
                              Lead     >5
                              Barium ^100
                                           2 mg/1
                                          ,0 mg/1
                                          ,0 mg/1
                                          .0 mg/1
                                          ,0 mg/1
                                          ,0 mg/1
                                          ,0 mg/1
                                          ,0 mg/1
   -   IgnitabHity
                               (See definition used
                                in 40 CFR 261.21)
                               (See definition used
                               in 40 CFR 261.23)
   -  Reactivity


•  Other Potentially Hazardous Characteristics
   -  Cyanide
                              Cyanide  ^2 mg/1
                                      ^10 mg/1
                                      ^20 mg/1
       Radioactivity
       Asbestos

       Acid formation
       potential
                               Ra 226   ^5 pCi/gm
                               Ra 226  ^20 pC1/gm
                               Asbestos content >1% by wt.

                               Presence of metal
                               sulfides and absence
                               of carbonate minerals
                                                                40 CFR 261.22

                                                                40 CFR 261.24

                                                                (100 times
                                                                National Interim
                                                                Primary Drinking
                                                                Water Standards
                                                                for Metals)
                                                                40 CFR 261.21
                                                                 40  CFR 261.23
                                                                 (10, 50, and 100
                                                                 times the Ambient
                                                                 Water Quality
                                                                 criterion for
                                                                 protection of
                                                                 human health,
                                                                 respectively)

                                                                 40 CFR Part 192
                                                                 Derived from
                                                                 40 CFR Part 192

                                                                 40 CFR Part 61

                                                                 Danger posed to
                                                                 the environment
                                                                 by acid drainage
Source:  Compiled by EPA,  OSW staff,  1985.
                                      4-3

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    •    Southwestern Copper;
    •    Other Copper;
    •    Western Lead/Zinc;
    •    Eastern Lead/Zinc;
    •    Missouri Lead/Zinc;
    •    Molybdenum;
    •    Nevada Gold/Silver;
    •    Other Gold/Silver;
    •    Taconite/Iron;  and
    •    Tungsten.
    EPA sampled at least one mine and mill  in  each  of these  categories  for
this study.   EPA then augmented this sample set by taking samples  from
operations (e.g., heap and dump leach operations) and industries  (e.g.,
beryllium and rare earth metals) either not covered at all,  or not
                                             2
sufficiently covered  in  the  first sample set.    These results  were  then
supplemented with data from  a  study performed for EPA's Effluent  Guidelines
Division (now the Industrial Technology Division) on the following  mining
industry segments:  antimony, bauxite (aluminum), mercury,  nickel, titanium,
tungsten, and vanadium.    EPA's Industrial  Environmental  Research Laboratory
performed the analyses of waste samples from mines  in the asbestos  mining
industry.  Generally, EPA sampled the full  range of waste types (e.g.,  fresh
tailings, mine water  pond liquid and settled solids, tailings  liquid and
settled solids, pregnant and spent leach liquor (process liquors  that may be
characteristic of seepage from leach operations), and tailings dike material)
produced by mining and beneficiation operations in  these segments.   The Agency
also took additional  samples of those wastes believed to be  most  likely to
present a hazard to human health and the environment (e.g.,  heap  and dump
                                      4-4

-------
leach wastes).   For this reason,  the percentage  of  samples  having hazardous or
potentially hazardous characteristics is probably greater than would have been
the case if a completely random sampling strategy had  been  used.  However, the
Agency excluded all results from samples that were  believed to be either
invalid or duplicative.
    EPA's Office of Solid Waste planned the original  sampling and analysis
effort in 1979-1980 and, with the cooperation of the  Office of Research and
Development, took samples between 1979 and 1984. To  show the scope  of EPA's
mining waste sampling and analysis effort, Table 4-2  presents 1980 figures for
the number of active mines, the number of mines  sampled, and the percent  of
mines sampled.  Data are presented for 1980, because  this was the year in
which the sampling effort was planned and initiated.   This  table shows that
EPA sampled 13 percent of all metal mines and 31 percent of all  asbestos  and
phosphate mines active in 1980.  Figure 4-1 is a map  showing the locations of
the mines EPA sampled.
4.1.1  RCRA Subtitle C Hazardous Waste Characteristics
    Solid wastes are defined as hazardous under regulations implementing
Subtitle C of RCRA if  they exhibit any of four general characteristics:
ignitability, corrosivity, reactivity, or EP toxicity.  They are also
considered hazardous if they are listed as hazardous  in 40  CFR 261.31-261.33.
Wastes may be listed under RCRA if the Administrator  of EPA determines that
the wastes meet one of the criteria  in 40 CFR 261.11.  The  Administrator  must
indicate whether the wastes are ignitable, corrosive, reactive,  EP toxic,
acutely hazardous, or  toxic (40 CFR  261.30).  Since Congress has, at least
temporarily, excluded  mining wastes  from regulation under Subtitle C of  RCRA,
EPA's current lists of hazardous wastes do not  include wastes from mining and
beneficiation processes.
                                      4-5

-------
Table 4-2  Scope of EPA's Mine Waste Sampling
             and Analysis Effort
Number of
Mining active mines
industry in sector,
segment 1 980a
Metals:
Antimony
Bauxite (Aluminum)*5
Beryl 1 i urn
Copper
Goldc
Iron
Lead
Mercury
Molybdenum
Nickel
Rare earth
metal s
Silver
Ti tani urn
Tungsten
1
2
1
39
44
35
33
4
11
1
2
43
5
29
Number of
active mines
sampl ed
1
1
1
13
6
5
4
1
3
1
1
6
2
1
Percent of
active mines
sampled
100
50
100
33
14
14
12
25
27
100
50
14
40
3
                     4-6

-------
                        Table 4-2   (continued)
Mining
industry
segment
Uranium
Vanadium
Zinc
Subtotal
Nonmetal s :
Asbestos
Phosphate
Subtotal
TOTAL
Number of
active mines
in sector,
19803
265
1
20
536
4
44
48
584
Number of
active mines
sampl ed
17
1
7
71
2
13
15
86
Percent of
active mines
sampl ed
6
100
35
13
50
30
31
15
a Estimated by Bureau of Mines 1981  (BOM 1982).

b Although the BOM lists 10 active mines,  there were  ony  two
  operations supplying bauxite for aluminum reduction.  The other
  mines are supplying bauxite for other uses.

c Excludes placer mines.
                                  4-7

-------
00
                  Figure 4-1.  Approximate locations of mining/benefication sites active in 1980 sampled by EPA for this report

-------
    Mining wastes are far more likely  to  be  corrosive  or  EP  toxic than
ignitable or reactive.   Therefore,  EPA did not evaluate ignitability, which
measures the ability of wastes to cause or exacerbate  fires,  or  reactivity,
which measures explosivity and the  ability of sulfide- or cyanide-containing
wastes to generate toxic gases, vapors, or fumes,  although some  mining wastes
containing cyanide or sulfide may be reactive.  However,  the toxic  properties
of cyanide-containing mining wastes were  examined  separately in  this  report.
    The RCRA Subtitle C characteristics of corrosivity and EP toxicity are
discussed below as they relate to mining  and beneficiation wastes.   In
addition, copper dump leach, which  may be a potential  candidate  for listing
under 40 CFR 261.31 because of its  potential EP toxicity  and corrosivity, also
is described.
4.1.1.1  Corrosivity
    A waste is considered corrosive and therefore  hazardous  if it is a liquid
and has a pH less than or equal to  2 or greater than or equal to 12.5, as
                         A
determined by a pH meter.   EPA chose pH  as a "barometer  of  corrosivity,
because wastes exhibiting low or high pH  can cause harm to human tissue,
promote the migration of toxic contaminants from other wastes, and  harm
aquatic life" (45 FR 33109, May 19, 1980).  The lower pH  limit of 2.0 was
chosen so that "a number of substances generally thought  to  be innocuous  and
many industrial wastewaters prior to neutralization" would not fall within  the
corrosive classification.  The upper pH limit of 12.5 was chosen to exclude
lime-stabilized wastes and sludges  from corrosive  classification (45 FR  33109,
May 19, 1980).  For this study, EPA also evaluated whether samples  had a  high
pH (greater than 10 but less than 12.5) or low pH (greater than 2 but less
than 4), to aid in deciding which wastes  could be potential  candidates
                                      4-9

-------
for listing and which might cause  damage  to  human  health and the environment.
These pH levels, and associated contamination by toxic metals, can degrade
aquatic ecosystems.
    Table 4-3 shows  the results of the corrosivity analyses performed by EPA
for this report.  Of the 159 liquid waste samples  taken by EPA, only 5 were
corrosive.  An additional  28 samples  had  low (more than 2 and less than 4) or
high (more than 10 and less than 12.5) pH's.  Some of the liquid samples, such
as pregnant leach liquors or wastewater prior to treatment and discharge, are
considered by industry to be process  streams.  The characteristics of some of
these liquids would  be likely to alter (improve) after the active life of the
mine.
    Table 4-4 identifies all of the industry segments that had at least one
sample with a low or high pH.  All  copper dump leach operations had at least
one sample with a pH less than or  equal to 4 and 11 of the 23 liquid samples
with pH's less than  or equal to 4  were from  the copper industry segment.  Of
the nine waste management operations  having  samples with pH's greater than 10,
more than half were  from tailings  processed  with caustic solutions.  However,
tailings such as these may later be treated  to lower their pH, which reduces
their hazard potential.
4.1.1.2  EP Toxicity
    A solid waste is defined as EP toxic  (and thus hazardous) if, using the
test methods described in 40 CFR Part 261 (Appendix  II), an extract from a
                                                     5
representative sample of waste contains certain metals  at a concentration
greater than or equal to 100 times the maximum contaminant levels for these
metals as established by EPA's National Interim Primary Drinking Water
                                     4-10

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                    Table 4-3  Results of Corrosivity3 Analyses of Liquid Mining Waste Samples
Number of samples with pH:
Mining
industry
segment
Metals:
Copper
Gold
Iron
Lead
Molybdenum
Silver
Uranium
Zi nc
Other metals5
Subtotal
Nonmetal s :
Asbestos
Phosphate
Subtotal
TOTAL
Number of
sampl es
analyzed

29
5
7
6
9
6
19
15
47
143

2
14
16
159
Less than or
equal to 2a

3 (10%)c
0
0
0
0
0
0
0
1 (2%)
4 (3%)

0
0
0
4 (3%)
Between
2 and 43

8 (29%)
0
0
0
1 (11%)
0
0
0
10 (21%)
19 (13%)

0
0
0
19 (12%)
Between
10 and 12.53

3 (10%)
1 (20%)
0
0
0
1 (17%)
0
0
4 (2%)
9 (6%)

0
0
0
9 (6%)
Greater than or
equal to 12. 5a

0
0
0
0
0
0
0
0
1 (2%)
1 (1%)

0
0
0
1 (1%)
Number of
samples
corrosive3

3 (10%)
0
0
0
0

0
2 (4%)
5 (3%)

0
0
0
5 (3%)
3 A waste is corrosive under current RCRA Subtitle C  regulations  if  the  pH  is less than or equal to 2 or greater
  than or equal to 12.5

D Includes antimony, bauxite, beryllium,  mercury, nickel,  rare  earth metals, titanium, tungsten, and vanadium.

c Numbers in parentheses are percentages  of  all  samples  analyzed  for that industry segment that have the
  hazardous characteristic.

Source:  PEDCo Environmental, Inc.  1984,  ERCO  1984, and  Harty and Terlecky  1982.

-------
Table 4-4  Number of Mines, Wastes, and Operations with Samples Showing Low or High  pH Levels
Number of waste management operations with at least one sample:


Mining
industry
segment
Copper



Gold



Molybdenum


Silver



Other metalsd




Type of
waste
management
operation
No. mines involved''
Mine waste0
Dump leach
Tailings
No. mines involved
Mine waste
Heap leach
Tailings
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Heap leach
Tailings
No. mines involved
Mine waste
Dump/heap leach
Tailings
Number
of waste
management
operations
analyzed
13
7
6
12
5
1
2
2
3
2
3
5
0
0
5
10
5
1
7

Having pH
less than
or equal
to 2
3
0
3
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1


Having pH
between
2 and 4
5
3
3
1
0
0
0
0
1
1
0
0
0
0
0
4
2
0
2


Having pH
between
10 and 12.5
1
0
0
2
1
0
1
1
0
0
0
1
0
0
1
3
0
1
2

Having pH
greater than
or equal
to 12.5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
Number
of opera-
tions with
corrosive
waste3
3
0
3
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
2

-------
                                                Table 4-4  (continued)
f1
Number of waste management operations with at least one sample:


Mining
industry
segment
Total
(All segments)



Type of
waste
management
operation
No. mines involved
Mine waste
Dump/Heap leach
Tailings
Number
of waste
management
operations
analyzed
78
43
10
52

Having pH
less than
or equal
to 2
4
0
3
1


Having pH
between
2 and 4
10
6
3
3


Having pH
between
10 and 12.5
8
0
1
7

Having pH
greater than
or equal
to 12.5
1
0
0
1
Number
of opera-
tions with
corrosive
waste3
5
0
3
2
a A waste is corrosive only if its pH is  less  than or equal  to 2  or greater than or equal  to 12.5.
b The number of mines involved may be less than the sum of sampled operations  if one mine  has more  than one  operation;
   for example, the same mine site might  have  both mine waste and one  or more  leach operations.
c Mine waste includes mine water.
d Includes antimony, bauxite, beryllium,  mercury,  nickel,  rare earth metals,  titanium,  tungsten,  and vanadium.
Source:  PEDCo Environmental, Inc. 1984,  ERCO  1984, and Harty and Terlecky  1982.

-------
Standards (NIPDWS) (40 CFR Part 141).   EP toxic  levels  are:
    •    Mercury (Hg)  >0.2 mg/1;
    •    Cadmium (Cd) or selenium (Se)  si.0 mg/1;
    •    Silver (Ag), arsenic (As),  total chromium  (Cr),
         or lead (Pb)  2=5.0 mg/1;  and,
    •    Barium (Ba)  ^100 mg/1.

    EPA designed the EP toxicity test to simulate the leaching of hazardous
constituents from a sanitary landfill  into ground water.   It approximates  the
conditions prevalent within a landfill where weak organic  acids may come in
contact with toxic metals.  In recognition of the fact  that contaminant
concentration levels would decrease  between  the  point at which the leachate
migrates from the waste and the point  of human or environmental exposure,  EPA
set EP toxicity levels for contaminants in leachate  at  100 times  the levels
acceptable in drinking water.  An  attenuation factor of 100 was used rather
than a lower level (e.g., 10 times the drinking  water limit) because of the
lack of empirical  data on which to base an attenuation  factor,  the  absence of
a variance procedure (i.e., delisting) for wastes that  fail the EP test, and
because "EPA believes the...[extraction procedure] to be a somewhat less
precise instrument than the listing  mechanism for determining  hazard,  inasmuch
as the EP fails to take into account factors such as the concentration of
toxicants in the waste itself and the quantity of waste generated which would
have a bearing on the hazardousness  of the waste" (45 FR 33111, May 19, 1980).
EPA preferred therefore to "entrust  determinations of marginal  hazard to the
listing mechanism rather than to the EP" (45 FR  33111,  May 19,  1980).  In
                                     4-14

-------
adopting the 100-fold attenuation factor,  the Agency explained that "anything
which fails the EP at this factor has the potential  to present a substantial
hazard regardless of the attenuation mechanisms at play" (45 FR 33111,  May 19,
1980).
    The metals measured by RCRA's EP toxicity test can, however, cause  some
types of environmental damage at levels much lower than those that fail  RCRA's
EP toxicity test or even EPA's National Interim Primary Drinking Water
Standards, especially if these metals are contained in wastes that contaminate
surface water rather than ground water.  Accordingly, the 24-hour average
level of EP metals set by EPA's Ambient Water Quality Criteria for the
Protection of Aquatic Life are, in all cases, lower than those permitted by
EPA's drinking water standards, and therefore are much lower than the levels
allowed by RCRA's EP toxicity test.  This does not mean that all mining wastes
meeting the EP toxicity test pose a threat to aquatic life,  because the EP
leaching procedure was designed to evaluate the potential  of a given waste for
unacceptable degradation of ground water and assumed that the wastes would be
disposed of above an aquifer supplying drinking water (a conservative
assumption).  Table C-l in Appendix C of this report provides a comparison of
EP toxicity levels, drinking water levels, and ambient water quality levels
for the metals measured by the EP toxicity test.  Research findings on  the
levels of metals measured by the EP toxicity test (i.e., arsenic, cadmium,
chromium, lead, mercury, and selenium) that are toxic to aquatic biota  are
summarized in Tables C-2 to C-7 of Appendix C.
    EPA's sampling results indicate that a small percentage  of the mining
waste samples were EP toxic.  Of the 332 samples from the metals mining
                                     4-15

-------
industry segments,  21  (6 percent)  exhibited  the characteristic of EP
toxicity.  These 21  samples  were from the  copper, gold, lead, silver, zinc,
and other metals industry segments.   An  additional 39 samples had elevated
levels (i.e., between  20 and 100 times the levels permitted by the drinking
water standards) of the metals  measured  by the EP toxicity test; these
additional samples  came from these same  industry segments and from the uranium
and phosphate mining segments.  These results are summarized in Table 4-5.
    Tables 4-6 and  4-7 differentiate  EP  toxicity test results for solid
samples and liquid  samples,  respectively.  Twenty of the 21 EP toxic samples
were solid samples  and 31 of the 39 samples  with elevated levels (i.e.,
between 20 and 100  times the levels permitted in the drinking water standards)
of the metals measured by the EP toxicity  test were solid samples.  One liquid
sample was EP toxic, and it  was from  the copper industry segment.
    Table 4-8 identifies all industry segments that had at least one EP toxic
sample or one sample with an elevated level  of one of the metals measured by
the EP toxicity test.   Samples  from 86 mines were tested for EP toxicity.  At
least one sample from 10 of  these  mines  was  EP toxic, and 29 mines had at
least one sample with an elevated  level  (i.e. greater than 20 times the
NIPDWS) of an EP toxic metal.  A particularly high percentage of samples from
gold heap leach and tailings, lead mine  waste and tailings, zinc tailings, and
copper dump leach operations had EP toxic  or elevated levels of one of the
metals measured by  the EP toxicity test.  Four of the eight copper dump leach
operations, three of the seven  zinc tailings operations, four of the six gold
tailings operations, two of  the three gold heap leach operations, and five of
the six lead operations  had at least one  sample with a level of one of the
metals measured by  the EP toxicity test  greater than or equal to 20 times the
NIPDWS.
                                     4-16

-------
          Table 4-5  Results of EP Toxicity Analyses  for All  Samples



Mining
industry
segment
Metals:
Copper
Gold
Iron
Lead
Molybdenum
Si 1 ver
Uranium
Zinc
Other metal sb
Subtotal
Nonmetal s :
Asbestos
Phosphate
Subtotal
TOTAL



Number of
samples
analyzed

83
26
31
15
15
25
67
25
45
332

7
70
77
409
Number of samples
with at least one
EP toxic metal at
level between
20 and 100X
the NIPDWSa

4 (5%)
7 (27%)
0
4 (27%)
0
3 (12%)
5 (7%)
5 (20%)
8 (18%)
36 (11%)

0
3 (4%)
3
39 (10%)



Number of
samples
EP toxic9

1 (1%)
3 (12%)
0
6 (40%)
0
4 (16%)
0
4 (16%)
3 (7%)
21 (6%)

0
0
0
21 (5%)
a Numbers in parentheses are percentages of all  samples  analyzed  for that
  industry segment that had the hazardous characteristic.

D Includes antimony, bauxite, beryllium, mercury,  nickel,  rare earth metals,
  titanium, tungsten, and vanadium.

Source:  PEDCo Environmental, Inc.  1984, ERCO 1984,  and  Harty and Terlecky
         1982.
                                       4-17

-------
         Table 4-6  Results of EP Toxicity Analyses for Solid Samples



Mining
industry
segment
Metals:
Copper
Gold
Iron
Lead
Molybdenum
Si 1 ver
Uranium
Zinc
Other metal sb



Number of
sampl es
analyzed

72
22
30
14
14
22
63
22
39
Number of samples
with at least one
EP toxic metal at
level between
20 and 100X
the NIPDWS3

1 (IX)
4 (18%)
0
4 (29%)
0
3 (14%)
5 (8%)
5 (23%)
6 (15%)



Number of
samples
EP toxic3

0
3 (14%)
0
6 (43%)
0
4 (18%)
0
4 (18%)
3 (8%)
      Subtotal
Nonmetal s;
Asbestos
Phosphate
Subtotal
TOTAL
298

  5
 68
 73
371
28 (9%)

 0
 3 (4%)
 3 (4%)
31 (8%)
20 (7%)

 0
 0
 0
20 (5%)
a Numbers in parentheses are percentages of all  samples analyzed for that
  industry segment that had the hazardous characteristic.
b Includes antimony, bauxite, beryllium, mercury,  nickel,  rare earth metals,
  titanium, tungsten, and vanadium.
Source:  PEDCo  Environmental, Inc.  1984, ERCO 1984,  and Harty and Terlecky
         1982.
                                      4-18

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         Table 4-7  Results of EP Toxlcity Analyses  for Liquid  Samples



Mining
industry
segment



Number of
sampl es
analyzed
Number of samples
with at least one
EP toxic metal at
level between
20 and 100X
the NIPDWS3



Number of
sampl es
EP toxic3
Metals:

Copper
Gold
Iron
Lead
Molybdenum
Silver
Uranium
Zinc
Other metals3

      Subtotal

Nonmetals:

Asbestos
Phosphate
      Subtotal
TOTAL
11
 4
 1
 1
 1
 3
 4
 3
 6

34
 2
 2

 4

38
  (27%)
  (75%)
  (33%)
8 (24%)



0
0

0

8 (21%)
1 (9%)
0
0
0
0
0
0
0
0

1 (3%)
0
0

0

1 (3%)
a Numbers in parentheses are percentages of all  samples analyzed for that
  industry segment that had the hazardous characteristic.

b Includes antimony, bauxite, beryllium, mercury,  nickel,  rare earth metals,
  titanium, tungsten, and vanadium.

Source:  ERCO 1984 and Harty and Terlecky 1982.
                                     4-19

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                   Table 4-8  Number of Mines and Waste Management Operations with EP Toxic  Samples or Samples
                              Having Elevated Levels of Metals, as Measured by the EP Toxicity Test
i
INi
O



Mining
industry
segment
Copper



Gold



Lead


Phosphate


Si 1 ver





Type of
waste
management
operation
No. mines involved
Mine waste
Dump leach
Tailings
No. mines involved
Mine waste
Heap leach
Tailings
No. mines involved
Mine waste
Tai 1 i ngs
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Heap leach
Tailings



Number of
operations
analyzed
13
11
8
13
6
6
3
6
4
2
4
13
13
10
6
4
0
6
Number of
operations
with at least
one EP toxic
sample
(100X NIPDWS)
1
0
1
0
2
1
0
2
3
1
2
0
0
0
1
1
0
1
Number of
operations
with at least
one sample
between 20 and
100X NIPDWS3
3
0
3
0
5
0
2
3
2
1
2
3
1
2
2
1
0
1
Number of
operations
with at least
one sample
greater than 2 OX
the NIPDWS&
4
0
4
0
5
1
2
4
3
2
3
3
1
2
2
1
0
2

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                                           Table 4-8  (continued)



Mining
industry
segment
Uranium


Zinc


Other Metalsc


TOTAL
(All segments)




Type of
waste
management
operation
No. mines involved
Mine waste
Tai 1 i ngs
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Dump/Heap leach
Tailings



Number of
operations
analyzed
17
17
NA
7
5
7
10
7
9
86
75
11
65
Number of
operations
with at least
one EP toxic
sample
(100X NIPDWS)
0
0
NA
2
0
2
1
1
1
10
4
1
8
Number of
operations
with at least
one sample
between 20 and
100X NIPDWSa
5
5
NA
3
1
3
5
2
3
28
11
5
14
Number of
operations
with at least
one sample
greater than 20X
the NIPDWSb
5
5
NA
3
1
3
5
2
4
29
13
6
18
NA indicates not applicable to this  report.

a Samples were not EP toxic but had  elevated  levels  of EP  toxic  metals.

b Samples were EP toxic or had elevated  levels of  EP toxic  metals;  results  in  this
  column may not equal  the sum of results  in  the previous  two  columns because  samples were  often  tested  for
  more than one EP toxic metal.

c Includes antimony, bauxite,  beryllium, mercury,  nickel,  rare earth metals, titanium,  tungsten and
  vanadium.

Source:  PEDCo Environmental,  Inc. 1984, ERCO 1984,  and Harty  and Terlecky  1982.

-------
    Table 4-9 shows the number and  percentage of EP  toxic samples and the
number of samples having elevated levels of  the metals measured by the EP
toxicity test, by type of metal.  Nineteen of the  21 samples failing the
standard EP toxicity test failed because they had  EP toxic levels of lead; in
addition, 15 of the 39 samples with elevated levels  of metals measured by the
EP toxicity test had elevated levels of lead.
    For purposes of comparison with these EP toxicity test results, most mine
waste samples, most settled solid samples, and some  low-grade ore samples were
subjected to a modified EP toxicity test in  which  deionized water, rather than
acetic acid, was used as the extracting medium.    None of the 214 samples
subjected to this test produced leachates containing metal concentrations at
the EP toxic level, including the samples from the lead  industry.  These
modified EP test results show that  in at least some  mining waste situations,
lead and other toxic metal constituents may  not be mobilized.  Actual leachate
samples were usually not obtained,  and therefore actual  leachate
concentrations are unknown.
    Since sulfuric acid simulates the situation in which waste leaches into an
acidic environment more closely than does acetic acid, sulfuric acid might be
an appropriate test leaching medium for modeling such an environment.  For
example, when lead combines with  sulfuric acid, the  lead sulfate that is
formed precipitates out of the solution, which renders the  lead less  soluble
than it would be if it were combined with acetic acid.   The  results  from EPA's
modified EP toxicity test using deionized water, and information on  the fate
of some waste constituents in acidic environments, suggest  that additional
toxicity tests may be necessary to  simulate  the potential hazard posed by  some
mining wastes in some environments.
                                     4-22

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                          Table 4-9  Number and Percentage of EP Toxic Samples and Samples Having
                                         Elevated Levels of Metals Measured by the
                                            EP Toxicity Test, by Type of Metal
IN3
GO





EP toxic
metal s
Arsenic
Barium
Cadmium
Chromi urn
Lead
Mercury
Silver
Sel eni urn



Number of
samples
EP toxic
(100X NIPDWS)3
1
0
1
0
19
1
0
0




Percentage of
all EP toxic
sampl esa
5
0
5
0
86
5
0
0
Number of
samples with
elevated levels of
EP toxic metals
(greater than 20
and less than 100X
NIPDWS)b
3
2
6
3
15
8
0
6
Percentage of
al 1 sampl es
with elevated
levels of metals
(greater than 20
and less than 100X
NIPDWS)b
8
5
15
8
38
21
0
15
       a Twenty-one  samples were EP toxic.  However, one of these samples had EP toxic levels of two of the metals
         measured by  the  EP toxicity test.

       b Thirty-nine  samples contained metals measured by the EP toxicity test at levels between 20 and 100 times
         the NIPDWS.  Many of  these samples contained these levels for more than one of the metals.

       Source:   PEDCo Environmental Inc. 1984, ERCO 1984, Harty and Terlecky 1982.

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4.1.1.3  EP Toxicity and Corrosivity (Copper  Disnp  Leach  Liquor)
    In the case of dump leach liquor from copper dump  leach operations,  EPA
believes that the results of the sampling and analyses performed  on  these
samples and presented in Table 4-10 indicate  that  this waste may  be  a
potential candidate for listing because  of its acidity and relatively high
concentrations of toxic metals.   Partial  results for samples of this waste
were presented in Tables 4-3 and 4-4 (Results of Corrosivity Analyses) and
Tables 4-5, 4-7, and 4-8 (Results of EP  Toxicity Tests).
    As shown in Table 4-10,  the sample from leach  operation no. 1  was EP
toxic, with an arsenic level of 7.8 mg/1  (156 times  the  NIPDWS) and  a cadmium
level of 1.8 mg/1 (180 times the NIPDWS).  Samples from  all three leach
operations had arsenic and cadmium levels at  least 50  times their respective
NIPDWS limits.  Samples from two of the  three operations had levels  of
chromium and selenium greater than 20 times the NIPDWS.   Two of the  three
copper dump leach samples were corrosive, with pH's  of less than  2,  and  the
sample from the third site had a very low pH  (2.49).
4.1.2  Other Characteristics
    The other criteria used in this report to assess the potential hazard of
mining waste include properties such as  radioactivity  and acid formation
potential , and the presence at certain levels of hazardous constituents  such
as cyanide or asbestos.  These constituents and properties are considered to
be potentially hazardous because they are believed to  pose a threat  to human
health and the environment if they are present in  waste,  including mining
waste, at the levels specified below.
4.1.2.1  Cyanide
    For the purpose of this report, EPA assessed liquid  mining waste samples
in relation to various cyanide levels:  greater than or  equal to  2 mg/1,
                                     4-24

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          Table 4-10  Results of Corrosivity and EP Toxicity Analyses
                      of Copper Dump Leach Liquor Samples
Tested
characteristic
Sample from
leach
operation
no. 1 (mg/1 )
Sample from
leach
operation
no. 2 (mg/1 )
Sample from
leach
operation
no. 3 (mg/1 )
PH

Arsenic
  mg/1
Bari urn
  mg/1

Cadmi urn
  mg/1
Chromium
  mg/1
Lead
  mg/1

Mercury
  mg/1

Seleni urn
  mg/1
Si 1ver
  mg/1
1.82
1.8
(180 X NIPDWS)
3.4
(68 X NIPDWS)
0.57
(57 X NIPDWS)
                    1.95
7.8                 3.5
(156 X NIPDWSa)     (70 X NIPDWS)
                    0.82
                    (82  X NIPDWS)
                    1.2
                    (24  X  NIPDWS)
                    0.35
                    (35 X  NIPDWS)
2.49
                                          2.5
                                          (50 X NIPDWS)
0.55
(55 X NIPDWS)
0.81
(16 X NIPDWS)
                                          0.13
                                          (3  X  NIPDWS)
National  Interim Primary Drinking Water Standards.

bDash (--) indicates level of this metal  was less than the NIPDWS  limit.

Source:   ERCO 1984.
                                      4-25

-------
greater than or equal  to  10 mg/1, and greater than or equal to 20 mg/1.  These
levels are 10,  50,  and 100 times, respectively, the ambient water quality
(AWQ) criterion for cyanide for  the  protection of human health (assuming daily
ingestion of 2  liters  of  contaminated drinking water and 6.5 grams of tissue
from organisms  living  in  the  same contaminated water).  In the cost analysis
section of this report, EPA used a cyanide  level of greater than or equal to
10 mg/1 to define the  threshold  of hazard.   (No samples from the iron,
uranium, other  metals, asbestos, or  phosphate industry segments were analyzed
for cyanide, because cyanide  is  not  introduced into mining and beneficiation
processes in these industries.)
    Because of  the difficulty of analyzing  waste samples for cyanide, EPA had
several laboratories test several of the  cyanide samples.  Table 4-11 shows
the results of cyanide analyses  of liquid waste samples.   Of 27 liquid  samples
analyzed for cyanide,  8 samples  (30  percent) had at least  one  test result
showing cyanide concentrations greater  than or equal  to 2.0 mg/1:  seven of
the samples were from the gold industry segment, and  one sample was  from the
copper segment.
    All of the cyanide sample test  results  for which  at least  one test  showed
a cyanide level greater than  or  equal  to 2.0 mg/1  are presented in
Table  4-12.  As shown on  this table, the copper  tailings pond  sample had a
cyanide level between 2 and 10 mg/1, and three of  the five gold tailings pond
samples had a cyanide level  of at least 10 mg/1  (and  one of these three gold
tailings samples had a cyanide level of at least  20 mg/1).   Both samples  from
gold heap leach operations had cyanide  levels  greater than 10  mg/1.
     EPA believes that wastes from gold and silver  metal  recovery and heap
leach  operations may be potential  candidates for listing,  because of their
tendency to contain high levels of cyanide.  Although EPA  did  not  take  any
                                     4-26

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        Table  4-11   Results of Cyanide Analyses of Liquid Waste Samples
                                                   Number  of  samples
                                                   with at least one
                                                      test result
          Mining            Number of              showing CN greater
          industry          samples                  than  2 mg/la
          segment           analyzed                   (10X AWQ)
          Metals:

          Copper               13                  1  (8)
          Gold                  7                  7  (100)
          Lead                  3                      0
          Molybdenum            3                      0
          Zinc               	l_                 	0_

          TOTAL                27                  8  (30)
a Numbers in parentheses  are percentage  of  samples taken  in that
  industry segment having the potentially hazardous characteristic.

Source:  Personal  Communication  from PEDCo  Environmental,  Inc. 1984; ERCO
         1984.
                                      4-27

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                     Table 4-12  Summary of Cyanide Sampling Results  for Liquid  Samples  with  at
                                      Least One Test Result  Greater than 2 mg/1
      Type of mine,
      operation,
      and sample
      identification
                       Number
                      of tests
    Number
   of tests
with CN values
  less than
   2 mg/1
    Number
   of tests
with CN values
  between 2
 and 10 mg/1
    Number
   of tests
with CN values
  between 10
 and 20 mg/1
Number of tests
with CN values
  greater than
  or equal to
    20 mg/1
ro
c»
Copper mine
 Tailings pond
 Sample A

Gold mine 1
 Tailings pond
 Sample A
 Sample B

Gold mine 2
 Tailings pond
 Sample A
 Sample B

Gold mine 3
 Tailings pond
 Sample A

Gold mine 4
 Barren leach pond
 Sample A

Gold mine 5
 Pregnant heap leach
 Sample A
                                3
                                4
                                4
                                5
                                                            1
                                                            5
      Source: Personal  communication from PEDCo  Environmental, Inc. 1984; ERCO 1984.

-------
samples of silver heap leach operations  specifically,  the  similarity of gold
and silver heap leach operations makes it likely  that  silver heap leach wastes
also have high levels of cyanide.   With  few exceptions,  gold and silver values
that are leached are extracted from finely crushed ores, concentrates,
tailings, and low-grade mine rock by dilute and weakly alkaline solutions  of
potassium cyanide or sodium cyanide.
    In analyses performed to support the promulgation  of effluent limitations
guidelines and standards for the ore mining and dressing point source category
(i.e., metals mining and beneficiation), EPA's Effluent Guidelines  Division
(now the Industrial  Technology Division) found that 2  of 68 mill wastewater
samples tested for cyanide from the copper/lead/zinc/gold/silver/platinum/
molybdenum industrial subcategory had cyanide levels greater than 2 mg/1 but
less than 10 mg/1.   But these were influent samples (to treatment) and
would be treated prior to discharge.  The highest discharge level,  even
without adequate treatment, was 0.4 mg of total cyanide per liter.  Free
cyanide was not measured.
    Cyanide is an environmental hazard at levels  significantly lower  than
2 mg/1 (EPA's Cyanide Ambient Water Quality Criteria for the protection of
human health).  The 24-hour average level of cyanide allowed by EPA's Ambient
Water Quality Criteria for the protection of freshwater aquatic life  is 0.0035
mg/1, with the concentration not to exceed 0.052  mg/1  at any time  (45 FR
79331; November 20, 1980).  Table C-8 in Appendix C summarizes research
findings on the toxicity of cyanide to aquatic biota.
4.1.2.2  Radioactivity
    Naturally occurring radionuclides in mining waste  and  ore may  pose  a
radiation hazard to human health if the waste is  used  in construction or  land
                                     4-29

-------
reclamation or if concentrations  of radionuclides  (e.g.,  radium-226)  are  high
enough to produce significant concentrations  of  hazardous decay  products
(e.g., radon-222).
    Two criteria have been used in  this report to  assess  potentially  hazardous
levels of radioactivity in mining waste.   These  criteria  are  both  based on
EPA's Standards for Protection Against Uranium Mill  Tailings  (40 CFR  Part
192).  These regulations contain  a  "cleanup"  standard  for uranium  mill
tailings that is set at a limit of  5 pCi  of radium-226 per gram  for the first
15 centimeters of soil  below the  surface.   (The  5  pCi/g radioactivity
criterion was also chosen by EPA  in an Advance Notice  of  Proposed  Rulemaking
published in 1978 (43 FR 59022) that solicited comments on expanding  the  list
of RCRA hazardous waste characteristics to include a "radioactivity
charcteristic".)  The second radioactivity criterion used in  this  report, 20
pCi or more of radium-226, is based on the "disposal  design"  portion  of the
same standard, which requires that  the average release rate of radon-222  not
exceed 20 pCi per square meter per  second.  In this report, EPA  made  the
conservative assumption that each picocurie of radium-226 per gram of waste
produces an average release rate  of 1  pCi  of radon-222 per square  meter per
second.  As a result, a radioactivity criterion  of 20 pCi or  more  of
radium-226 per gram of waste can  be assumed to include all wastes  that would
fail to meet the radon-222 criterion set forth in  40 CFR  Part 192.
    EPA analyzed selected mining  wastes to determine their radium-226
concentrations.  Of 187 solid waste samples,  69  (37 percent)  had radium-226
concentrations greater than or equal to 5 pCi/g.  These samples  were  from the
uranium, "other" metals, and phosphate mining segments.  Of the  same  187
samples, 34 (18 percent) had radium-226 concentrations greater than or equal
                                     4-30

-------
to 20 pCi/g; these samples were also from the uranium,  other metals  group,  and
phosphate mining industry segments.   Results  of the  radium-226  analyses  are
presented in Table 4-13.   (Asbestos  samples were not tested for radioactivity,
because EPA believed that wastes from this industry  segment were unlikely  to
be radioactive.)
    The number of mines and waste management  operations having  radioactive
samples is presented in Table 4-14.   All  17 uranium  mines sampled by EPA had
at least one mine waste sample with  a level of radium-226 greater than or
equal to 5 pCi/g.  Fourteen of the 17 mines had at least one mine waste  sample
of radium-226 greater than or equal  to 20 pCi/g.  Ten of the 13 phosphate
mines sampled by EPA had at least one sample  with a  level of radium-226
greater than or equal to 5 pCi/g.  Only 2 of  these mines, however, had samples
with levels of radium-226 greater than or equal to 20 pCi/g. Two of the three
other metals mines sampled had at least one sample with a level of radium-226
greater than or equal to 5 pCi/g.  Only one of these mines, however, had a
sample with a radium-226 level greater than or equal to 20 pCi/g.
    Much of the available scientific literature concerned with  radiation
effects on organisms focuses on human health; information on these radiation
effects is summarized in Table C-9 of Appendix C.
4.1.2.3  Asbestos
    EPA chose to evaluate asbestos as a potentially  hazardous mining waste
constituent because of the well-documented inhalation danger that asbestos
fibers, even in very small quantities, pose to human health. The health
effects of asbestos exposure and the rationale for the level of asbestos
considered in this report to be potentially hazardous are described  below.
                                     4-31

-------
      Table 4-13  Results of Radioactivity Analyses of Solid Waste Samples
Mining
industry
segment
Metals:
Copper
Gold
Iron
Lead
Molybdenum
Si 1 ver
Uranium
Zinc
Other metal sa
Subtotal
Nonmetals:
Phosphate
TOTAL
Number of
sampl es
analyzed
17
4
8
4
6
6
58
10
7
120
67
187
Number of samples
with Ra-226 levels
greater than
or equal to 5 pCi/g"5
0
0
0
0
0
0
40 (69%)
0
5 (71%)
45 (38%)
24 (36%)
69 (37%)
Number of samples
with Ra-226 levels
greater than
or equal to 20 pCi/gb
0
0
0
0
0
0
29 (50%)
0
2 (29%)
31 (26%)
3 (4%)
34 (18%)
alncludes antimony,  bauxite,  beryllium,  mercury,  nickel,  rare earth metals,
 titanium, tungsten, and vanadium.

Numbers in parentheses show percentage  of  samples taken  in that  industry
 segment having the  potentially hazardous characteristic.

Sources:  PEDCo Environmental,  Inc.  1984, ERCO 1984,  and  Harty and Terlecky  1982.
                                    4-32

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                                     Table 4-14  Number of Waste  Management Operations
                                                Having Radioactive Samples
                                                                        Number of
                                                                        operations
                                                                      with at least
                                                                        one sample
                                                                      with level  of
  Number of
  operations
with at least
  one sample
with level of
CO
00
Mining
industry
segment
Uranium

Phosphate


Other metal sa


Total



Type of waste
management
operation
No. mines involved
Mine waste
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Tailings
No. mines involved
Mine waste
Heap/dump leach
Tailings
Number of
operations
sampled
17
17
13
13
10
3
2
3
62
55
2
41
Ra-226 greater
than or equal
to 5 pCi/g
17
17
10
8
6
2
2
2
29
27
0
8
Ra-226 greater
than or equal
to 20 pCi/g
14
14
2
0
2
1
1
1
17
15
0
3
              alncludes antimony, bauxite,  beryllium,  mercury,  nickel,  rare  earth metals,
                titanium, tungsten, and vanadium.
              Source:  PEDCo Environmental,  Inc.  1984 and ERCO  1984.

-------
    According to the 1982 EPA Support Document for the Final  Rule on Friable
Asbestos-Containing Materials in School  Buildings, "the hazards of asbestos
exposure identified by epidemiologic research are cancers of the lung, pleura,
peritoneum, larynx, pharynx and oral cavity,  esophagus, stomach, colon and
rectum, and kidney.  Inhalation of asbestos fibers also produces a non-
cancerous lung disease, asbestosis."  Pleural and peritoneal  mesotheliomas
(cancers) are considered "signature" diseases for asbestos exposure; that is,
these diseases are almost always caused  by asbestos exposure.   There are
well-documented cases of mesotheliomas occurring in persons residing within a
                                                                  g
mile of an asbestos mine who had no other known asbestos exposure.
    EPA has promulgated a National Emission Standard for asbestos (40 CFR
Part 61, Subpart M) under Section 112 of the Clean Air Act, establishing
asbestos disposal requirements for active and inactive disposal sites.  The
regulation requires owners and operators of demolition and renovation projects
to follow specific procedures to prevent asbestos emissions to the outside
air, and further requires that demolition and renovation material  be
controlled if the material  contains more than 1  percent asbestos by weight in
a form that "hand pressure can crumble,  pulverize, or reduce to powder when
dry."  In this report, the Agency used this 1 percent criterion to determine
when mining wastes should be considered  potentially hazardous on the basis of
their asbestos content.
    Only five waste samples obtained from asbestos mining and milling sites
were analyzed for asbestos.  The results of these analyses, shown in
Table 4-15, indicate that the asbestos content of all of these samples greatly
exceeded 1 percent.
                                     4-34

-------
       Table 4-15  Results of Asbestos Analyses
Sample
number
1
2
3
4
5
Type of
asbestos
Chrysotile
Chrysotile
Chrysotile
Chrysotile
Chrysotlle
Estimated percentage
asbestos
by weight
20-40
5-20
70-85
30-50
70-90
Source:  Based on analyses performed by the Industrial
         Environmental Research Laboratory, U.S.
         Environmental Protection Agency, Cincinnati, Ohio.
                           4-35

-------
    Regulations in Subpart M of 40 CFR Part 61  also contain standards for
emissions from asbestos mills and active and inactive asbestos waste disposal
sites.  According to these regulations, owners  and operators of asbestos mills
must ensure that their facilities either discharge no visible emissions to the
outside air, or use air cleaning devices to clean emissions as specified in 40
CFR 61.154.  Owners and operators of active asbestos waste disposal  sites must
ensure that no visible asbestos emissions are discharged to the outside air,
cover asbestos-containing waste material at least once a day, or receive
approval from the Administrator of EPA to use alternate control measures.  The
regulation also requires security measures for active and inactive asbestos
waste disposal  sites.
    There is evidence that asbestos is present in many of the wastes generated
by the metals mining industry segments covered  in this report.  Asbestiform
amphibole fibers from taconite mill tailings were detected at high
                                                                  g
concentrations (14-644 million fibers per liter) in Lake Superior.
Sampling performed by EPA's Effluent Guidelines Division to develop effluent
limitations guidelines and standards for the ore mining and dressing point
source category showed that asbestos fibers were present in mine or mill water
from almost all metals mining industry segments.    Based on these results
and on a statistical comparison with the suspended solids data, EPA found that
by controlling the suspended solids in the discharge, the asbestiform fiber
concentrations were effectively controlled in this industry.
    Some effects of asbestos exposure, such as toxicity, bioaccumulation,
cytotoxicity, asbestosis, and carcinogenicity on humans, bacteria, aquatic
biota, and rats are summarized in Table C-10 in Appendix C.
                                     4-36

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4.1.2.4  Acid Formation Potential
    The exposure and subsequent oxidation of naturally occurring metal
sulfides (especially iron pyrite)  in ores and mining waste can produce  acid,
which may increase the leaching and mobility of toxic waste constituents,
including the heavy metals.  Wastes that contain significant amounts of iron
pyrites (FeS^) or other base metal  sulfides may release acids and metals for
many decades.  The hazard is initiated by the chemical reaction of air, water,
pyrite, and pyrrhotite or other iron-bearing sulfides to produce sulfuric  acid:
                   4FeS2  + 15 02 +  14H20—4Fe(OH)3,+ 8H2$04
For example, the oxidation of the pyrite in 1 ton of waste having a 1 percent
pyritic sulfur content would produce 15 kilograms of sulfuric acid.  Unless
the acid is neutralized (by the alkalinity of the water or by reaction  with
carbonate material in the waste),  the acid will reduce the pH of the water and
increase the concentration of the potentially toxic waste constituents,
especially metals, that are leached and transported.
    The potential effect of acid drainage on the concentration of metals in
leachate is illustrated in Figure 4-2.  For example, at a pH of 5.5, the free
metal ion concentration in equilibrium with solid oxides or hydroxides  of
mercury (Hg) is approximately 0.0002 mg/1.  If enough acid is added to  the
water to reduce the pH from 5.5 to 4.5, the concentration of mercury increases
to more than 0.02 mg/1, an increase of more than two orders of magnitude.
Although the diagram is an oversimplification and does not reflect the
complexities of the real  world, it does demonstrate that acid may greatly
increase the concentration of metals in leachate and exacerbate environmental
hazards.
                                     4-37

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                                                                          Mercury Concentration  (mg/1)
                                                                     o
                                                                          o
                                                                     CD   •
                                                                     O   O
                                                                     O   O
                                                                     ro
                                                                   ro
CO
00
                               (ID
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                                ro
                             3 -I

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                                -J
                              l/> O
                              o c
                             o o
                             X 3

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                             n> o
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                                o
                             o n>
                             -j 3
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                             -J -••
                             O O
                             X 3
                             — >. tn
                             CL
                             n> — ••
                             in 3
cr>
00
                                                                   ro
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                                                                                          JL
                             ro
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CD
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-------
    For this report, EPA estimated the quantity of metal  mining waste that
poses an acid drainage problem, using information on the mineral content of
metal ores from 115 mines producing more than half of all the tailings
generated by the metals mining industry segments represented in the U.S.
Bureau of Mines Minerals Availability System data base.
    To estimate whether the tailings from these mines have high, uncertain, or
no acid formation potential, EPA made the following assumptions:
    t    If the data base reports that the minerals content of the ore in a
         particular mine includes pyrites and/or other metal sulfides but does
         not include carbonates, the tailings from that mine have a high
         potential for forming acid.
    •    If the data base reports that the minerals content of the ore in a
         particular mine includes pyrites and/or other metal sul fides and
         carbonates, the tailings from that mine have an uncertain potential
         for forming acid.
    •    If the data base reports that the minerals content of the ore in a
         particular mine does not include pyrites and/or other metal  sulfides,
         the tailings from that mine have no potential for forming acid.
    The number of mines that generate tailings with high, uncertain, and no
acid formation potential are presented, by industry segment, in Table 4-16.
According to Table 4-16, mines having the highest acid formation potential are
found in the copper, gold, and silver industry segments.
    The limitations of these data are:
    •    The data base does not report the mineral composition of the soil or
         rock that is removed at mines to gain access to an ore body.   It was
         assumed that ore constituents were similar to waste (gangue)
                                     4-39

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             Table 4-16  Estimated Acid Formation Potential  of Tailings at Active
                          Metal  Mines by  Industry  Segment
Mining
industry
segment
Copper
Gold
Iron
Lead
Silver
Zinc
Number
of active
mines for
which minerals
data exists
24
15
25
15
19
18
Number of
mines with high
acid formation
potentiala»d
9 (38)
6 (40)
0
1 (7)
6 (31)
0
Number of mines
with uncertain
acid formation
potential b»d
13 (54)
3 (20)
9 (36)
14 (93)
10 (53)
17 (94)
Number of mines
with no acid
formation
potentiaic.d
2 (8)
6 (40)
16 (64)
0
3 (16)
1 (6)
a High Acid Formation Potential - Tailings derived from ores containing pyrites
  and/or other metal  sulfides but no carbonate minerals (which would tend to neutralize
  produced acids).

b Uncertain Acid Formation Potential - Tailings derived from ores containing pyrites
  and/or other metal  sulfides and carbonate minerals.   (Such wastes  may or may not
  produce acid, depending on the relative ratio of acid-forming to acid-neutralizing
  minerals.)

c No Acid Formation Potential - Tailings from ores containing no pyrites or other metal
  sulfides.

d Numbers in parentheses are percentage of all  mines in an industry  segment.

Source:  Derived from ore minerals information in U.S.  Bureau of Mines Mineral
         Availability System data base.  For this analysis,  only mines active in 1982 were
         considered.

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        constituents, but it is not clear that this extrapolation could be
        extended from tailings to overburden.  For example, the overburden
        may be completely different from the ore and have no acid formation
        potential.
    •    The reason that  EPA categorized the acid formation potential of
        tailings from mines having both acid-forming minerals  (i.e.,
        sulfides) and acid-neutralizing minerals (i.e., carbonates) as
        uncertain is that the actual acid formation potential  of these
        tailings may range from high to none, depending on the relative
        concentrations of acid-forming and acid-neutralizing minerals in the
        tailings.  The concentration processes at  some mills require the
        addition of alkaline materials, which are  mixed with the tailings and
        would reduce the acid formation potential  of these high-sulfide,
        low-carbonate ores.
    •    The presence or  absence of water, which  is necessary for pyrite
        oxidation products to form acid, was not considered when categorizing
        the  acid  formation potential of these tailings, although many mines
        are  located in arid  regions of the country, where  the  lack  of water
        reduces  the potential for acid drainage.
    a    EPA  has  not considered whether chemical, mineralogical, biological,
        cl imatological,  or physical factors  might  also  influence the ability
        of tailings  from particular mines  to form  acid.
    Acid drainage  can lower the pH of streams and other  surface water.
Table  C-ll  in  Appendix C  of this report provides  a  summary  of the effects  of
decreased  pH levels  on fish.
                                     4-41

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         4.2  ESTIMATED AMOUNTS OF POTENTIALLY HAZARDOUS  MINING WASTE
    EPA's methodology for estimating the amount of potentially  hazardous
mining waste is presented in Appendix B to this document.   EPA's estimate of
annual generation of hazardous waste and of the costs  of  treating and
disposing of hazardous waste are based on projections  of  the  number of mines,
the amount of waste generated annually, and the amount of waste existing  on
site during 1985.  EPA felt that a projection to 1985  was preferable to using
historical data because of the rapid changes occurring in the mining industry
in recent years (i.e., declining production in many segments).
    Table 4-17 shows these estimates for eight mining  industry  segments:
asbestos, copper, gold, lead, phosphate, silver, uranium, and zinc.  Since
there were no data on asbestos mines in EPA's data base,  results for asbestos
are based on historical data rather than projections;  these data probably
overestimate the number of active asbestos mines and the  amount of waste
generated at these mines annually, since EPA is aware  that fewer than four
asbestos mines are now in operation.  EPA did not project results for the iron
and molybdenum industry segments, because the wastes generated  by these
segments do not exhibit any of the hazard characteristics for which EPA
tested.  In addition, the other metals industry segments  are not included in
this analysis because of the small number of mines in  these industry segments
and the small amount of potentially hazardous waste generated at these mines
annually.
    As shown in Table 4-17, the copper industry segment generates the largest
amount of waste annually: 632 million tons per year.  The phosphate industry
segment, generating 518 million tons of waste per year, has the second highest
rate of annual waste generation.  In many industry segments, the amount of
waste existing on site is very large, exceeding the annual amount of waste
generated  by a factor of 20 to 40.

                                     4-42

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     Table  4-17   Estimated  Number  of Active Mines, Annual Amount of Waste
                Generated,  and  Waste Existing on Site for 1985
Mining
industry
segment
Asbestos**
Copper
Gold
Lead
Phosphate
Si 1 ver
Uranium
Zinc
Estimated
number
of active
mines
4
22
100
7
34
50
50
12
Annual generation
of waste (millions
of metric tons)
5
632
65
9
518
17
91
3
Wastes existing
on site
(millions of
metric tons)9
NA
20,789
218
395
16,599
57
1,564
19
NA indicates data not available.
a Data extrapolated to industry segment based on  estimates  from Charles  River
    Associates.
b Asbestos estimates developed by EPA.
Source:  Adapted from Charles River Associates 1985c.
                                      4-43

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    Table 4-18 presents EPA's estimates of the amount of mining wastes
generated annually that exhibit the RCRA hazardous waste characteristics and
mining wastes that may be potential candidates for listing, by industry
segment.  The estimated amount of corrosive waste generated annually is 50
million metric tons a year.  All of this corrosive waste is generated by the
copper industry segment.  The estimated amount of EP toxic wastes generated
annually is 11.2 million metric tons per year, and 63 percent of this EP toxic
waste is generated by the gold industry segment.   EP toxic waste is also
generated by the lead, silver, and zinc industry segments.
    Table 4-18 also shows the amount of wastes generated annually of the types
that may be potential  candidates for listing.  The amount of copper dump leach
waste (a potential  candidate for listing because  of low pH and elevated EP
toxicity) generated annually is 182 million metric tons.  Wastes from gold and
silver metal recovery and heap leach operations may be potential  candidates
for listing because of their high levels of cyanide.   The gold and silver
industry segments generate 9.3 million metric tons of metal  recovery wastes
and 14 million metric tons of heap leach wastes annually that may be potential
listing candidates.  The gold industry generates  larger amounts of these
wastes annually than the silver industry.
    Table 4-19 presents estimated annual  generation amounts  for wastes  with
hazardous characteristics that are particularly relevant to  mining industry
wastes:  acid formation potential, radioactivity,  and friable asbestos
content.  EPA estimates that 95 million metric tons of waste have a high
potential  for forming acid;  all  of this waste is  generated in the copper
industry segment.   This estimate of waste having  high acid formation potential
is probably low,  because EPA could only estimate  the  acid formation potential
                                     4-44

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                                       Table 4-18  Estimated Amount of Waste with RCRA
                                      Characteristics Generated Annually and Mining Wastes
                                         That May be Potential Candidates for Listing
-pa

en
RCRA characteristics
Mining
industry
segment
Asbestos
Copper
Gold
Lead
Phosphate
Silver
Uranium
Zinc
TOTAL
Amount of waste
generated annually
(million metric
tons/year)
5
632
65
9
518
17
91
3
1,340
Corrosive
waste
(million
metric
tons/year)
0
50
0
0
0
0
0
0
50
EP toxic
waste
( mi 1 1 i on
metric
tons/year)
0
0
7
2.9
0
1
0
0.3
11.2
Potential candidates for listing
Copper dump
leach wastes
(million metric
tons/year)
0
182
0
0
0
0
0
0
182
Cyanide-treated
gold and silver
metal recovery
wastes (million
metric tons/year)
0
0
9
0
0
0.3
0
0
9.3
Gold and silver
heap leach
wastes (million
metric tons/year)
0
0
11
0
0
3
0
0
14









    Source:   Derived  by  EPA from  data  in Charles River Associates 1985c, PEDCo Environmental, Inc. 1984, and ERCO 1984.

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                        Table  4-19  Estimated Annual Amount of Waste Generated  Exhibiting  Other
                              Potentially  Hazardous Characteristics, By  Industry  Segment
-p>

en



Mining
industry
segment
Asbestos
Copper
Gold
Lead
Phosphate
Silver
Urani urn
Zinc
TOTAL

Annual
production
of waste
(million metric
tons/year)
5
632
65
9
518
17
91
3
1,340

High acid
formation
potential
(million metric
tons /year)
0
95
0
0
0
0
0
0
95

Radi um-226
greater than or
equal to 5 pCi/g
(million metric
tons/year)
0
0
0
0
352
0
91
0
443

Radi um-226
greater than or
equal to 20 pCi/g
(million metric
tons /year)
0
0
0
0
13
0
80
0
93
Friable
asbestos content
greater than
1% by weight
(million metric
tons/year)
5
NA
NA
NA
NA
NA
NA
NA
5
        NA indicates  data not available.

        Source:   Derived by  EPA from data  in  Charles River Associates 1985c,  PEDCo  Environmental,  Inc.  1984,
        and ERCO  1984.

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of tailings (see Section 4.1.2.4).   In addition,  EPA classified the  acid
formation potential  of many tailings piles as uncertain because of lack of
data on the relative proportion of acid-forming to acid-neutralizing minerals
in these tailings, even though some of them probably have a high potential  for
forming acid.
    Table 4-19 presents estimates of radioactive waste at two radioactivity
level s~radium-226 equal to or exceeding 5 pCi/g, and radium-226 equal  to or
exceeding 20 pCi/g.   At the 5-pCi/g level, there are 443 million metric tons
of radioactive waste generated annually, 352 million metric tons in the
phosphate industry segment, and 91 million metric tons in the uranium industry
segment.  If the 5-pCi/g level is used as the hazard criterion, radioactive
waste  is the largest single contributor to the total amount of potentially
hazardous waste generated by  the industry segments of concern.  At the
20-pCi/g level, 93 million metric tons of hazardous radioactive waste are
generated annually: 13 million metric tons in the phosphate industry segment,
and  80 million metric  tons in  the uranium industry segment.
     The total amount of waste  generated annually with a friable asbestos
content of  more than 1  percent by weight  is  5 million metric  tons per year.
This amount may be an  underestimate, because EPA did not sample wastes  from
industry segments other than  the asbestos industry for their  friable asbestos
content.
     Table  4-20  shows the  estimated  amount of potentially hazardous mining
waste  generated annually,  by  industry segment.   If  the radioactivity criterion
used is 5  pCi or  more  of  radium-226 per gram, 755.2 million metric  tons of
potentially hazardous  mining  waste  are  generated  by these  segments  annually.
 If  the radioactivity criterion chosen is  20  pCi  or  more of radium-226  per
gram,  405.2 million metric tons  of  potentially hazardous mining waste  are
                                      4-47

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J2.


oo
                                  Table 4-20  Total Amount of Potentially Hazardous
                                           Mining Waste Generated Annually
                             Annual
                           production
Total amount of
waste with RCRA
  Total amount
 of potentially
hazardous waste''
   (if Ra-226
is greater than
  Total amount
 of potentially
hazardous waste"3
   (if Ra-226
 is greater than
Mining
industry
segment
Asbestos
Copper
Gold
Lead
Phosphate
Silver
Uranium
Zinc
TOTAL
of waste
(million metric
tons/year)
5
632
65
9
518
17
91
3
1,340
characteristics
(million metric
tons /year)3
0
50
7
2.9
0
1
0
.3
61.2
or equal to 5 pCi )
(million metric
tons /year)
5
276
24
2.9
352
4
91
.3
755.2
or equal to 20 pCi )
(million metric
tons /year)
5
276
24
2.9
13
4
80
.3
405.2
            a  RCRA characteristic  waste means corrosive or EP  toxic waste.

            b  Total  potentially hazardous waste means corrosive  and EP toxic waste, waste  containing
              cyanide  at  a  level  greater than 10 mg/1, radioactive waste, wastes containing  friable
              asbestos content greater than  1 percent by weight, and waste with high acid  formation
              potential.
            Source:   Derived by EPA from data  in Charles River Associates 1985c, PEDCo Environmental  Inc.
                     1984,  and ERCO 1984.

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generated annually.  These total estimates do not equal the sum of the amounts
of waste considered hazardous based on individual hazard characteristics,
because waste from a single operation may be classified as potentially
hazardous for several different reasons.  For example, 50 million metric tons
of copper dump leach are corrosive; however, this waste is also included in
the estimate of 182 million metric tons of copper dump leach waste that may be
a potential candidate for listing.
    Sixty-one million metric tons of mining industry waste are hazardous,
according to the RCRA hazardous waste characteristics of corrosivity and EP
toxicity; for comparison, the total amount of hazardous waste generated
annually by all  nonmining industry segments combined is 64 million metric
tons.  The portion of mining industry waste that is hazardous because it is EP
toxic or corrosive is less than 5 percent of the total amount of waste
generated by these industry segments.  Of mining industry wastes that may be
classified as hazardous because they are EP toxic or corrosive, 82 percent are
from copper dump leach operations that generate corrosive wastes, and an
additional  11 percent are EP toxic waste generated by the gold industry
segment.
    Wastes that are hazardous according to the RCRA hazardous waste
characteristics  of corrosivity and EP toxicity constitute 8 percent of the
total amount of  potentially hazardous mining waste generated annually, if the
radioactivity hazard level chosen for radium-226 is equal  to or more than 5
pCi/g.  If the radioactivity hazard level  for radium-226 is equal  to or
greater than 20  pCi/g, mining wastes that are hazardous according to the RCRA
characteristics  of corrosivity and EP toxicity comprise 15 percent of the
total amount of  potentially hazardous waste generated annually.
                                     4-49

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         4.3   EFFECTIVENESS OF WASTE CONTAINMENT AT MINING WASTE SITES
    Because a large amount of mining and  beneficiation waste  is potentially
hazardous, human health and the  environment could be  adversely affected  if
these wastes escape containment.   EPA  commissioned  a  contractor study    to
determine whether mining waste management facilities  leak  and, if  they  do,
whether they release constituents of concern into surface  or  ground water.
The Agency also reviewed the results of other monitoring and  mining studies  to
corroborate its findings.
4.3.1  EPA Study
    EPA selected eight mining sites at which to monitor ground and surface
water.  The study focused on four types of waste (mine waste, tailings,  dump
leach waste, and mine water) and five  mining industry segments  (copper,  gold,
lead, uranium, and phosphate).  Seven  specific region-commodity categories  of
waste were monitored: Arizona copper  tailings ponds,  New Mexico copper  dump
leach wastes, gold tailings ponds from Nevada and  South  Dakota, Missouri lead
tailings, New Mexico uranium mine water ponds, Idaho  phosphate mine waste
piles, and Florida phosphate tailings.
    Ground water and surface water were monitored at  four  sites,  ground water
only at  three sites, and surface water alone at one site.   At each site, four
or five  samples were taken over a 6-  to 9-month period.   Samples  were analyzed
for selected  indicators, properties,  or compounds that might be  evidence of
leakage:  antimony, arsenic, barium,  beryllium, cadmium, calcium,  chloride,
chromium, copper, cyanide, fluoride,  iron, lead, magnesium, manganese,
mercury,  molybdenum, nickel, nitrate,  phosphate, potassium, selenium, silver,
sodium,  sulfate, thallium, vanadium,  zinc, acidity, alkalinity,  conductivity,
pH, radionuclides, settleable solids,  suspended solids, total dissolved
solids,  total organic carbon, and turbidity.
                                     4-50

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    Table 4-21  shows the Agency's interpretation  of the monitoring  results.
These results indicate, with a reasonably high degree of confidence,  that most
of the facilities sampled do leak.   However,  the  data do not demonstrate
conclusively that constituents reach concentrations of concern  at all  sites  or
that they migrate over long distances.
    At the copper mine sites, only ground water was monitored,  because
southwestern streams, in general, flow only after storms.   The  site at which
copper tailings were monitored has surface runoff diversions for such  events.
This site also uses thickened discharge, recovers about 50 percent  of  its pond
water, caps filled tailings ponds with alluvium,  and then revegetates.
Monitoring results showed chloride concentration  gradients and  an increase in
total dissolved solids and sulfate over time in all wells, indicating seepage
from the copper tailings pond.  Concentrations of sulfate (four to  six times
higher than natural, local unimpacted levels) and total dissolved solids (two
to four times higher than natural but within range for the aquifer) exceeded
national drinking water standards in all wells and were even higher for the
tailings pond.   (Drinking water standards include the National  Interim Primary
Drinking Water Standards (NIPDWS) and National Secondary Drinking Water
Standards.  These standards are used as a basis for comparison.) Although the
well farthest from the water table mound formed from pond seepage had the best
water quality, concentrations of metals were very low (near detection limits)
in all wells.
    Copper dump leach liquor at the operation studied was very  acidic,
contained high levels of total dissolved solids,  and exceeded nearly all
primary and secondary drinking water standards.  The pregnant leach liquor is
collected in a leachate collection pond and pumped back to the  precipitaion
                                     4-51

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                                        Table 4-21   Results  of  the Monitoring  Program
en
ro
      Industry
      segment and
      management
      practice
   Impact on
      Copper  tail ings
        pond

      Copper  dump leach

      Gold  tailings  pond
      Gold  tailings  pond
      Lead  tailings
      Uranium  mine
       water  pond

      Phosphate
       overburden  pile

      Phosphate  sand
       and  clay tailings
Surface  Ground
water    water
NMa


NM

no
yes
no
NM
no
no
yes


yes

yes
yes
no



yes


NM


no
           Seepage indicators
                              Comments
      a  NM indicates  not  monitored.

      Source:   PEDCo  Environmental,  Inc. 1984
Sulfate, IDS, chloride
Sulfate, IDS

Cyanide, chloride,  sulfate,
nickel,  and ammonia
Cyanide, chloride, IDS,
and pH
Sulfate, IDS, chloride
Sulfate, chloride, IDS,
and radionuclides
IDS, fluoride, chloride,
total  phosphorus,  and
total  organic carbon
Low concentration of metals
Seepage is recharging the aquifer

IDS, sulfate, and zinc concentrations
  in downgradient wells equivalent to
  concentrations in tailings pond
  water

Surface water degradation after storms.
Cyanide not detected in surface water.
Metals did not exceed drinking water
  standards, although several other
  indicators did

Monitoring continues at this site;
  tailings may be having an effect on
  shallow ground water

Barium, a precipitating agent, also
  found downgradient to pond

No observable impact
Seepage greater in shallower aquifer

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plant.  At this site,  ground-water degradation was  evidenced  by  increased
concentrations of calcium,  sulfate, and total  dissolved solids.   The  leach
pile area is in an unlined  natural  drainage basin,  and  seepage  from it
apparently is recharging the aquifer.   (Although a  hydrogeologic study  was  not
conducted to confirm that the mine pit acts as a ground-water sink, the bottom
of the mine pit is 700 feet lower than the water level  in  the background well.)
    Gold tailings ponds receive cyanidation process wastes, have high
concentrations of cyanide,  arsenic, cadmium, lead,  mercury, and  selenium, and
are typically alkaline.  Cyanide was not detected in surface  water near either
of the gold tailings ponds, although low but detectable cyanide  levels  in
wells at both sites indicate seepage to ground water.   At  the first site, an
underground mine, ore is crushed and then leached with  a sodium  cyanide
solution.  Significant downstream increases were found  for fluoride,  specific
conductance, potassium, magnesium, sodium, and sulfate. These  increases were
thought to be caused largely by natural weathering processes, and the
concentrations never exceeded South Dakota cold-water fish propagation  stream
standards.  Alkalinity decreased downstream, and surface water  was not
considered to be impacted by the tailings pond.  The strongest  indicators of
tailings pond water seepage into ground water are the presence  of constituents
added during the beneficiation process:  chloride and cyanide.   Cyanide was
detected in three (of six)  downgradient monitoring wells;  chloride in two.
Additionally, sulfate, sodium, nickel, and ammonia concentrations indicated
seepage.  Cadmium, manganese, iron, sulfate, and total  dissolved solids were
at or exceeded levels permitted by the drinking water standards. An
independent analysis of these data concluded that concentrations of zinc,
total dissolved solids, and sulfate in downgradient wells  were  essentially  the
                                                  12
same as concentrations in the tailings pond water,    supporting  the
conclusion that contaminants had migrated.

                                     4-53

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    The second mine site in the gold mining  industry  also employs cyanide
leaching.   Spent leach liquors and  leached ore  are  disposed of in tailings
ponds; decant water is recycled to  the mill.  In  surface water, concentrations
of arsenic, manganese, total  dissolved solids,  and  fluoride were significantly
higher downstream than upstream,  but cyanide was  not  detected.  Tailings pond
releases during storms and snowmelt were  likely to  be responsible for
downstream water contamination.   Ground-water monitoring revealed
concentrations that exceeded drinking water  standards for arsenic, manganese,
pH, chloride, fluoride, nitrate,  lead, manganese, and total dissolved  solids.
Seepage from abandoned underground  mines  may have contributed to these
elevated levels, particularly for arsenic and manganese.  Cyanide was  detected
at low levels in two of four wells, but metal concentrations did not exceed
levels permitted in drinking water  standards.   The  presence of cyanide and the
increasing concentrations of total  dissolved solids and chloride indicate
tailings pond leakage.
    The underground lead mine selected for the  EPA  study is in Missouri, where
approximately 80 percent of all  lead production occurs.  The crushed ore goes
through a froth flotation circuit,  and tailings are pumped to a pond.   This  is
a zero-discharge facility; a seepage and  collection system recycles water to
the milling system.  Surface water  monitoring indicated significant increases
in calcium, magnesium, total  dissolved solids,  sulfate, nitrate, and chloride
downstream.  These increases were attributed to natural weathering processes,
as all levels were within the range reported for  streams that do not receive
lead mining waste.  Although small  amounts of cyanide are used to process
these ores, cyanide was not detected in surface water.  The copper level
exceeded the level specified in Missouri  standard for the protection of
                                     4-54

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aquatic life both upstream and downstream from the  tailings  pond.  Ground-
water monitoring revealed high concentrations  of  sodium,  fluoride, chloride,
sulfate, and total  dissolved solids;  the  latter three were considered  evidence
of seepage.  In one sample, total  dissolved solids  exceeded  permissible
drinking water standard levels.   Groundwater continues  to be monitored at this
site, which has a set of shallow and  deep wells.   Preliminary  analysis
indicates that tailings are having a  greater impact on  the water  quality of
the water in the shallower wells.
    Only ground water was monitored near  uranium  mine water  ponds in
New Mexico.  Uranium is recovered from surface and  underground mining  at this
site.  Waste management practices include overburden and  waste piles,  as well
as unlined settling ponds.  Permissible levels specified  in  drinking water
standards were exceeded in several wells  for selenium,  nitrate, sulfate,
manganese, and total  dissolved solids.   Elevated  concentrations of magnesium,
calcium, and sodium reflected the poor quality of the water  in the aquifer.
High levels of nitrate, magnesium, and total organic carbon  may have resulted
from leakage from a pond formerly used for sewage disposal.  Gross beta and
gross alpha concentrations were elevated, and  measurable  levels of radium-226
were also found.  High concentrations of  sulfate, chloride,  total  dissolved
solids, and radionuclides in downgradient wells are considered indicators of
pond seepage.  Elevated downgradient  levels of barium are another indication,
because barium chloride is added to precipitate radium  before  water is
discharged to the pond.
    The impact of phosphate mine waste (overburden) was evaluated at a mine in
eastern Idaho.  This is an open-pit mining operation in which  the overburden
is generally backfilled to inactive mine  sites.  Waste  rock  is usually graded
                                     4-55

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and revegetated.   Surface runoff  is  collected  in  basins to  remove  suspended
solids before the water is discharged.   EPA concluded, based on monitoring
results, that current mining operations  have little  impact  on  surface water.
Ground water was not monitored, because  there  were no suitable well  sites.
    In Florida, surface water and ground water were  monitored  near phosphate
sand and clay tailings.   Several  waste management practices are used:   the
clay fractions are slurried to settling  ponds  and overflow  is  reused; sand
tailings are used as backfill; overburden is piled or used  in  dike
construction.  Although levels of fluoride and sulfate were elevated in
surface water, quality did not appear to be affected by the tailings.   No
monitored constituent exceeded its Florida Water  Quality  Standard.   Two
ground-water aquifers were monitored: a shallow  water table aquifer and a
deeper Floridian Aquifer.  Elevated levels of  several constituents in tailings
serve as good indicators of seepage:  sodium,  sulfate, fluoride,  total  organic
carbon, total phosphorus, radium-226, gross alpha, and gross beta.   Of  these,
sodium, total organic carbon, fluoride,  and total phosphorus were  statistic-
ally higher in one or more wells  downgradient  to  both aquifers than in
respective background wells.  Although  the fluoride  level exceeded that of  the
drinking water standards, all levels were within  the range  of  ambient
conditions.  Chloride and total  dissolved solids, however,  were higher  than
ambient conditions, indicating that sand tailings constituents enter ground
water.  In conclusion, data indicate that neither clay  slime  ponds nor  sand
tailings have seriously affected the quality of shallow  ground water.   To
date, neither practice has had an impact on the deeper  Floridian  Aquifer, but
this aquifer may be recharged by the upper aquifer.
                                     4-56

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    Table 4-22 compares selected concentrations of indicators  in  ground-water
monitoring wells near the mine site with drinking water standards and water
quality criteria, where these values are available.   Ground-water degradation
may be attributable to current and/or past mining practices,  although
naturally poor background water quality exists in some areas.   Further
degradation may occur if additional waste constituents (notably metals  that
have not thus far appeared in high concentrations in the monitoring wells)
migrate in the future.  Factors governing leaching rates, fate, and transport
of constituents are complex, highly site specific, and dependent  on
physicochemical properties of both the waste and the local  subsurface
environment.  For example, pH, reduction-oxidation potential,  adsorption,
coprecipitation processes, and complex chemical and hydro!ogic interactions
are unique to each site.  Seasonal factors that could not be assessed  because
of the time constraints of this study are other localized influences on
constituent migration and transport.  For these reasons, the results of this
study cannot be directly extrapolated to industry segments employing similar
waste management practices.  Other studies may help place this monitoring
study in perspective.
4.3.2  Other Studies
    This review is not comprehensive, but provides conclusions from earlier
EPA studies and studies conducted by state and local governments  and the
academic community.
    Mines can contaminate ground water through waste disposal  practices, but
the nature of the contamination is highly variable and site specific.
Copper waste management practices leak constituents into both  surface  and
ground water.  Factors that affect the migration of this leakage  include ion
                                     4-57

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            Table  4-22  Concentrations3 of Seepage Indicators in Ground Water at Selected Monitoring Sites0







-Pi
1
un
00
Constituent
Chi ori de
Cyanide
Fluoride
Nickel
Radium -2 26
Sulfate
Total dissolved
sol i ds
Permissible
level in Water quality
drinking water criteria for
standards0 aquatic life**
250
0.02 - 0.2 0.0035
1.4 - 2.4e
0.056f
5 pCi/1
250
500
Gold
tailings Lead
pond tailings
1.94 - 58.4 22.8 - 44.8
0.02 - 1.76

0.10 - 0.31

800 - 1,200 38 - 108
269 - 556
Uranium
mine water
ponds
26-210



0.25 - 0.33 pCi/1
770 - 1,810
1,650 - 5,800
Phosphate
tail ings
55.3 - 63.2

1.85 - 6.58



169 - 205
a Concentrations are in milligrams per liter  except  as otherwise  indicated.
b Values are from one or more wells downgradient  or  upgradient  (or both) from the site.
c National  Interim Primary Drinking Water  Standards  (NIPDWS) or Secondary Drinking Water Standards, except for
  cyanide,  where the "detection" limit is  given.
d Values are for chronic freshwater animal  toxicity.
e Temperature dependent.
f At a hardness of 50 mg/1 CaCOs.
Source:   PEDCo Environmental, Inc.  1984

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                                                                 14
exchange capacity, hydraulic conductivity,  and  carbonate  content.
Carbonate neutralizes acids, and metals will  precipitate  when  the pH  is
neutral  or alkaline.   A study of the Tucson mining  district  found that leakage
from a copper tailings pond, indicated by hardness  of and sulfate in  the
water, degraded ground water downgradient from  the  pond.
    The Globe-Miami area east of Phoenix was also the focus  of a  study.
Copper mine runoff degraded surface water,  and  leaching practices degraded
ground water by lowering the pH and increasing  total  dissolved solids,
sulfate, copper, and other trace metal concentrations.  Because of liquids
leaching through the soil, alluvia in area washes are contaminated with
sulfate, iron, and copper; the plume is advancing downgradient.  Abandoned
mines have the same potential; but because of the arid climate, significant
degradation near these mines has not occurred.
    The cyanidation process used in gold mining creates the potential for
cyanide migration.  Cyanide can be free, part of other compounds, or strongly
complexed with metals.  An EPA laboratory study   showed that some forms  are
mobile, while others are less so.  Movement depends on the type of cyanide and
the media through which it travels.  Potassium cyanide in leachate is less
mobile  than water containing cyanide  ions in soils.  High pH and low clay
content increase cyanide mobility.  In the soil, cyanide salts are biologi-
cally converted to nitrates or become complexed with metals.  Without oxygen,
cyanides become gaseous nitrogen compounds.  These chemical changes take place
when  cyanide concentrations are low.  Former mining practices that did not
include wastewater treatment before release can be the source of persistent
cyanide concentrations.  One company, reopening a mine closed  for nearly
40 years, found levels of cyanide  far above detection limits  (0.14-0.58 mg/1)
                                     4-59

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                                                 18
while drilling test wells  before  activities  began.    Before mitigative
measures were implemented  in 1982,  one  Nevada  gold mine  had ground-water
levels as high as 5,509 mg/1.19
    Before proper environmental  treatment  systems were in  place, the Missouri
Department of Conservation found  a  reduction in  species  diversity  in the
aquatic habitat in the lead mining  district  that was directly  attributable to
                                 20
mining waste or milling effluent.     In another  study, surface water in the
area had low levels of dissolved  metals,  indicating potential  transport out of
the system.  A downstream  lake was  thought to  act as a sink, and some
sediments had lead and zinc concentrations of  10 mg/1  (Missouri Clean  Water
Conmission effluent guidelines are  0.05 and  0.2  mg/1, respectively, for these
metals).  Releases from the sediments could  create concentrations  that exceed
guideline levels, although little is known about the conditions under  which
                                                   21
these constituents may be  relased from the sediment.
    Radionuclide concentrations in  uranium mine  water are  high, but a  U.S.
Department of the Interior study  showed that these concentrations  are  reduced
                                                              22
downstream as a result of  adsorption or deposition in the  soil.    An
earlier EPA study of the Grants Mineral Belt (New Mexico)  estimated tailings
                                            23
pond seepage at 48.3 million gallons a year.
    Idaho phosphate mining has been studied  extensively.  An earlier study  at
the EPA site  (before current management practices were in  place) indicated
that mining practices had increased sediment and nutrients, added  oils, and
                            24
reduced the aquatic habitat.    Another study  concluded  that  the potential
existed for surface and subsurface flow patterns to be altered and for water
quality to be degraded by several constituents:   arsenic,  cadmium, chromium,
copper, lead, molybdenum,  selenium, vanadium,  zinc,  uranium,  radium-226,
                                     4-60

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nitrogen, and phosphorus.   However,  the high  carbonate  content reduces  the
                                                             25
solubility, and thus the potential  impact,  of these elements.     Finally, a
recent USGS survey of the phosphate  mining  industry indicated that neither
sand tailings nor clay slime ponds  had a significant effect on ground-water
        i}C
quality.
                  4.4   STRUCTURAL  INSTABILITY OF  IMPOUNDMENTS
    Impoundments may also pose threats to human health and the environment if
they are not structurally stable.   The structural failure of impoundments can
release large volumes of waste.  The causal  factors in the failure of unstable
waste structures and the subsequent flooding range from cloudbursts or minor
earth tremors to extended periods  of heavy rainfall, snow, or ice, or the
                                                         27
dumping of more wastes than a saturated bank can contain.
    Today there are thousands of tailings impoundments across the country that
have varying degrees of structural stability.   Many of these facilities are
located in remote areas, but others are built within flood range of homes and
well-traveled roads.   If these structures fail, extensive surface water
contamination, property damage, and life-threatening situations may occur.
    Although dam and impoundment failures in the mining industry segments
covered in this report have not yet caused human deaths in the United States,
they have been responsible for significant environmental degradation.  In
Florida, for instance, the collapse of a phosphate tailings dike in 1971
resulted in a massive  fish kill and pollution of the Peace River over a
                                 28
distance of about 120  kilometers.     Other dam failures at metal mining
sites have caused water quality degradation, crop failure, reductions in land
                       29
values, and fish kills.
                                     4-61

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    Stability problems are becoming more acute  as  the  grade  of  the  ore that is
mined decreases (resulting in larger quantities of mine  waste and tailings),
as dam heights increase, and as the areas near  mining  facilities  become more
highly populated.     In addition,  the recent promulgation  of Effluent
Limitations Guidelines and Standards for discharges to surface  water may have
aggravated these stability problems, because mine  owners or  operators may
elect to comply with NPDES permits by impounding larger  quantities  of water
than in the past.   The potential  danger posed by these impoundments is
increased by the fact that many new, large mines are situated  in  mountainous
areas where it is necessary to store large volumes of  waste  in  valleys
upstream of inhabited areas.
    The Mine Safety and Health Administration's (MSHA's) recent "Report of
Progress to Implement Federal Guidelines for Dam Safety" states that
"experience has shown that the unregulated disposal of mine  and mineral
                                                                3?
processing waste has the potential for disastrous  consequences."
According to the U.S. Department of Agriculture, an estimated 10-20 percent of
the mine waste disposal embankments in the U.S. and Canada have experienced
                                     33
significant slope stability problems.
    Technical personnel from MSHA recently completed field evaluations of
22 metal/nonmetal  mine tailings dams located in areas under Bureau  of Land
Management leases.  They determined that no dams were imminent hazards, but
                                                          34
they did find technical deficiencies at many of the sites.    Investigations
of mine tailings impounding structures (tailings dams) in the past 2 years,
including five emergency calls requested by metal  and nonmetal  mine health and
safety district managers, have revealed hazardous conditions.  Most of the
impounding structures  inspected show some or most of these serious
deficiencies: extremely steep downstream slopes; no emergency outlet
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structures such as spillways or decant systems;  high  water,  often  up  to  the
crest of the dams; cracks and sloughs  in the structures  themselves; narrow,
uneven crests; the absence of trash racks to keep drainage pipes unclogged;
and the absence of diverting ditches to keep surface  runoff from entering
             35
impoundments.

                               4.5   DAMAGE  CASES
    EPA has compiled, reviewed, and analyzed data on  National  Priorities List
(Superfund) mine and mill sites, data  on damage  at other mine  and  mill  sites
contained in state files,   and information in technical  reports documenting
                                                        37 38
cases of mine waste-related environmental contamination.   '
    Although this analysis has separated the damage cases into four  separate
categories (damage at active, inactive, abandoned, and Superfund sites), it is
important to note that active sites frequently become inactive, and  inactive
sites are sometimes abandoned.  Therefore, some  of the special environmental
problems caused by conditions at inactive or abandoned sites (e.g.,  the
erosion of tailings and their discharge into surface water,  or the collection
                                                              39
and discharge of frequently acidic and mineralized mine water)  can  only  be
avoided if active sites undergo some type of closure procedures before they
become inactive or are abandoned.
4.5.1  Active Sites
    Problems at active mine and mill sites have been documented in Arizona,
Colorado, Florida, Missouri, Montana,  and New Mexico; these sites  represent
phosphate, gold, silver, copper, uranium, and molybdenum operations.   Releases
ranged from catastrophic (loss of pond liner integrity,  pond overflow, dam
        40
failure,   tailings pipeline break) to chronic (pond seepage).  Contaminants
included cyanides, sulfuric acid, and metals (copper, cadmium, chromium, lead,
                                     4-63

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mercury, and zinc).   Both surface water   and ground-water    quality
degradation have been observed,  with  impairment of aquatic  ecosystems most
commonly caused by massive releases.   Remedial  actions  included  relocating  and
improving pipelines, replacing liners,  installing  of  leachate recovery
systems, and stabilizing dams.
4.5.2  Inactive Sites
    EPA has identified inactive  mine  and mill  sites with  environmental
contamination in Arizona, California,  Idaho,  Missouri,  Montana,  and Utah.
Mining industry segments represented  include  gold,  silver,  copper, mercury,
lead, and zinc.  Catastrophic releases,  often associated  with heavy rains,
have resulted from dam failures, flood  erosion  of  tailings, or dike washout.
Several  sites had intermittent or seasonal  problems caused  by snow melt  or
spring floods.   Other sites,  including  old mine waste dumps and  old tailings
impoundments, had chronic seepage or  runoff problems.   Contaminants measured
in surface water at concentrations greater than permissible levels in primary
drinking water standards include arsenic,  cadmium, and  lead.   Reductions  in
populations of fish  and other freshwater organisms were observed near at least
12 inactive mine/mill  sites that had  had catastrophic or  chronic releases.
Mitigation measures  included  dam repair,  pond lining, development of diversion
ditches or secondary ponds, and  lime  treatment  of  tailings.
4.5.3  Abandoned Si tes
    Many of the waste disposal  practices that have  resulted in major incidents
of environmental  contamination at abandoned mine sites  are  no longer used
(i.e., the dumping of tailings  into streams or  onto uncontained  piles).  EPA
identified abandoned sites where environmental  contamination  resulted from
such practices  in Arizona, California,  Idaho, Montana,  and  Vermont.  Gold
(placer and lode), silver, copper, lead,  zinc,  and unidentified  hard rock
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mining segments were represented.   Various  combinations  of  runoff,  erosion,
and seepage resulted in the release of arsenic,  cadmium,  cobalt,  iron,
manganese, lead, and zinc into surface waters, with  resultant  stress  on  stream
                                                         44 45
ecosystems over stretches ranging from 2 to 80 kilometers.   '     At some
sites, diversion ditches and trenches to lower the water table have been used
to mitigate these effects, but no mitigation has been  attempted  at  most
abandoned sites.
4.5.4  National Priorities List Sites
    Environmental contamination problems at the  13 abandoned mine/mill  sites
on the Superfund National Priorities List (NPL)  were generally caused by mine
waste disposal practices that are no longer used.   These sites are  located in
Arizona, California, Colorado, Idaho, Kansas, Oklahoma,  and South Dakota.
Mining industry segments represented are gold/silver (five  sites),  asbestos
(three sites), lead/zinc (two sites), and copper (three  sites).   The  three
asbestos sites differ from the other sites in posing an  airborne hazard to
human health.  The other 10 sites have chronic  runoff  and/or seepage, often
with acidic mobilization and transport of arsenic, cadmium, copper, iron,
lead, and/or zinc.  Ground-water contamination,  jeopardized water supplies, or
potentially contaminated food chains are the effects common to most of these
sites.  Degradation of aquatic ecosystems also  has been  observed at
nonasbestos NPL sites.  Mitigative measures applied to date include pond
sealing,  installation of dams, berms, and diversion ditches, and use  of the
waste in construction.  Additional measures will be taken following completion
of the remedial plans for each site.
    Brief descriptions of environmental contamination problems and threats to
human health posed by five NPL sites follow.
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    1)   Mountain View Mobile Home  Estates  is a 45-unit,  17-acre  subdivision
near the city of Globe in east-central  Arizona.  Before 1973,  three  mills,  the
Metate Asbestos Corporation,  the Jaquays Asbestos Corporation,  and the  Globe
town mill, processed chrysotile asbestos from nearby mines.   In 1973 the
Metate mill  was found to be in violation of EPA air  quality  standards,  and  the
Gil a County Superior Court issued a temporary injunction  to  cease operations.
The injunction was made permanent in May 1974.   Before  terminating operations,
the owner of the Metate Corporation obtained a rezoning of this property into
residential  subdivisions.  Approximately 115,000 cubic  meters  of  asbestos mill
tailings were used as the primary fill  to level the  site, which was  then
covered with topsoil.  The mill buildings,  housing,  and equipment remained
standing on the site.  Lots were sold and occupied before the  Superior  Court
injunction was made permanent.
    In October, 1979, asbestos contamination of the  soil  and air  was detected
at the subdivision.  Soil samples contained 5 to 50  percent  asbestos fibers,
and air samples had as many as 78 fibers/cm .  The asbestos  in the soil and
the airborne asbestos had contaminated all  the households that were  tested.
    In December 1979, the Arizona Department of Health  Services ordered the
responsible asbestos companies to submit site cleanup plans  to be implemented
during the spring of 1980.   In February 1980, the Arizona Division  of
Emergency Services, with the authorization of the governor,  provided temporary
housing for the residents  (population approximately  130) while their
properties were being decontaminated.  The Metate mill  was demolished,  and
open ground was capped with 6 inches of soil.  The residents returned to their
homes, but wind and water  erosion exposed some of the asbestos landfill
material on the surface of the soil, in the earth around the homes,  and in  two
washes draining the site.
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    In April  1983,  the Centers for Disease  Control  in Atlanta  issued a health
advisory for the site, noting continuing health  hazards.  The  Remedial
Investigation and Feasibility Study funded  by EPA proposed  three  solutions to
the problem.
    The site abandonment option was chosen  because it was the  least costly of
the three and eliminated the need for continued  site monitoring and selection
of an offsite disposal area.  In addition to relocating the individuals  in
this community, it was necessary to demolish existing structures.  In this
particular case, mining waste contamination made the housing structures  unfit
for habitation and ruined the community.
    2)   Acid drainage discharging from numerous mines  and  dumps  at the  Iron
Mountain site in California flows into Boulder Creek and Slickrock Creek, both
tributaries of Spring Creek.  Concentrations of cadmium, copper,  iron, and
zinc in the waters of these creeks exceed their respective  permissible levels
in Federal drinking water standards by factors of 2 to  5.   Spring Creek, with
its load of toxic metals, enters into the Sacramento River. The  water supply
intake for the city of Redding (population  approximately 50,000)  is 2 miles
below the confluence of Spring Creek and the Sacramento River; and the water
intake for Bella Vista Water District, which serves apprxoimately 15,000
people, is located 1 mile farther downstream.  Water samples taken at the
Redding intake show elevated levels of cadmium, copper, iron,  and zinc.
Samples of fish tissue from resident trout collected  in the Sacramento  River
showed high levels of cadmium, copper, and zinc.
    3)   At California Gulch, an NPL site in Colorado,  approximately  30
private wells have been abandoned because water from these wells  is unfit for
human consumption.  The surface water in California Gulch  has  been polluted so
                                     4-67

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extensively by acid mine drainage and the erosion of mining wastes into the
stream from the nearby mine site that the stream is devoid of any aquatic life.
    4)   In 1962, the Celtor Chemical  Works in Hoopa County, California,  was
abandoned by its owners/operators after they received numerous citations  for
contributing to pollution and fish kills in the Trinity  River.   Tailings  ponds
and piles located on the flood plain were the sources of contaminants.   In
1964, 2 years after closure of the operation, a flood obliterated the
structures and washed the tailings into the stream bed.   As late as 1982, soil
and sediment samples collected both on site and off site showed elevated  and
potentially health-threatening levels of cadmium (1.4 to 94.0 ppm), copper
(140 to 2700 ppm), lead (6 to 1900 ppm), and arsenic (4.7 to 40 ppm).
    5)   The Anaconda complex of mining, milling, and smelting facilities in
Montana disposed of approximately 5 billion tons of mining wastes in the
Silver Bow Creek/Clark Fork River.  For a stretch of approximately
180 kilometers, the river system was heavily damaged by  tailings materials
that were deposited in the river bed and in stream meanders.   The river has
recently begun to recover, and the beginning of a renewal  in aquatic life can
be seen in small plants and microinvertebrates that have become reestablished
there.  Although the waste disposal  practices of the early to mid-1900s that
caused this destruction are now prohibited by state and  Federal  laws; e.g.,
the Clean Water Act, the results of the waste practices  of 40 years ago may
take another 40 years, and a considerable amount of resources,  to undo.

                              4.6  RISK ANALYSIS
    As shown in the previous portions  of this section, some wastes from mining
and beneficiation do have the potential  for being hazardous to  human health
and the environment.  EPA's waste sampling and analysis  indicate that some
                                     4-68

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mine waste and mill tailings are EP toxic, generally for lead.   The sampling
and analysis also showed that some leachates from copper leach  dump operations
have the characteristic of corrosivity, with a pH less than 2.0; and even
those that are slightly less acidic can seriously jeopardize the quality of
ground water.  Other waste streams, although not hazardous under current RCRA
characteristics, contain potentially hazardous concentrations of asbestos,
cyanide, or radioactive isotopes.  Some tailings have the potential for acid
formation, and tailings impoundments may be subject to catastrophic breaks.
Ground-water monitoring studies by EPA and other organizations have
demonstrated that seepage from tailings impoundments into ground water is
common.  Finally, various degrees of damage have been caused by chronic or
sudden releases from active, inactive, or abandoned mine and mill sites.
    The previous portions of this section do not, however, provide
quantitative estimates of releases, exposures, or risks associated with
various mine and mill waste disposal practices.  Without this information, the
efficacy of current and alternative management practices cannot be compared.
Therefore, EPA is  now studying the use and release of cyanides and acids at
typical mining and beneficiation operations.  Specifically, cyanide releases
from metal recovery circuits and heap leaching operations are being examined.
Sulfuric acid releases being examined include those from active, inactive, and
abandoned copper leach dumps and copper mill tailings impoundments.
    EPA also has begun general studies relating the respective locations of
drinking water supply systems and human population centers to mines and
mills.  A preliminary analysis, based on  the Federal Reporting Data System,
indicates that for 58 mine/mill sites, 20 have public ground-water systems
within 5 kilometers of the  site.  These public water systems serve populations
ranging from 42 to 47,494.  Another EPA data base,  the  Graphic Exposure
                                      4-69

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Modeling System, uses Census Department data for population  distributions and
shows that people live within 5 kilometers of the mines at 30 of the 58 sites,
with total populations between 5 and 11,736.   Only 11  of the 58 sites have
both resident populations and public ground-water systems within 5 kilometers.
    If EPA identifies significant mining waste releases of cyanides, acids,  or
other constituents of concern, further analyses will  focus on actual or
potential risks to human populations or aquatic ecosystems.   These studies
will take into consideration the properties of various kinds of mine
overburden, mill tailings, and heap/dump materials.   Constituents other than
EP toxic metals will  be examined to determine whether their  release can
jeopardize aquatic organisms.  Degradation, attenuation, precipitation, and
other processes affecting the transport of released  materials will  be
examined.  To assess the potential  for ground-water  contamination,
site-specific estimates will be made for such factors as porosity,
permeability, and moisture content in the unsaturated zone,  and for hydraulic
conductivity in the saturated zone.
    The risk analyses will be used to quantify threats that  releases from mine
and mill wastes pose to human health and the environment. These analyses will
permit EPA to consider the wide variation in mining  practices and settings,
and to determine how changes in management practices can be  implemented to
improve and protect human health and the environment.   EPA would conduct risk
analysis as part of the development process for any  major regulation of
hazardous waste from the mining and beneficiation of ores and minerals.
                                     4-70

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                                 4.7  SUMMARY
    To identify mining and beneficiation wastes  with  the potential  to  endanger
human health and the environment, EPA conducted  an  extensive program of
sampling and analyzing mine waste, mill  tailings, and wastes from  heap and
dump leach operations to determine their chemical properties.   These studies
were supplemented by data from ground-water monitoring,  estimates  of acid
formation potential, a survey of state files to  obtain documented  cases of
damage to human health and environment,  and a review  of the pertinent
literature.  In the sampling and analysis studies,  corrosivity and EP toxicity
were measured, because they are the RCRA Subtitle C characteristics most
likely to be exhibited by wastes from mines, mills, and leach operations.   The
radioactive content of many solid and liquid samples  also was measured. When
appropriate, measurements were taken of asbestos or cyanide content.  Most
mine waste samples, most settled solid samples,  and some low-grade ore samples
were also subjected to a modified EP toxicity test, in which deionized water,
rather than acetic acid, was used as the extracting medium.  It should be
noted that EPA has not yet performed quantitative assessments of the risks
posed by mining wastes.  These will require measurement or estimation of waste
constituent transport, as well as receptor population exposure, dose, and
response.
    Extrapolating from the sampling and other analytic results, EPA estimated
the amounts of potentially hazardous waste generated  by the mining industry
segments of concern annually.  Estimated amounts are: 50 million metric tons  a
year (MMTY) of corrosive wastes; 11 MMTY of EP toxic  wastes; 23 MMTY of
cyanide-containing wastes; 95 MMTY of wastes with high acid formation
potential; and 182 MMTY of copper leach dump wastes with the potential for
releasing toxic metals and acidic  (but not corrosive) liquids.  If a
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 radioactivity level of 5 pCi per gram of waste is chosen as the radioactivity
 hazard criterion, 352 MMTY of phosphate mine waste and mill tailings and 91
 MMTY of uranium overburden and low-grade ore would be considered hazardous.
 The total amount of potentially hazardous waste generated annually, 755 MMT,
 is not equal to the sum of the wastes in these categories because some of the
wastes are in more than one category.
    Analyses of ground water monitoring results and damage cases showed that a
number of constituents leak from tailings impoundments and copper leach dump
operations.  However, it is not clear that this seepage constitutes a danger
to human health, although it could degrade the quality of water in aquifers.
The instability of impoundment dams was identified as a possible threat to
human health and the environment, with damage at active, inactive, and
abandoned sites attributed to catastrophic releases of impounded slimes,
sands, and water.
    In assessing the 13 mine/mill sites on the National  Priorities List (NPL),
prepared under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), EPA determined that the contamination problems
associated with these sites were generally caused by disposal  practices no
longer used.  Natural recovery and decontamination processes at these sites
have been slow, and additional  time and resources will  be needed before
recovery is complete.
    To determine the degree of risk from wastes at existing mine,  mill, and
leaching operations, identified as hazardous or potentially hazardous, EPA is
conducting studies on release rates, exposure pathways,  and possible effects
on human health and the environment.  These risk  assessments will  permit EPA
to consider the wide variability in mining wastes and environments and to
determine which changes in management practices would be most beneficial.
                                     4-72

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                             SECTION 4 FOOTNOTES
 1  PEDCo Environmental,  Inc. 1984.

 2  ERCO 1984.

 3  Harty and Terlecky 1982.

 4  Liquid wastes  are also  considered corrosive and therefore hazardous if
   they corrode steel at a rate greater than 6.35 rrni per year at a test
   temperature of 55°C,  as determined by  the test method specified in National
   Association of Corrosion Engineers Standard TM-01-69, standardized in "Test
   Methods  for the Evaluation  of  Solid Waste, Physical/Chemical Methods" or an
   equivalent test method  approved by the Administrator (40 CFR 261.22).  "EPA
   chose metal corrosion rate  as  its other barometer of corrosivity because
   wastes capable of corroding metal can  escape  from the containers in which
   they  are segregated  and liberate other wastes" (45 FR 33109, May 19,
   1980).   Because of the  preliminary nature of  the findings of this report,
   and because mining wastes are  not likely to be stored in metal containers,
   EPA's corrosivity analyses  for this report are based solely on the pH
   measure.

 5  Wastes are also considered  EP  toxic (and thus hazardous) if the extract
   of a  representative  sample  of  waste contains  any of the following
   pesticides or  herbicides at levels specified  in 40 CFR 261.24  (b), Table 1:
   Endrin;  Lindane; Methoxychlor; Toxaphene; 2,4-D; 2,4,5-TP Si 1 vex.  EPA did
   not use  the EP toxicity test to analyze mining wastes for these
   contaminants.

 6  US EPA 1982a.

 7  US EPA 1982a.

 8  US EPA 1982b.

 9  Cook  et  al. 1976.

10  US EPA 1982a.

   PEDCo Environmental, Inc. 1984.

12  Williams and  Steinhorst 1984.

13  US EPA  1977.

14  PEDCo Environmental, Inc. 1984.

   Pima  Association of  Governments 1983.
                                     4-73

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16 Gordon 1984.
17 US EPA 1976.
18 Letter to Nevada Division of Environmental  Protection  from
   Margaret Hills, Inc.  1981.
19
   File memo from Cortez Gold Mines,  Cortez,  NV,  1983.
20
   Ryck and Whitely 1974.
21 Jennett and Foil 1979.
22
   U.S. Department of the Interior 1980.
23 US EPA 1977.
24 Platts and Hopson 1970.
25 Ralston et al.  1977.
26 U.S. Geological Survey,  U.S.  Bureau of Land Management,
   and U.S. Forest Service, 1977.
27 Carroll 1983.
9ft
" BOM 1981 a.
29 SCS Engineers  1985.
   Soderberg and  Busch  1977.
31 Klohn 1981.
32 MSHA 1983.
33 USDA Forest Service  1979a.
34 MSHA 1983.
35 MSHA 1983.
36 The data from the state  files and  the  National  Priorities List  were  not
   analyzed in depth, nor were any of the sites visited,  but enough  documented
   cases were obtained  to demonstrate the range and  severity of  contamination
   problems that  may be  associated with mine  and  mill waste disposal.
37 SCS Engineers  1985.
                                     4-74

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op

   Unites et al.  1985.

?Q
Jy Martin and Mills 1976.



40 Schlick and Wahler 1976.


41
   Missouri Geological Survey 1979.



42 Gordon 1984.



43 SCS Engineers 1984.

44
   Schrader and Furbish 1978.



45 Jennett and Foil 1979.
                                     4-75

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                                   SECTION 5
                               THE ECONOMIC COST
                    OF POTENTIAL HAZARDOUS WASTE MANAGEMENT

    This section examines the potential cost to facilities and selected
segments of the mining industry if EPA were to regulate mining and
beneficiation wastes under the hazardous waste controls of Subtitle C of
RCRA.  The cost study on which these estimates are based was restricted to
five major metal mining segments (copper, lead, zinc, silver, and gold), and
covered mines currently active in 1984.   The estimates do not cover mining
segments in which there are potential hazards from radioactivity or asbestos,
although studies assessing the cost of reducing exposure to radioactivity are
underway.
    To examine potential  costs that might be imposed on the selected metal
mining segments, the Agency constructed eight hypothetical regulatory
scenarios differing in degree of impact.  These scenarios utilized
combinations of four different sets of management standards, varying in
stringency, and two different sets of hazardous waste criteria for determining
which waste streams would be regulated.  The estimated incremental  costs
reflect the added expenditures that facilities and industry segments would
incur above and beyond the cost of current waste management practices.
    The results are tentative, since they are based on only a sampling  of
sites, very general  engineering cost evaluations, and various hypothetical
regulatory scenarios.   Nevertheless, the estimates do provide a first
approximation of the potential  level  and variation of cost under the specified
assumptions.   They do  not evaluate broader economic effects such as implied
                                     5-1

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mine or mill closings, employment losses, price changes,  or  international
trade effects.
    The subsections below describe the methods and summarize the results.

                             5.1   COST METHODOLOGY
    To estimate the costs of potential regulation, EPA (1) established
criteria for determining whether waste is potentially hazardous; (2)  developed
hypothetical alternative regulatory standards for waste management practices
with different degrees of stringency;  (3) estimated the incremental cost of
imposing those standards at a large sample of mining facilities; and  (4)
extrapolated these results to the universe of applicable  mining  facilities  in
the segments covered by the study.
    The cost study focused only on currently active (1984) "major"  mines—
i.e., mines generating greater than 10,000 short tons  of  ore per year, except
for gold and silver operations where a lower production cutoff was  used.  For
the five metal segments studied (copper,  lead, zinc,  gold, and silver), the
study results cover approximately 190  active mine sites representing  an
estimated 95 percent of the total  active  mines and 99 percent of the  total
amount of waste currently generated in these five segments.
    EPA established two levels of criteria, referred to here as  Scenarios A
and B, for determining whether waste is hazardous.   EPA also defined  four
levels of regulation, varying from imposing full  Subtitle C  regulations (most
stringent) to imposing only a basic maintenance and monitoring function (least
stringent).  Combining the two hazardous  waste scenarios  and the four
regulatory standards resulted in eight different scenarios.
    To estimate the additional cost of each of these eight scenarios  at
specific sites, EPA (1) identified the capital and operation and maintenance
                                     5-2

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needs for each scenario; (2) developed engineering cost functions reflecting
these requirements; (3) established a data base with all  the necessary
information (e.g., waste volumes, acreage, perimeter distance, current waste
management practice) for estimating costs from the cost functions;  and (4)
applied information from 47 specific mines to the cost functions to develop
the incremental costs at those sites.
    Finally, EPA extrapolated the site-specific results to the universe of
mining waste to develop industry totals.  It did so by projecting from the
site-specific cost by industry segment (copper, gold, silver,  lead, zinc), by
waste operation (mine waste, leach operation, tailings),  and by scenario.   The
distinguishing feature of this approach is that the costs reflect real-world,
site-specific data.
5.1.1  Hazardous Waste Criteria
    Regulated waste volumes depend on the criteria selected for determining
whether wastes should be regulated, and EPA used the basic waste character-
istics described in Section 4 to specify which waste streams should be
considered as potentially hazardous for costing purposes, creating  two sets of
waste:  "A" and "B."  (Estimates of the volume of potentially  hazardous wastes
are discussed in Section 4.2.)
    "A-Scenario" Wastes include waste streams meeting the Subtitle  C tests for
EP toxicity and corrosivity.  In addition, they include gold mine tailings
wastes from cyanide-process metal  recovery operations (originally promulgated
as interim final  Subtitle C listed hazardous wastes prior to the Section 3001
exempti on).
    "B-Scenario" Wastes include all  wastes under the "A"  list,  as well  as:
    •    Gold and silver heap leach operations (because of cyanide  content);
                                     5-3

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    t    Wastes with high acid formation  potential--i.e.,  those  found to
         contain high sulfides (mainly pyrites)  and  low carbonate  or  other
         buffering mineral  content (as defined in  Section  4);  and
    •    Copper dump leach liquids (because  of acidity).
The "B" list of wastes represents a range of mine  waste characteristics of
concern over and above the hazard characteristics  already  contained in
existing EPA hazardous waste regulations  as  expressed by the "A" list.   The
Agency examined the "B Scenario" list to  be  able to  explore, quantitatively
and systematically, the waste quantity and management cost implications of
regulating these additional wastes of concern.
5.1.2  Regulatory Standards
    EPA structured four regulatory alternatives for  different levels of waste
management practice.  The regulatory alternatives  covered  a range  of
variations on Subtitle C management standards, ranging  from the  full  set of
standards at one extreme to a much more modest program  of  basic  preventive
maintenance and ground-water monitoring at the other end of the  spectrum.
    The Full Subtitle C Regulatory Scenario  (Scenario 1) provides  for a full
application of current EPA hazardous waste regulation to potentially hazardous
"A" or "B" mine waste, leach piles, and mill tailings.   For present costing
purposes, it represents a maximum cost strategy, including:  a security fence
around the perimeter, capping of both existing and new  waste sites at closure,
corrective action via interceptor wells for existing waste amounts (assuming
10 percent of the sites need them), and liners for all  new waste piles,
leaching areas, and tailings ponds.  It also requires activities common to all
of the alternative management strategies:
    t    Permitting;
    •    Surface water run-on and runoff diversion/collection
         ditches (mine waste only);
                                      5-4

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    •    Ground-water monitoring wells and testing;
    •    Leachate collection ditches; and
    •    Post-closure inspection, drainage maintenance, and
         ground-water monitoring.
         The Tailored Standard Scenario (Scenario 2) represents an intermediate
cost alternative.  This scenario includes the five common activities listed
above.  However, the waste management technique here is distinguished by
substitution of waste treatment processes where considered feasible—namely,
the removal of cyanide from gold and silver tailings and removal of sulfides
(pyrites)  from copper mill tailings.  The scenario assumes that all sites
would require interceptor wells because it assumes a 100 percent failure rate
for all waste sites, except for treated wastes at gold and copper sites
(treatment is the alternative to interceptor wells).
    The Corrective Action Scenario (Scenario 3) also represents an
intermediate alternative with to regulatory standards that are less stringent
than those embodied in Scenario 1.  The applicable activities are identical  to
those listed under Scenario 2 (including the 100 percent failure assumption),
with the exception that cyanide is not removed from gold and silver tailings,
and sul fides are not removed from copper mill  tailings.
    The Basic Maintenance and Monitoring Scenario (Scenario 4) includes  only
the five activities common to the other scenarios.  By design, this represents
a least-cost scenario consistent with providing a measure of protection
against surface water contamination and a first warning of any offsite
movement of contaminated leachate.  It can also be regarded as the first stage
of a corrective action strategy.
    Combining the four regulatory standard alternatives with the two
alternative sets of potential  hazard criteria  yields eight possible levels  of
                                     5-5

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cost.  Table 5-1  summarizes the definitions of costing scenarios  in terms of
their alphanumeric designations:  the numbers 1  through 4 represent the
alternative regulatory standards,  and the letters A and B represent the
applicable potential  hazard criteria.
5.1.3  Estimating Incremental  Costs at Specific Sites
    EPA identified the cost elements required for each scenario.   Cost
elements are the individual capital requirements, and individual  operation and
maintenance requirements.  EPA also developed engineering cost functions for
each cost element for performing the activities that the management standards
require.  EPA then created a data base for 47 mining facilities that
incorporated the information necessary to calculate costs from the engineering
cost functions.  This included identifying the current waste management
practice (baseline practice) at each of the 47 sites.  This information was
necessary to develop incremental costs that reflect the costs of practices
required under each of the four regulatory standards above and beyond the
baseline practice.  In addition, the data base incorporated information
relative to site-specific geography, product production, total waste
quantities, waste quantities that would meet the hazardous waste criteria,
type of industry, and type of waste operations.  Finally, EPA computed the
incremental cost for each scenario at each site by applying the data base
information to the engineering cost functions.
5.1.3.1  Cost Elements
     As discussed previously, imposing various degrees of regulation requires a
different mix of outlays  for capital, operation, and maintenance.  The mix of
cost elements varies by  the stringency of  the regulatory standard.  For
convenience, Table 5-2 summarizes  the cost elements  included  in each of  the
four regulatory  standard scenarios.  A discussion of each element  follows.
                                      5-6

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                  Table 5-1    Definition of Costing Scenario
Variations by specified hazards
Variations by type of
regulatory approach
"A" SCENARIOS:  Subtitle C
                Definitions:
   •  EP Toxicity Characteristic
   •  Corrosivity Characteristic
   •  Cyanide Gold-Mine Tailing
         Liquid Waste
"B" SCENARIOS:  Subtitle C Above,
    Plus!
   •  Cyanide Toxicity Characteristic
   0  High Acid Generation Potential
         Characteristic
   •  Copper Dump Leach Listing
                                            1.   Full  Subtitle C Regulations
2.  Tailored Standards
  (varying by type of hazard)
3.  Corrective Action

    100% failure bracket
4.  Basic Maintenance and
    Monitoring
    Zero failure bracket
                                     5-7

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       Table 5-2   Summary of Cost Elements Included for Each Scenario
Regulatory scenario
Cost
1.
2.
3.
4.
5.
6.
7.
8.
el ement
Permitting
Leach ate system
Monitoring system
Run-on/runoff system
Post-closure maintenance
and operation
Site security
Liners (new waste only)
Closure cap
1 2
X X
X X
X X
X X
X X
X
X
X
3
X
X
X
X
X



4
X
X
X
X
X



 9.   Tailings treatment
       (for copper and gold)

10.   Corrective action via
       interceptor wells
Note:    Explanations as  to  variations  between and within scenarios are
         contained in the text.

a Only for existing accumulated  waste  sites  (that were closed at  time  of
  RCRA implementation).

b Exceptions:  gold and copper tailings (subject to  treatment instead).
                                     5-8

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    Permitting.  Mining operations with hazardous wastes would require RCRA
permits.  Permits would be based on geological  and engineering studies
describing the plan for managing wastes and containing or treating
contamination.  Incremental costs in this study vary among states with more
advanced permitting requirements and those with less.
    Site Security.  RCRA regulations require that security be provided to
prevent the general public and livestock from coming into contact with
hazardous waste.  For this study, EPA assumed that operators of facilities
would install and maintain cyclone fences around all hazardous waste areas
during their active lifetime and a 30-year post-closure period.
    Caps and Liners.  RCRA Subtitle C rules require caps when disposal sites
are closed and that new waste landfills and impoundments be lined.   The cap
assumed for this study consists of vegetation,  topsoil, clay or sand,
polyethylene cover, and clay.  We assumed that  liners were composed of a
combination of clay and synthetic liner materials.
    Monitoring Wells.   RCRA rules require ground-water monitoring of hazardous
waste disposal sites.   The study assumes that wells will be located around the
general  perimeter of each waste disposal  operation (500 feet between each
well), and that four replicate samples will  be  taken and analyzed twice a year
for appropriate contaminants.
    Run-On and Runoff Systems.  Regulations provide that precipitation be
directed around hazardous waste piles to avoid  leaching of contaminants.
Runoff from surfaces of piles must also be controlled.   The costs here reflect
primarily ditching and flow control  systems.
    Leachate Collection Systems.   RCRA rules  require a system to collect  and
treat contaminated seepage from hazardous waste piles.   A full  system
includes:  (1) ditches  or trenches on the downgradient sides of the waste  pile;
                                     5-9

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(2) an intermediate liquid storage  system;  and  (3) a chemical treatment  plant.
    Corrective Action via Interceptor Wells.  At  some  sites,  contamination
migrates into ground water, forming a plume that  can migrate  from the  site.
When this happens, RCRA Subtitle C  rules  require  corrective action.  For this
study, EPA assumed that interceptor wells would be installed  in  the  plume, or
at the downgradient edge of the plume,  to pump  the contaminated  water  to the
surface.  EPA assumed that all  contaminated water would  be sent  to a treatment
plant.  In Scenario A, interceptor  wells  are installed at closure only for
existing waste.
    Tailings Treatment.  This applies only  to Scenario 2 where treatment of
new waste is employed when feasible rather  than interceptor wells.
Specifically, EPA assumes that future gold  and  copper  ore tailings would be
treated to separate out pyrite concentrates for disposal as a hazardous  waste,
using a flotation circuit, and that a treatment plant  would be installed to
destroy cyanide in gold beneficiation operations.
    Closure.  When the useful life  of a waste pile or  tailings pond  is over,
the study assumed the site would be capped  with impervious cover material.
The design and cost of the cap depends on whether the  waste site is  from past
operations or future operations.
    Post-Closure.  Operation and maintenance (O&M) costs are  assumed to  be
incurred for 30 years after closure.  The annual  O&M costs would consist of
several elements:  (1) maintenance  of the cap and fencing; (2) inspection; (3)
detection or compliance monitoring; (4) maintenance of the run-on and  runoff
systems; (5) operation of the leachate collection; and (6) operation of  the
interceptor well/treatment system.
    Financial Assurance.  RCRA Subtitle C rules require  firms to demonstrate
that they can meet closure and post-closure costs.  They may  do  so by  posting
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surety bonds, by purchasing a letter of credit, by establishing a trust fund,
by purchasing an insurance policy, or by passing a financial  test.
5.1.3.2  Cost Functions
    Engineering cost functions were developed for each of the waste management
practice cost elements listed in Table 5-2.  The functions generally take the
form:    C = aV , where C = cost, a = a constant, V = the volume of waste,
and b = the elasticity of cost with respect to volume (which  shows  how cost
changes as a result of small volume changes).  Many of the functions use the
number of acres or perimeter distance as the independent variable rather than
waste volume.  Permitting costs are based on type and size of mine, as well  as
current State agency permitting requirements.
5.1.3.3  Sample Facility Data Sources
    The Agency's cost study utilized and built upon a mine facility data base
providing site-specific data for 47 metal mining properties,  with information
on geophysical characteristics, mine/mill technologies and efficiencies,
                                                        2
historical production levels, and other salient factors.   Additional  site-
specific data were assembled on the type and size of current  waste  management
areas and practices, as well as life expectancy of ore bodies and current
production cost factors.  The data were supplemented by survey information on
current State mining waste regulations.  These data provide the primary inputs
for estimating historical and current mine, tailings, and leach pile waste
generation rates as well as simulating baseline management practices at each
of the 47 properties.
    EPA waste characteristics sampling data were available for one  or more
waste streams at 41 of the 47 facilities; and the combination of these two
data sources then formed the basis for calculating potentially hazardous waste
quantities and incremental hazardous waste management compliance costs for
                                     5-11

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each database facility under the various  hypothetical  regulatory scenarios,
using the cost functions previously described.
    Appendix B provides a fuller discussion  of  the  facilities  data base,  the
methods used in estimating waste generation  rates,  and the  techniques  employed
to extrapolate waste quantities and compliance  costs  from the  sample sites to
the segment totals for the mining segments  in the study.
5.1.4  Total Number of Facilities and  Waste  Quantities Regulated
    EPA aggregated the site-specific regulated  waste  quantities, capital
costs, and O&M costs for each facility in the data  base by  industry, by
scenario, and by waste operation.  The resulting industry totals for numbers
of facilities affected and regulated waste quantities  are summarized for  the
specific segments in Table 5-3.
    As indicated in Table 5-3, 99 out  of  191 metal  mining facilities
(52 percent) and 67 million metric tons out  of  a total  annual  generation  of
725 million metric tons (9 percent) of metal mining waste would be subject to
potential Subtitle C regulation under  Scenario  A.   However,  except for gold,
less than half of the facilities in any given segment would be affected.
Furthermore, not all of a given affected  facility's waste sources would
necessarily be subject to regulation.   For  example, copper  mine and tailings
wastes were not found by our sampling  to  be  potentially hazardous under our
Scenario A definition, but some copper dump  leach piles are potentially
hazardous in Scenario A.  This accounts in  part for the relatively low
percentage of waste meeting the hazard criteria, in contrast to the higher
percentage of facilities.  In addition, the  (listed)  cyanide process tends to
dominate the gold milling/processing operation, but a relatively smaller
fraction of total waste.
                                     5-12

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           Table 5-3  Numbers of Potential  RCRA Mine Facilities  and
               Quantities of Hazardous Waste in EPA Cost Study,
                      Scenario A and B, by  Mining Sector



Copper
Gold
Silver
Lead
Zinc
Total s
Copper
Gold
Silver
Lead
Zinc
Total s
Number of
Regul ated/
total

6/22
75/100
12/50
3/7
3/12
99/191
21/22
100/100
25/50
3/7
3/12
152/191
facilities
Percent
regulated

27
75
24
43
25
52
96
100
50
43
25
80
Annual
(millions
Regulated/
total

A__ 	
50/632
13/65
1/17
3/9
0.3/2.4
67/725
B_ 	 _„
276/632
24/65
4/17
3/9
0.3/2.4
307/725
waste generation
of metric tons/year)
Percent
regulated

7.9
19.6
5.7
33.3
11.5
9.3
43.7
36.6
22.3
33.3
11.5
42.3
Source:   Estimated by Charles  River  Associates 1985a.
                                    5-13

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     In Scenario B, the fraction of firms under regulation increases to about
80 percent overall, and the fraction of regulated waste increases to about
40 percent.  Almost all copper sites (although still  less than half of the
total waste volume) would face regulation under this  scenario, as well  as all
gold mines (due to cyanide heap leach and metal  recovery).   For silver, lead,
and zinc, the fraction of facilities affected ranges  from 25 to 50 percent and
the fractions of waste regulated from 11  to 33 percent under Scenario B..
    This methodology relies on the use of real-world  sites  with site-specific
information concerning prevailing regulations and current waste management
practices, geography, and mine operations.   It requires a high level  of detail
in building up the cost estimates for each  EPA data base site.  The results
presented below are based on the application of  this  methodology to a large
sample (47) of real-world sites and the extension of  those  results to the
remaining sites.

           5.2  POTENTIAL COSTS OF RCRA SUBTITLE C WASTE MANAGEMENT
    This section discusses potential  costs  for the metal  mining industry  in
the aggregate, for individual  segments, and for  individual  mine facilities if
certain wastes were managed as hazardous  wastes  under various  regulatory
scenarios.  The discussion also provides  some insights as to the relationship
of compliance costs to mine production costs.
5.2.1  Potential  Total  Cost for the Metal Mining Industry
    EPA's cost analysis leads  to three principal  findings with respect to
total potential  cost.   The first is that the waste management  costs of RCRA
could be quite substantial under the  types  of regulatory scenarios that this
report considers,  as Table 5-4 illustrates.   In  annual ized  cost terms,  costs
for the five metal  mining segments would  be measurable in the  millions  of
                                     5-14

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          Table 5-4  Potential  Total  Cost For Metal Mining  Industry9
                   Under Various RCRA Regulatory Scenarios
Regul atory
scenarios"
1A
2A
3A
4A
IB
28
3B
4B
Lifetime0
($ millions)
$2,421
937
1,036
128
9,985
3,577
2,809
330
DPVLd
($ millions)
$1,279
305
332
60
5,746
1,139
800
137
Annual e
($ million)
$185
47
46
7
854
210
118
17
a Industry segments include:   copper,  lead,  zinc,  gold,  and silver.

b See Subsection 5.1.1  and Table 5-1.

c Lifetime cost (1985 dollars),  not discounted,  including:   closure  and  30
  years post-closure costs for existing wastes;  opening  and managing a new
  waste management facility for 15-year future operations;  closure at end  of
  15th year; post-closure management for 30  years.

d Discounted Present Value of Lifetime Costs,  as listed  in  note (c). Real
  discount rate of 9.0 percent.

e Lifetime Costs Annualized over 15-year future  mine production period using
  a real discount rate of 9.0 percent.


Source:  Estimated by Charles River Associates 1985a.
                                     5-15

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dollars per year up to several  hundred minion dollars  per  year  over a 15-year
mine production cycle.  Lifetime costs (undiscounted) for operating the mines
in five metals segments would be measurable in the  hundreds of million
dollars, possibly up to several billion dollars over the next 15 years of mine
production.
    The second major conclusion is that costs vary  substantially among the
RCRA management scenarios chosen for analysis.  Generally speaking, the
highest cost scenarios (1A and IB) are several times more costly than the
intermediate cost counterparts (2A and 3A, 2B and 3B).   Similarly,  the minimum
maintenance and monitoring scenarios (4A and 4B) cost only a fraction as much
as the intermediate cases.
    The third finding is that the additional waste  management cost  incurred by
adding additional B-Scenario wastes is also very substantial: Scenario B is
typically  two to four times more costly than Scenario A for given regulatory
standards  or strategies.
    The figures presented in Table 5-4 assume that the potentially  hazardous
portions of both existing waste (accumulated at these sites from past
operations) as well as new (future) waste generated at these sites  would be
managed as RCRA Subtitle C hazardous waste.   If only new wastes  generated in
the future were to be regulated, the costs would be 40 to 70 percent of those
shown  in Table 5-4, depending on the scenario considered.
5.2.2  Potential Costs for Individual Segments
    Potential total costs for the five individual metal mining segments vary
widely among the segments analyzed and across alternative regulatory
scenarios, as Table 5-5 illustrates.  By far, the largest aggregate lifetime
cost for each alternative falls on copper mining, because of the extremely
large  quantities of waste and the relatively  high proportion of total waste
                                     5-16

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    Table  5-5   Potential Total Costs For Selected Metal Mining Sectors
                  Under Various RCRA Regulatory Scenarios
        Sector
                           Subtitle C
                            Tailored standards
1A
IB
2A
2B
Lifetime costs {$ million)3
Copper
Gold
Silver
Lead
Zinc
Total s

Copper
Gold
Silver
Lead
Zinc
Total s

Copper
Gold
Silver
Lead
Zinc
Total s
$1 ,400
670
46
260
45
$2,421
Di
$ 710
370
28
140
26
$1,279

$ 110
48
4
19
4
$ 185
$8,300
1,200
180
260
45
$9,985
scounted present
$5,000
490
90
140
26
$5,746
Annuali zed costs
$ 740
75
16
19
4
$ 854
$400
250
60
180
47
$937
value ($ mill
$ 96
110
23
58
18
$305
$2,400
770
180
180
47
$3,577
ion)b
$ 770
230
63
58
18
$1,139
($ million/year)0
$ 14
17
4
9
3
$ 47
$ 150
37
11
9
3
$ 210
a Lifetime cost (1985 dollars),  not discounted,  including:  closure  and
  30 years post-closure costs  for existing  wastes;  opening and managing a
  new waste management facility  for 15-year future  operations; closure at
  end of 15th year; post-closure management for  30  years.

b Discounted Present Value of  Lifetime  Costs,  as listed  in note  (a).
  Real  discount rate of 9.0%.

c Lifetime costs annualized over 15-year future  mine  production  period,
    using a real  discount rate of 9.0%.

Source:  Estimated by Charles  River Associates 1985a.
                                     5-17

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that is of potential  concern,  particularly in the dump leaching  and milling
operations.  The gold segment bears the second highest lifetime  total  cost
since most gold production uses cyanide processes either  in  leaching or
milling operations.
5.2.3  Potential Costs for Individual  Mine Facilities
    As noted previously,  the number of mine facilities that  might be subjected
to hazardous waste regulations is highly uncertain,  depending on various
possible definitions  of hazardous waste constituents,  variations in natural
mineral deposits, and differences in ore processing  methods.  EPA waste
sampling suggests wide variations among different segments as to percentage of
mines with potentially hazardous waste, as well  as wide variations within
individual segments regarding possible quantities and  characteristics  of such
waste materials.  This section examines potential  cost implications for
individual facilities among and within the five segments  analyzed.
    Table 5-6 provides a comparative summary of individual mine  facility cost
estimates for two illustrative scenarios--Scenario IB  (the highest cost
scenario estimated) and Scenario 4B (the lowest cost scenario for the B-waste
group).  Potential costs are presented on both a lifetime and an annual ized
basis.  For the high-cost scenario (IB), average lifetime costs  for affected
facilities would range from $7 million for silver mines up to almost $400
million for individual copper mines.  Annualized and discounted  over a 15-year
mine production cycle, these would translate into new  annual  average cost
burdens for individual mines, ranging from $600,000  per year (silver mines) up
to $35 million per year (copper mines) per facility.
    The facilities with the highest costs—those with  the greatest volumes of
potentially hazardous wastes or especially difficult management  conditions--
would experience additional management costs that would be significantly
                                     5-18

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              Table 5-6   Potential  Incremental Compliance Costs
                     For  Individual RCRA Mine Facilities
                       For High-  and Low-Cost  Scenarios
Copper
Gold
Silver
Lead
Zinc
Copper
Gold
Silver
Lead
Zinc
Copper
Gold
Silver
Lead
Zinc
                   Scenario IB
                                    Scenario 4B

Average
facility
Maximum
cost
facility3

Average
facility
Maximum
cost
facility3
 390
  12
   7
  85
  15
 240
   5
   4
  46
   9
35.1
 0.8
 0.6
 6.5
 1.4
                            Lifetime  costs  ($ millions)b
,300
 170
 120
 170
  27
             10.0
              0.6
              0.5
             11.0
              3.0
                    -Discounted present value  ($ mill ion/year)c-
1
,100
  63
  50
 110
  16
3.8
0.3
0.3
4.4
1.1
                         -Annual ized  costs  ($  mi 11 ion/year)d-
 190
   9
  10
  14
   4
              0.50
              0.04
              0.04
              0.57
              0.20
                   33.0
                   16.0
                   10.0
                   17.0
                    6.0
16
 8
 5
 7
 3
                    2.4
                    0.9
                    0.6
                    1.2
                    0.5
3 Maximum means the maximum cost for a  facility  in  the  EPA data base.

b Lifetime cost (1985 dollars),  not discounted,  including:  closure and
  30 years post-closure costs  for existing  wastes;  opening and managing a
  new waste management facility  for 15-year future  operations; closure at
  end of 15th year; post-closure management for  30  years.

c Discounted present value of  lifetime  costs,  as listed in note (a).
  Real  discount rate of 9.0%.

d Lifetime costs annual ized over 15-year future  mine  production period
  using a real  discount rate of  9.0%.

Source:  Estimated by Charles  River Associates 1985a.
                                     5-19

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higher than the average.  For example, in the zinc and copper segments, a
high-cost facility would face costs about three times higher than the
average.  For silver and gold, the costs of meeting the Scenario IB RCRA
regulation would be on the order of 15 times the industry average.
    Differences between the two scenarios are equally striking.   Facilities
employing RCRA cap and liner controls (Scenario IB) would have 5 to 40 times
more RCRA-related waste management costs over their lifetime than if they
employed only the maintenance and monitoring functions estimated for
Scenario 4B.
5.2.4  Potential RCRA Costs Relative to Mine Production Costs
    Comparing potential facility compliance costs to total  mine production
costs provides insight on the possible effect of RCRA Subtitle C regulations
on individual  mine economics.  Table 5-7 shows potential  incremental
compliance costs per unit of mine product (typically, concentrated ore) and
potential  incremental  RCRA costs as a percentage of the segment's average
current total  direct production cost.  Potential cost impacts of hazardous
waste regulation for an average mine for the low-cost Scenario 4B range from
about 1 to 5 percent of total production costs for the five metal segments.
By contrast, for the high-cost Scenario IB, potential incremental RCRA
regulation costs would range from about 20 to 120 percent of current total
direct product costs,  on the average, for individual  facilities  in the five
segments.
    The high-cost mines again would experience impacts significantly greater
than the average.  In Scenario IB, EPA estimates that the high-cost facilities
in all five segments would face potential RCRA compliance costs  in excess of
                                     5-20

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           Table  5-7    Potential  Incremental RCRA Compliance Costs
                      Relative to Facility Production  Costs
             Cost per unit of product3
              (Dollars per metric ton)
             Average for
              affected
             facilities
High-cost
facility
                Percent of direct product cost3
Average for
 affected
facilities
High-cost
facility
Copper
Gold
Silver
Lead
Zinc
17.6
5,625.5
267.9
5.4
28.7
	 i.UW-1
$ 44.1
29,466.9
1,071.5
15.4
57.3
                                 Low-cost scenario (4B)
                   1.7%
                   1.1%
                   2.5%
                   1.9%
                   5.2%
                      4%
                      6%
                     10%
                      5%
                     10%
Copper
Gold
Silver
Lead
Zinc
$ 1,212.5
117,867.6
4,286.1
60.6
209.4
	 niyn-tubu
$ 3,417.1
267,881.0
16,608.6
253.5
319.7
icenor i u \. ID i -
120%
23%
40%
21%
39%
340%
54%
160%
88%
58%
3 Direct costs of mine product are based on sector  averages  of  current
  cash operating costs for facilities,  as estimated by
  Charles River Associates for EPA.   Costs do not include  facility-level
  capital investment,  depreciation,  interest expense, or corporate  overhead.

Source:  Estimated by  Charles River Associates,  1985a.
                                     5-21

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50 percent of their total direct production costs.  Even under the low-cost
Scenario 48, estimates for the most-affected facilities in each of the five
segments range between 5 and 10 percent of total mine production costs.
                                      5-22

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                             SECTION 5 FOOTNOTES
    Charles River Associates 1985a.

2
    This data base was originally developed by Charles  River Associates.
                                     5-23

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                                  SECTION 6
                       CONCLUSIONS AND RECOMMENDATIONS

                                  6.1 SCOPE
    As detailed in Section 1, this report covers the waste generated from the
extraction and beneficiation (concentration)  of metallic ores,  phosphates, and
asbestos and the mining of uranium.   Although these selected mining segments
include only about five percent of the 13,000 active mining operations in the
U.S. noncoal mining industry, the facilities  covered in this report generate
over 90 percent of the total waste material  produced by all noncoal mines.

                          6.2  SUMMARY OF CONCLUSIONS
    The Agency's conclusions from the studies presented in this report are
summarized under major groupings paralleling the organization of the report,
namely:  (1) Structure and Location of Mines, (2) Waste Quantities, (3)
Potential Hazard Characteristics, (4) Evidence of Environmental Transport, (5)
Evidence of Damage, (6) Management Practices, and (7) Potential Costs of
Regulation.
6.2.1  Structure and Location of Mines
    Because of the wide availability of  detailed and comprehensive information
published by the U.S. Bureau of Mines and supplemented by  data from industry
trade  associations, EPA's conclusions on the numbers, sizes, and locations of
U.S. mines  are based solely  on these  standard sources.

    1.   There is a relatively small  number  of mines in the segments under
         consideration in this study.  Fewer than 500 mine sites (1985)
                                       6-1

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     extract and concentrate metals,  phosphates,  and  asbestos in the U.S.
     (excluding gold placer mines).   Of these,  about  290 (62  percent) are
     accounted for by the precious metals (gold,  silver)  and  uranium
     segments alone.
2-   There is a great diversity in the size  of  mining facilities.   This  is
     true whether one measures size in terms of property  area,  product
     tonnage, total  volume of material  handled, or waste  generated.   The
     largest mine sites (e.g., in  the iron ore, copper,  and phosphate
     segments) are measured in terms  of square  kilometers, and  each one
     handles more than 10 million  tons of material per year.   By contrast,
     about 25 percent of the mines included  in  this study handle less than
     1,000 tons per year.
3.   There is also great diversity in the unit  value  of  product mined.   In
     the segments studied,  this value varies from $20 per ton for crude
     phosphate to over $10 million per ton for  gold.
4.   With few exceptions (notably  in  the precious metals) the trend has
     been toward a reduction in the number of active  mines in most
     segments and an increase in the  number  of  inactive mines,  closed or
     abandoned mines.
5.   Metals, phosphate, and asbestos  mining  are very  heavily  concentrated
     in a few States and EPA Regions.   Over  90  percent of the mine sites
     in the industry segments are  west of the Mississippi River,  and over
     60 percent are  concentrated in just 10  States with 20 or more mines
     each.  Eight of these  10 States  are in  the Rocky Mountain  and Great
     Basin regions (EPA Regions 6,8,9,  and 10), where almost  65 percent  of
     U.S. metal  mines  are located.
                                   6-2

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    6.    These mines are generally  located  In  areas  of  low  population
         density.   They are often,  although not always,  located  several
         kilometers from population centers and the  sources of public  water
         supplies  (reduced human exposure Impact).
6.2.2    Waste Quantities
    The conclusions summarized in this section are derived  primarily from EPA
studies.   Waste quantity estimates are based largely on primary  data from the
U.S. Bureau of Mines on ore concentration and productivity  for individual  mine
properties or producing regions, supplemented by EPA-sponsored engineering
studies and extrapolations.  These studies and extrapolations are described in
detail in Section 4.1 and Appendix B to this report.  Waste types and
quantities reported here include all mine overburden and waste rock (mine
waste), material subject to dump (copper) or heap (gold and silver) leach
operations, and tailings from beneficiation processes.
    1.   Annual aggregate waste quantities for these segments are large by any
         standard.  Mines in the metal, phosphate, and asbestos segments
         produce about 1.0 to 1.3 billion metric tons per year of various
         types  of mining waste.  By contrast,  total municipal "post-consumer"
         solid waste totals 150 million tons and total  industrial hazardous
         waste  for  all  industries other than mining totals about 250 million
         tons per year.
     2.   Total  waste accumulated by all active, inactive,  and abandoned mines
         since  1910 is  estimated at 50 billion metric  tons.
     3.   Ratios of  waste  to product in mining  vary  considerably, but are
         generally  substantially higher than  for any other industries.  The
         percentage of  marketable  ore obtained from mining operations ranges
         from 60  percent  of the material excavated  at  iron ore mines to
                                        6-3

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     30 percent at surface copper mines and 7 percent at surface uranium
     mines.  By contrast, 50 percent or more of all  the harvested wood in
     the forest products industry becomes marketed wood or paper products,
     and only a very small  percentage of crude oil  remains as waste in the
     production of fuels and petrochemicals.
4.   Total  waste quantities vary greatly among facilities  in  mining.   As
     noted earlier, 25 percent of the mines in this study  are rated at
     less than 1,000 tons per year of total  material  handled  (well  within
     the waste generation range of facilities in,  say,  the pulp and paper
     or petrochemicals industries.)   On the other  hand, the larger
     facilities in the copper, iron, and phosphate mining  segments handle
     more than 10 million tons per year each.   Any one  of  these larger
     individual  facilities will  generate more total  waste  in  the normal
     course of its activities than all  firms together in almost any other
     industry.
5.   Aggregate waste in mining is concentrated in  a few segments and a few
     states.   Seventy percent of the 1.3 billion tons of total  mining
     waste (1982) was generated in two segments, copper (39 percent)  and
     phosphates (31  percent).   This  suggests that  almost 23 percent of all
     mining waste is generated in Arizona (68 percent of copper
     production), and that almost 23 percent of this  waste is generated  in
     Florida (74 percent of U.S.  phosphate production).  An additional  14
     percent of all  mining waste was contributed by  iron mining (largely
     in Minnesota),  and 6 percent by uranium (Colorado,  New Mexico, Utah,
     and Wyoming).   All  remaining nonfuel  mining segments  together
     generated the remaining 10 percent of total mining industry waste.
                                   6-4

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6.2.3    Potential  Hazard Characteristics
    Data on waste hazard characteristics are the result of extensive  EPA
sampling and analysis studies,  as described in Section  4,  and  are  based  on
samples from 86 extraction and  beneficiation sites.
    1.   Of the 1.3 billion metric tons of waste produced  each year,  only
         61 million metric tons (5 percent) of copper,  gold,  silver,  lead,  or
         zinc wastes exhibited  RCRA hazardous characteristics.  These include
         50 million metric tons of corrosive (pH less than 2.0)  copper leach
         dump waste and 11 million metric tons of gold, silver,  lead, or zinc
         overburden or tailings that were EP toxic (generally  for  lead).  EP
         toxicity test leachates from gold, silver,  lead,  zinc,  uranium, and
         other metal wastes had toxic metal concentrations between 20 and 100
         times the levels set by the National Interim Primary  Drinking Water
         Standards; however, these were below the threshold of being  a
         hazardous waste.
    2.   Twenty-three million metric tons per year of gold and silver wastes
         are potentially hazardous because they have been  leached  using  a
         cyanide solution.  These cyanide wastes include those metal  recovery
         wastes previously listed as hazardous, as well as heap leaching
         wastes, but do not include copper mill tailings or other  mill
         tailings with low (less than 10 mg/liter) concentrations  of  cyanide
         from flotation circuits.
    3.   Copper leach dump material (182 MMT) and copper mill  tailings
         (95 MMT) may be hazardous.  In addition to the 50 MMT/year of copper
         leach dump waste estimated to be corrosive, the remaining 132 MMT of
         this waste may also pose potential hazards because of its low pH and
         relatively high concentrations of toxic metals.  Copper leach dump
                                       6-5

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     wastes are  potentially  hazardous  even when  the  pH  level  of  their
     leachate is not below 2.0,  because  their  leachate  is  still  quite
     acidic and  contains toxic metals.   However,  toxic  constituents  in  and
     hazardous characteristics of  these  wastes do not exceed  EPA's
     established criteria.   Similarly, copper, gold, silver,  and lead mill
     tailings containing high  (greater than  1  percent)  concentrations of
     pyritic material and low (less than 1  percent)  concentrations  of
     carbonate buffers have  a  high potential  for forming and  releasing
     sulfuric acid.
4.   Naturally occurring radioactivity (radium-226)  levels in excess of
     five picocuries per gram (pCi/g)  has been estimated for  443 million
     metric tons/year of wastes  from sites  generating uranium mine  waste
     and phosphate wastes.  Use  of an  alternative radioactivity  measure of
     20 pCi/g yields an aggregate  estimate of about  93  million metric
     tons/year of radioactive waste, most of which is  uranium mine  waste.
5.   Four asbestos mines generate  about  5 million metric tons per year of
     waste containing high  (greater than 1  percent)  asbestos  fiber
     content.  Only asbestos mines were  tested in the  current study for
     asbestos fibers.
6.   EPA's solid waste sampling thus far has  not found any hazardous
     characteristic in waste from the iron ore,  molybdenum, or certain
     minor metals segments.  The Agency tested wastes from virtually all
     metal mining segments  but did  not  test wastes from all mineral mining
     segments,  on the assumption that these wastes are unlikely to be
     hazardous.
7.   Based on the above,  the Agency concludes that as many as 80 percent
     of the metal mining  facilities and perhaps 56 percent of the waste
                                   6-6

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         generated could be considered potentially hazardous to human health
         or the environment under some circumstances.   Generally,  a given mine
         site will exhibit only one primary problem:  EP toxicity,  cyanide
         contamination, corrosivity/acidity, radioactivity,  or asbestos,
         according to the Agency's sampling results.
6.2.4    Evidence of Environmental Transport of Potentially  Hazardous
         Constituents
    The potentially hazardous constituents and characteristics of  various
mining wastes can be transported from the location of  storage  or disposal  to
possible receptors by various combinations of surface  water  flow,  seepage into
ground water and ground-water flow, and wind currents.   The  Agency's  studies
in this area focused primarily on efforts to evaluate  environmental  transfer
to and through surface and ground water.   Study methods included both a
literature search and a limited field monitoring study at eight selected  mine
sites (one only for surface water) over a 6- to 9-month monitoring period.
    1.   Ground-water monitoring is difficult,  expensive, and  has  seldom  been
         conducted at mine sites on a comprehensive basis.   Because of complex
         geologic strata (presence of an ore body) and the extensive  size  of
         many mine properties, proper ground-water monitoring  is technically
         difficult and costly.  Historical  practice in the mining  industry has
         not required such monitoring.   As  a result, there is  very  little
         available information in the literature,  and  almost none  on  a
         complete or comprehensive basis.   Most mines  have no  historical or
         contemporary ground-water monitoring information.
    2.    EPA's limited field  monitoring  shows environmental  transfer  of mine
         waste constituents to ground water,  but not necessarily transfer  of
         the EP toxic constituents of concern.   Mine waste constituents—both
         indicator sulfates,  chlorides,  and some elements that could  be
                                      6-7

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         considered environmentally harmful—were shown to migrate from waste
         management areas to local  aquifers.   Short-term monitoring detected
         seepage from tailings impoundments (a copper, lead, phosphate sand,
         and two gold impoundments), a copper leach dump, and a uranium mine
         water pond.  However, the EP toxic constituents of concern did not
         appear to have migrated at these sites during the short period of
         this study.
    3.   EPA's limited field monitoring generally did not show contamination
         of surface waters, but this may be the result of local circumstances
         of management, climate, and parameters monitored.  Surface water
         contamination would not be expected  downstream from an intact
         tailings impoundment.  However, abnormally heavy precipitation could
         lead to releases or bypasses to protect the integrity of the
         impoundment dam.
    4-   Other scattered monitoring study data suggest mixed or inconclusive
         results regarding ground water and surface water contamination by
         constituents of concern.  In Arizona, copper mine runoff has degraded
         surface water, and uncontained leachate from copper leach dump
         operations has degraded ground water by lowering pH and increasing
         concentrations of sulfates, copper,  and total  dissolved solids.
         Abandoned gold recovery operations that did not treat wastes before
         release can be the source  of persistent cyanide contamination.
         Generally, contaminant plumes from tailings impoundments (other than
         uranium mill  tailings impoundments)  have not been studied.
6.2.5    Evidence of Damage
    The Agency's conclusions on observed damage to the enviroment and health
are based on an  extensive survey of State government natural  resource and
                                       6-8

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health agency files through 1984 to obtain evidence of environmental
incidents, followed by review and evaluation of the evidence obtained.   All  50
States were surveyed by telephone, and 10 were visited.   The mining sites
reported on were not visited to observe or verify data obtained in the
survey.   Several  hundred initially reported incidents were evaluated and
eventually narrowed down to 20 verifiable cases of damages having substantial
documentation.  The damage survey was supplemented by reviews of published
reports and National Priorities List (Superfund) data.
    1.   Damage cases are about equally distributed between catastrophic
         (sudden releases, spills) and chronic (seepage, periodic runoff)
         incidents.
    2.   Documented damage typically involves physical or chemical degradation
         of surface water ecosystems, often including fish kills or reduction
         in biota, but seldom involves direct effects on human health.
    3.   A number of incidents of damage caused by mining wastes at currently
         active sites in the phosphate, gold, silver, copper, and uranium
         industries have been well documented in several States, including
         Arizona. Colorado, Florida, Missouri, Montana,  and New Mexico.
         Similar results have been documented at inactive sites, but abandoned
         and Superfund sites may have additional problems.
    4.   Damage to surface waters has often been reducible or reversible by
         use of modified waste management practices or other physical controls.
6.2.6    Waste Management Practices
    The Agency's conclusions on waste management practices are based on
literature reviews, site visits in conjunction with waste sampling,
engineering design studies, and consultation with State regulatory agencies
and mine company engineers.
                                       6-9

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1.    Site selection,  including both  the mine property  itself and  the
     specific location of waste storage, treatment,  and  disposal
     activities,  is perhaps the single most important  aspect of
     environmental  protection in the mining industry.  The  selection  of
     the mine property is based primarily on the  ability of the operation
     to produce a commodity (e.g., copper, gold,  etc.) at a competititve
     price and a reasonable profit.   The cost of  transporting  waste via
     pipeline, conveyor, or truck to the disposal  site is an  important
     variable in determining the profitability of the  mine, because of the
     large volume of material moved  at most mines.
2.    The potential  for waste utilization as a solution,  or  even as a
     significant contributor, to waste management in most mining  segments
     is extremely limited.
3.    There are few major innovations under development that would lead to
     major changes in mine production processes or waste management
     practices.
4.    The difference between  "best practice" and typical  practice  is often
     significant among mines in many major segments.  These differences
     are related to both voluntary management practices  and variations in
     State regulations.
 5.    Within  known technological options, there appear to be major
     opportunities for process modifications, some source separation of
     wastes,  treatment of acids and cyanides, and, possibly,  controlled
     release  of certain effluents that could significantly reduce damage
     potentials in certain contexts.
 6.   Many waste management practices being applied to hazardous waste in
                                   6-10

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         other industries—most notably caps and liners—have not been
         attempted for mining wastes.
6.2.7    Potential Costs of Regulation
    The Agency conducted engineering cost analyses,  using  several  different
hypothetical  regulatory scenarios,  for a sample of 47 actual  sites,  and then
extrapolated these costs to the universe of facilities in  the copper,  lead,
zinc, silver, and gold mining segments.  EPA's approach, methods,  and
assumptions are discussed briefly in Section 5 and in Appendix B.
    1.    For five metal mining segments, total annualized  costs could  be
         substantial, but vary considerably across different hypothetical
         regulatory scenarios.  Annualized costs range from $7 million  per
         year (for a scenario that emphasizes primarily basic maintenance  and
         monitoring of RCRA hazardous wastes) to over $800 million per  year
         (for a highly unlikely scenario that approximates a full  Subtitle C
         regulatory approach emphasizing cap and liner containment for  an
         expanded range of potentially hazardous wastes).
    2.    Almost 60 percent of total  projected annualized costs at operating
         facilities can be attributed to the management of waste accumulated
         from past production.
    3.    Costs would vary greatly among segments.  Some segments may not be
         affected at all (iron, molybdenum), because their waste streams
         apparently do not contain hazardous constituents.  Total  lifetime
         costs for affected segments could range from $45  million  for  zinc up
         to $8.3 billion for copper (for the highest cost  scenario).
    4.    Costs would vary greatly among mines within segments.  Incremental
         compliance costs, as a percentage of direct product cost, could vary
         as much as 25:1 among facilities within a given segment.   Factors
                                       6-11

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         affecting these differences  include  geography,  ore  grade,  past  waste
         accumulation,  percentage  of  waste with  hazardous characteristics,  and
         process and waste management practice efficiencies.

                             6.3  RECOMMENDATIONS
    Section 8002(f) of RCRA requires  EPA to  conduct a study  of the  adverse
effects of mining waste and to provide "recommendations  for  Federal...actions
concerning such effects."  Based on our findings from this study, we  make
several preliminary recommendations for those wastes and industry segments
included in the scope of the study.  The recommendations are subject  to  change
based on continuing consultations  with the Department of the Interior (DOI)
and new information submitted through the public hearings and comments on this
report.  Pursuant to the process outlined in  RCRA  §3001(b)(3)(C), we  will
announce our specific regulatory determination within six months  after
submitting this report to Congress.
    First, EPA is concerned with those wastes that have  the  hazardous
characteristics of corrosivity or EP  toxicity under current  RCRA  regulations.
EPA intends to investigate those waste streams.  During  the  course  of this
investigation EPA will  assess more rigorously the  need for and nature of
regulatory controls.  This will  require further  evaluation of the human  health
and environmental exposures mining wastes could  present. EPA will  assess the
risks posed by various types of mining waste sites and alternative  control
options.  The Agency will perform additional  waste sampling  and analysis,
additional ground-water or surface water monitoring analysis, and additional
analysis of the feasibility and cost-effectiveness of various control
technologies.
                                       6-12

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     If the Agency determines through the public comments, consultation with
DOI  and other interested parties, and its own analysis, that a regulatory
strategy is necessary, a broad range of management control options consistent
with protecting human health and the environment will be considered and
evaluated.  Moreover, in accordance with Section 3004(x), EPA will take into
account the "special characteristics of such waste, the practical difficulties
associated with implementation of such requirements, and site-specific
characteristics...," and will comply with the requirements of Executive Orders
12291 and 12498 and the Regulatory Flexibility Act.
     Second, EPA will continue gathering information on those waste streams
that our study indicates may meet EPA's criteria for listing—dump leach waste,
because of its high metal concentrations and low pH, and wastes containing
cyanides.  Although these waste streams are potential candidates for listing
as hazardous wastes, we need to gather additional information similar to the
information gathered for the rulemaking for corrosive and EP toxic wastes.
When we have gathered sufficient information, we will announce our decision as
to whether to initiate a formal  rulemaking.   If the Agency finds it necessary
to list any of these wastes, we will also develop appropriate management
standards in the same manner as those for corrosive and EP toxic wastes.
    Finally, EPA will continue to study radioactive waste and waste with the
potential  to form sulfuric acid.   The Agency is concerned that radioactive
wastes and wastes with the potential for forming acid may pose a threat to
human health and the environment, but we do  not have enough information to be
able to conclude that they do.   We will  continue to gather information to
determine whether these wastes  should be regulated.   If EPA finds that it is
necessary to regulate these wastes,  the Agency will  develop the appropriate
measures of hazard and the appropriate waste management standards.
                                       6-13

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                                   SECTION 7

                             SELECTED BIBLIOGRAPHY


Alper, Joseph.  1984.  Bioengineers are off to the mines in high technology.
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American Mining Congress.  1982.  Reclamation Plan for the Jackpile-Paguate
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ASCE.  1977.  Waste clay dewatering and disposal, in Bromwell, L.G., and
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Bates, Robert L., and Jackson, Julia A. (eds.).  1984.  Dictionary of
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Bell, Alan V.  1976.  Waste controls at base metal mines.   Environmental
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BOM.  1985.  Open File Report 185-84, Groundwater Monitoring in the Tucson
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BOM.  1984.  Minerals Yearbook.   Washington, DC:  U.S. Bureau of Mines,  U.S.
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BOM.  1983.  Minerals Yearbook.   Washington, DC:  U.  S. Department of the
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BOM.  1980a.  Mineral  Facts and  Problems.   Washington, DC:   U.S. Department
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BOM.  1980b.  Open File Report 94-80, Containment Pond Technology—State of
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    of Mines.
                                     7-1

-------
BOM.   1979.   Minerals Yearbook.   Washington,  DC:   U.S.  Department of the
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BOM.   1975.   Mineral  Facts and Problems.   Bulletin 667.   Washington, DC:
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Bruynesteyn, A.,  and Hackl,  R.P.   1982.   Evaluation of  acid production
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Carroll,  Walter.  1983.   Mine waste hazards.   MESA--The  Magazine  of Mining
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Chafer,  Arthur B.  1974.  Guidelines for  the  Design, Construction and
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Charles  River Associates.  1985a.   Estimated  Costs to the U.S. Mining
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Charles  River Associates.  1985b.   Estimates  of Investment  and Operating Costs
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Charles  River Associates.  1985c.   Proprietary Data Base.   Boston, MA:
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Charles  River Associates.  1984.   State Regulations and Management Practices
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Collins,  R.J., and Miller, R.H.   1977.  Availability of Mining Wastes and
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Cook, Philip M., Rubin, Ivan B.,  Maggiore, Carl J., and Nicholson, William
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    of Electrical and Electronics Engineers.

Coppa, L.V.  1984.  Copper, Lead, Zinc, Gold, and Silver Waste Disposal
    Activities and Practices in the United States.  Washington,  DC:  U.S.
    Department of the Interior, U.S. Bureau of Mines.
                                      7-2

-------
Curtin, Mary Ellen.  1983.  Microbial mining and metal  recovery.
    Bio/Technology (May):229-35.

Dames & Moore.  1985.  EPA/PEDCo Mine Waste Management Study:   Overview.
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DOE.  1985.  Technical  Summary of the UMTRA Project Technology Development
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Edwards, R.E., N.A. Speed and D.E. Vernoert.  1983.  Cleanup of chemically
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ERCO/A Division of ENSECO.  1984.  Mining Waste Study:   Draft Data Report
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Geological Society of America.  1971.  Thermal  Monitoring  of Leakage Through
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Goodson & Associates.  1982.  Development of Systematic  Waste Disposal  Plans
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Gordon, A.J.  1984.  Mining Impacts on Groundwater Quality in the State of
    Arizona U.S.A.  Phoenix, AZ: Arizona Department of Health Services.

Greber, J.S.,  Patel,  V.P., Pfetzing, E.A., Amick, R.S.,  and Toftner, R.O.
    1979.  Assessment of Environmental  Impact of the Mineral Mining Industry.
    EPA-600/2-79-107.  Cincinnati, OH:   U.S. Environmental Protection Agency,
    Office of Research  and Development, Industrial  Environmental Research
    Laboratory.

Harding-Lawson Associates.  1981.  Development of Methods  for Reclaiming
    Abandoned Tailings  Ponds and Dams:  Volume I.  Bureau of Mines  Open  File
    Report 40(1)-82.   Report prepared for the Bureau of  Mines under Contract
    No. J0199117.   Washington, DC:  U.S.  Department of  the Interior, U.S.
    Bureau of Mines.

Harty, David M., and Terlecky, Michael  P.  1982.  Characterization of
    Wastewater and Solid Wastes Generated in Selected Ore  Mining Subcategories
    (Sb, Hg, Al, V, W,  Ni, Ti).  Report prepared for the Effluent  Guidelines
    Division,  U.S. Environmental Protection Agency, by Frontier Technical
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Heming, T.A.  1985.  Physiological and  Toxic Effects of  Cyanides to Fishes:
    A Review and Recent Advances.  Conference proceedings:   Cyanide and the
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    Colorado State University.
                                     7-3

-------
Jennett, J.C., and Foil, J.I.  1979.   Trace metal  transport from mining,
    milling, and smelting watersheds.  Journal  of the Water Pollution Control
    Federation 51(2):378-404.

Klohn, Earle J.  1981.  Current tailings dam design and construction methods.
    Mining Engineering (July):798-808.

Lucia, P.C.  1982.   Review of Experience with Flow Failures of Tailings, Dams
    and Waste Impoundments.  Berkeley, California: University of California.

Martin, Harry W., and Mills, William R. Jr.  1976.  Water Pollution Caused
    by Inactive Ore and Mineral  Mines.  Report prepared for the Industrial
    Environmental Research Laboratory, Office of Research and Development,
    U.S. Environmental Protection Agency, by Toups Corporation.  Contract No.
    68-03-2212.  Cincinnati, OH:  Industrial  Environmental  Research Laboratory.

Missouri Geological Survey.  1979.  Effects of Abandoned Lead and Zinc Mines
    and Tailings Piles on Water Quality in the Joplin Area, Missouri.  Ozark
    Gateway Council of Governments, Joplin, Missouri.  Report No.
    USGS-WRD-WRI-77/079; USGS/WRI-77-75.

Mountain States Research and Development, Inc.   1981.  Inventory of Waste
    Enbankments of Surface and Underground Openings:   Metal and Nonmetal
    Active Mines.  Bureau of Mines Open File Report 110-82.  Report prepared
    for the U.S. Bureau of Mines under Contract No. J0199054.  Washington,
    DC:  U.S. Department of the Interior, U.S.  Bureau of Mines.
MSHA.  1984.
    (draft).
Design Guidelines for Mine Waste Piles and Tailings Dams
Washington, D.C.:  Mine Safety and Health Administration.
MSHA.  1983.  Report of Progress to Implement Federal  Guidelines for Dam
    Safety.  Washington, DC:  Mine Safety and Health Administration.

New Mexico Energy and Mining Department.   1979.   An Overview of the New Mexico
    Uranium Industry.  Santa Fe, NM:  New Mexico  Energy and Minerals Department.

Pacific Northwest Laboratories.   1983.   Geochemical Modelling of Uranium Mill
    Tailings, A Case Study.   Annual Geochemistry Review,  Proceedings of a
    Conference, Washington,  DC.

PEDCo Environmental, Inc.  1984.  Evaluation of  Management Practices for Mine
    Solid Waste Storage, Disposal, and  Treatment.   3 Vols.  Prepared for the
    Industrial  Environmental Research Laboratory,  U.S. Environmental
    Protection Agency.   Contract No.  68-03-2900.  Cincinnati, OH:   PEDCo
    Environmental, Inc.
Pima Association of Governments.   1983.
    Copper Mining District.   Pima, AZ:
                           Ground-Water Monitoring in the Tucson
                          Pima Association of Governments.
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    Drainage (Stauffer Mine Pollution),  Caribou National  Forest.   Progress
    Report No.  1. Boise, ID:  U.S.  Forest Service.
                                      7-4

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Portfors, Ernest A.  1981.  Environmental aspects and surface water control,
    in Wilson, D., (ed. ):  Design and Construction of Tailings Dam  (ed. David
    Wilson),  July 1981, 99-117.

Ralston, D.R., Mohammad, 0., Robinette, M., and Edwards, T.  1977.  Solutions
    to Water  Resources Problems Associated with Open Pit Mining in the
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    University of Idaho.

Ryck, P.M., and Whitely, J.R.  1974.  Pollution Abatement in the Lead-Mining
    District of Missouri.  Proceedings of the 29th Purdue Ind. Waste
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Schiller, Joseph E.  1983.  Removal of Cyanide and Metals from Mineral
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Schrader, Ed L., and Furbish, William J.  1978.  An aqueous and
    sedimentalogical  model for heavy metal contamination of stream systems
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                                      7-5

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TFI.  1984.  Water Quality of Phosphate Mine Effluents in Florida,
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                                      7-6

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Wixson,  Bobby G.,  Gale,  Nord L.,  and Davies, Brian E.   1983.   A Study  on the
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                                     7-7

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                APPENDIX A
SUMMARY OF MAJOR WASTES FROM THE MINING AND



          PROCESSING OF OIL SHALES

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                                  APPENDIX A
                  SUMMARY OF MAJOR WASTES FROM THE MINING AND
                           PROCESSING OF OIL SHALES
                               A.I   INTRODUCTION
     It is projected that the first U.S. commercial oil shale plant (Union
Oil's 10,000 bbl/day Long Ridge facility) will come on line in 1985.   Other
larger plants are scheduled to start production between 1987 and 1994, and
many of these may be supported by the Federal Government through the U.S.
Synthetic Fuels Corporation.  It has been estimated that in the western United
States alone, mining and processing volumes could eventually reach 1 million
metric tons per day.
    The mining methods that will be used include room-and-pillar, lane-and-
pillar, open pit, and vertical-modified-in-situ (VMIS); production rates are
expected to range from about 12,000 to approximately 150,000 metric tons per
day.  Downstream, or auxiliary, operations will include oil upgrading, gas
cleanup, and raw and wastewater treatment, but the processes that will be used
in these operations are more diverse and less well  defined than mining and
retorting operations.
    Although the types and quantities of solid wastes that will be produced by
oil shale plants are not well  defined at this time, it is estimated that
production of the volume of oil  shale anticipated (1  million metric tons per
day) will  require the disposal of 810,000 metric tons of retorted shale per
1 The information in this Appendix has been summarized from "High Volume
  Wastes from the Mining and Processing of Oil  Shales," written by E.R. Bates,
  U.S.  Environmental Protection Agency, 1985, but not yet published.
                                     A-l

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day, 66,000 metric tons of raw shale fines  per day,  and  over 3,000 metric  tons
per day of spent catalysts, treatment chemicals and  sludges, and  byproduct
wastes.  This would result in 300 million metric tons per year of wastes that
must be disposed of in an environmentally acceptable and cost-effective manner.
    Table A-l shows the estimated quantities of solid waste that  are projected
to be produced by a commercial oil  shale industry mining 1  million metric  tons
per day of raw oil shale.  Some of these wastes, such as spent arsenic guard
bed catalysts and API separator bottoms, will  most certainly be hazardous.
For the most part, these wastes will be produced in  the  large-scale
solids-handling operations associated with  most oil  shale facilities.  They
include spent shale from retorting operations, dusts recovered from air
pollution controls, and unused raw shale (sub-ore, fines, dust).
Non-marketable byproducts, oily solids, scrap, and garbage  are also considered
major solid wastes.
    A number of other solid wastes that may contain  materials that are
classified as hazardous will also be generated by commercial oil  shale
facilities.  These include spent catalysts, used chemicals and sludges from
gas cleanup operations, and water treatment sludges and slurries.  Hydrogen
plants, which produce hydrogen for hydrotreating the crude shale, will be the
major source of a variety of  spent catalysts.  As listed in Table A-l, these
catalysts may include Co-Mo and ZnO catalysts from the hydro-desulfurizer
 (HDS) unit; Ni-base, Fe-O, and Cu-Zu catalysts from the reformer; Ni-base
catalysts from the methanator; and arsenic guard bed and hydrodenitrification
 (HDN) catalysts from the hydrotreater.  However, as can be  seen from the
 individual quantities and  totals listed, discrepancies exist  in the  estimates
 of quantities that may be  produced.
                                      A-2

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      Table  A-l   Relative  Quantities  of Solid Wastes  Potentially
                Generated by the Oil  Shale Industry
Type of
waste
Mean Quantity of
Waste Produced
(metric tons/
million metric
tons of shale
mined)
Standard Deviation
(metric tons/
million metric
tons of shale
mined)
Percent
Uncertainty3
(*)
Data
Points
(N)
Major Solid Wastes:
Spent Shale
Raw Shale
Rejects
Off-Spec
Byproducts
Oily Solids
Scrap and
Garbage
TOTAL5
Spent Catalyst
Hydrogen Plant0
HDS Unit
Co-Mo
ZnO
Reformer0
Ni-base
Fe-Cr
Cu-Zn
Methanator
Ni-base
Hydrotreater0
Guard Bed
HDN
810,000
66,100
1,180
340
40
880,000
Generation:
3.50
0.96
0.41
0.65
3.01
0.81
1.23
1.64
0.34
0.34
20.5
15.6
1.45
24,000
12,200
170
180
20
40,000

0.25
0.18
0.20
0.17
0.24
0.02
2.8
2.0
3.0
18.5
14.4
52.9
50.0
5.0

7.1
18.8
48.8
26.2
19.5
5.9
13.7
12.8
8
8
4
5
4
-

5
4
3
4
2
2
4
2
4
4
4
2
TOTAL c
26.9
5.1
19.0
                                A-3

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                              Table A-l (Continued)
Type of
Waste
Mean Quantity of
Waste Produced Standard Deviation
(metric tons/ (metric tons/
million metric million metric Percent
tons of shale tons of shale Uncertainty3
mined) mined) (%)
Data
Points
(N)
Gas Cleanup Processes:
Activated Alumina 1.86 0.90 48.4
Co -Mo
A1203
DEA
Stretford
Chemicals
TOTAL0
FGD Sludges
Water Treatment
Biological
SI udges
Sludges
& Floats
Tank Bottom
(WWT) Sludges
API Separator
Bottoms
API Float
Raw Water
Treatment
0.11
0.13
0.60

1.87 0.58 31.0
2.06 0.54 26.4
2,250 1,500 66.0
Sludges and Slurries:

545

6,900
150

20 -

2 -
72 -

3
2
2
1

3
6
3


3

1
2

2

1
1

Sludges & Floats
a Percent uncertainty is the relative standard deviation.
b Included in this total are 2340 million metric tons of solid wastes not
  broken out separately above.
c Quantities in subcategories do not equal the total for these categories.  These
  discrepancies result from the small data base, differing information from
  various projects, and uncertainty since these plants have not yet been operated.
  For a full explanation, see Heistand 1985.
Source:  Heistand 1985
                                     A-4

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    Because planned gas cleanup operations are more diverse and less well
defined than oil upgrading, the amounts of chemicals used (activated alumina,
Co-Mo, A^Og, DEA, and Stretford chemicals) and flue gas desulfurization
(FGD) sludges from gas cleanup processes are more difficult to estimate, and a
solid statistical analysis of the mean factors listed in Table A-l  is not
feasible.  Information on chemicals other than activated alumina and the
Stretford chemicals is incomplete, and several projects plan to use more than
one of the gas cleanup chemicals listed.  The estimated total  of used
chemicals generated from fuel  gas cleanup is about 2.1  metric  tons  per million
metric tons of oil shale mined.  While FGD has been suggested  as an
alternative to fuel gas cleanup processes, the amounts  of FGD  chemicals such
as calcium sulfate or gypsum are quite high, with mean  quantities projected to
be 2,250 metric tons per million metric tons of shale (Heistand 1985).
    Sludges and slurries will  be generated in raw and wastewater treatment in
commercial oil  shale facilities.   Because the exact composition and amounts of
the wastewaters requiring treatment are not well  defined and many of the
resulting materials may be used on site, only limited information is available
for estimating the volume of water treatment sludges and slurries (Heistand
1985).  The dry weights of these wastes are listed in Table A-l.

                    A.2  POTENTIAL DANGERS TO HUMAN HEALTH
                             AND  THE  ENVIRONMENT
    Oil  shale facilities will  produce  large volumes of  solid wastes that have
only a limited reuse potential.  In some cases,  spent catalysts may be
reclaimed and recycled  back into the process.   Elemental  sulfur,  which  can be
removed  by some air pollution  control  technologies, has some market potential
                                     A-5

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although the presence of trace impurities may constrain its use.   Hazardous
wastes such as some spent catalysts and sludges will  be disposed  of in
licensed hazardous waste facilities.
    The catalyst that is of particular concern in oil  shale upgrading is the
arsenic guard bed catalyst.  Raw shale oil contains significant amounts of
arsenic (15 ppm range) that must be removed prior to upgrading and refining.
Arsenic is removed by the arsenic guard bed catalyst, which must be replaced
periodically and reclaimed or disposed.  However, no facilities currently
exist to reclaim the catalyst, and environmentally safe disposal  of this spent
catalyst, which may contain 20 percent arsenic as well as other contaminants,
and be pyrophoric  (tend to autoignite), may be difficult.  As noted in
Table A-l, approximately 15 metric tons of spent arsenic guard bed catalyst
will be produced for each million metric tons of shale mined.
    Other dangers  to human health and  the environment posed by oil shale
mining and processing may result from  the long-term effects of the onsite
disposal of millions of tons  of retorted oil  shale, raw oil shale waste, and
other process wastes.  These  hazards include  the following:
    •    Auto-oxi dati on/autoi gni ti on
    •    Leaching
    •    Mass failure.
A.2.1   Auto-oxidation/Autoigm'tion
    Auto-oxidation resulting  in autoignition  may be  a  serious  problem if raw
shale  fines and/or carbonaceous spent  shales  are not  disposed  of  in  a manner
that  minimizes  this hazard.   If oil  shale disposal  sites are not  properly
designed they could autoignite, releasing large  quantities of  pollutants such
S02,  NO ,  H2S,  C02, trace  elements,  and  hydrocarbons.   Combustion
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 could  also  impair pile stability, resulting in disposal pile failure and/or
 acceleration of the leaching process.  EPA has recently conducted tests to
 assess the  potential for autoignition of waste raw oil shale fines and
 retorted oil shales (EPA 1984).  The results of these tests indicate that raw
 shale  fines have an autoignition potential similar to that of bituminous
 coals,  while retorted shales appear to be less reactive.
 A.2.2   Leaching
    High inorganic salt loading and possible organics in leachates from raw
 shale  fines or spent shale could have potentially significant impacts on
 ground-water supplies and on surface waters that supply the water needs of
 millions of people.  Because the composition of retorted oil  shales varies
 based  on the properties of the raw shale feed and the retorting process used,
 the composition of any leachates from retorted shale disposal  sites will  vary
 depending on the properties of the retorted shale and on other wastes disposed
 of with the retorted shale, such as wastewaters for cooling/wetting and
 treatment sludges.
    The available data indicate that even if raw and retorted  shale wastes are
 not defined as hazardous under RCRA,  the leachates from these  wastes are  high
 in dissolved salts as well  as other contaminants and could have a serious
 impact on surface and ground water if significant amounts  of leachate are
 produced.   The amount of leachate produced will  depend to  a large extent  on
 site-specific characteristics and the disposal  controls employed.   Because
billions of tons of retorted oil  shale may eventually be produced,  the
cumulative impact on water  quality could be very great.
A.2.3  Mass Failure
    Retorted oil  shale disposal  sites will  be  the largest  solid waste disposal
sites ever constructed.   A  typical  50,000 bbl/day surface  retorting plant will

                                     A-7

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produce about 450 million cubic feet/year of solid  waste,  which would  cover an
area of about 3.5 square miles to a depth of 150 feet over an  operating  plant
life of 30 years (USEPA 1980).  Mass failure of  one of these fills  could cause
extensive property damage and threaten lives.  Failure of  even one  of  the
several disposal piles proposed could destroy downstream reservoirs; threaten
shale oil upgrading, storage, and loading facilities; and  deposit millions of
tons of leachable retorted shale in the Colorado River and/or  its tributaries.
    The most likely cause of a disposal site failure is saturation  of  the
waste pile and/or liquefaction of the pile bottom leading  to  slippage.
Moisture that could contribute to this problem might result from wastewaters,
precipitation and infiltration, ground-water intrusion into the pile,  or
surface  streams routed over or through the disposal site.

                          A.3  DISPOSAL ALTERNATIVES
A.3.1  Alternatives for Minimizing Environmental Impacts
    Oil  shale operations will result in significant land disturbances  on and
near the development  site.  Use of the land  required for access to the site
for mining,  processing facilities, and waste disposal will permanently modify
the terrain  and influence the ecosystem by causing changes in the vegetation
and habitat.  Local aesthetics will also be  affected.
    The  most significant  impacts on the environment will  probably result from
the disposal  of solid shale wastes, which will  remain  long after a mine has
been depleted and  the processing facility has closed  down.  A major factor  to
consider in  solid  waste  disposal is the surface- and  ground-water regime of
the  site.  While a waste  landfill  should  blend  in  cosmetically with the
surroundings, it must also be sufficiently  isolated  from  the surrounding
                                      A-8

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strata to protect the hydrologic environment.  Other factors that influence
waste disposal and may contribute to the extent of environmental  impacts are
the size and duration of the oil shale operation and the mining and retorting
technologies used.  Because a substantial  amount of raw shale will  need to be
mined and processed to produce oil, the processed shale will be the major
waste produced by oil shale processing and its disposal will be the primary
environmental issue.
    The physical and chemical properties of the processed shale as well as the
geology and hydrology of the site will be the determining factors in selecting
disposal and reclamation approaches.  Every retorting method produces shale
that is unique and every development site has features not found elsewhere,
and therefore their combination should be analyzed on an individual basis.
The physical and chemical characteristics of the processed shale will be
determined by the source of the raw shale, its particle size after crushing
and retorting, and the temperature of the retorting.
    There are primarily two types of processed shale—carbonaceous and burned
(decarbonized).  Carbonaceous processed shales are produced by indirect
retorting in which residual coke on the retorted material  is not incinerated.
Examples of this type of retorting are the TOSCO II and Union B processes.
Burned shales originate either from direct-heat processes, such as Paraho and
Modified in Situ (MIS), in which the air is introduced in the retort to cause
combustion of the residual carbon or from combination-mode processes, such as
Lurgi, Superior, and Union C, in which the retorting primarily occurs in the
indirect mode, but the residual  coke on the procesed shale is incinerated in a
separate stage.
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    The mining and processing of oil  shale actually result in an increase in
the volume of shale.   In-place density of the raw shale  is approximately 2.16
    3
g/cm , but it is only practical  to compact the processed shale to about 1.5
to 1.6 g/cm .  Even after losing about 20 percent of its original  weight,
the shale after retorting will occupy about 10 to 15 percent more volume than
it originally occupied.   This will be an important factor when considering
different approaches for the disposal of processed shale.
    Processed shale moisturizing will be essential  in disposing of the
processed shale and will  serve several functions.  The processed shale will
emerge from most retorts at elevated temperatures, requiring cooling and/or
moisturizing prior to handling and disposal.   Transporting the processed shale
to the disposal area will involve extensive materials handling and transfer
that will be potential  sources of airborne particulates, and these particulate
emissions can be minimized by moisturizing and using covered transport.
Perhaps the most significant advantage to moisturizing is that it facilitates
proper compaction and cementing of the processed shale,  which will allow the
disposal of the maximum quantity of material  in a given  space and will  provide
greater stability to a waste landfill.
    Several alternatives are available for the disposal  of shale processing
wastes.  The disposal approaches available are surface disposal (canyon or
valley fill, surface pile), open pit backfill, underground mine backfill, in
situ retort abandonment, and, the least likely, commercial utilization of
wastes.  The approaches or combinations of approaches used will depend largely
on site-specific features, the mining and retorting methods used, the surface
and subsurface hydrology of the area, and the properties of the processed
shale resulting from the retorting methods used.   These disposal alternatives
are discussed in the following paragraphs.

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A.3.2  Surface Landfills
    The disposal of wastes in a valley or canyon near the plant site may be
the approach preferred by many oil  shale developers.  This selection is
influenced by the terrain of oil  shale areas where large valleys and/or
canyons are available on development sites to accommodate the wastes
generated.  Proper reclamation can allow for the landfill to be blended into
the surrounding terrain.
    The advantages of this type of landfill are that the surface area needing
to be reclaimed or revegetated would be reduced and the bulk of the material
would be protected from the weather.  However, water contamination resulting
from run-on and runoff and mechanical failure resulting from mass movement and
slippage are two disadvantages of this method that must be considered.  If the
disposal area is flat, the landfill will need to be built above the surface as
a pile, in which case it will not blend into the surrounding environment and
will be visible from a distance.   Although surface waste piles may limit
run-on and runoff problems, pile-up operations are more difficult and involve
more skill than valley fill operations, and exposure of landfills to wind and
water may result in excessive erosion.
    The disadvantages of surface landfills as a disposal alternative can be
summarized as follows:
    t    Exposure to rain, snow, and wind may result in erosion of the waste
         pile and mechanical failure.
    •    Waste  particles disturbed by weather may become airborne or be
         carried into surface- or ground-water supplies in runoff from the
         waste  pile.
    •    Surface landfills may not blend into the surrounding terrain.
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A.3.3  Open Pit Backfilling
    Open pit backfilling is a type of surface landfill  that may be an
alternative for open pit mining operations.   Backfilling requires that the
overburden, sub-ore, and processing wastes generated during the first 20-30
years be temporarily stored or permanently disposed of  in another location so
that they do not inhibit mining operations.   Once the mine pit has been
sufficiently developed, the waste can be disposed of in the non-active pit
areas while mining continues on the active faces.  After the project is shut
down, some of the initial  waste stored outside the pit  can be returned to the
mine, but approximately 20-30 percent of the total mined-out volume would
still need to be permanently disposed of outside the pit.
    The advantages of open pit mining and backfilling are that they allow for
greater resource recovery than underground methods and  the erosion potential
is greatly reduced because the bulk of the material  will not be exposed to the
weather.  In addition,  if backfilling is complete, the  land can be brought
back to its original contour.  The disadvantages of open pit backfilling
include the following:
    •    Additional disposal is required outside the open pit.
    •    A depression in the land surface may result from compaction and
         settling of materials backfilled into the pit, allowing water
         collection and possible waste pile infiltration.
    t    Ground water may be contaminated, particularly if the pit intersects
         an existing aquifer.
A.3.4  Underground Mine Backfilling
    Returning the processed shale to the underground mine is an attractive
disposal approach and several underground backfilling methods are available,
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although none has been tested on a large scale.   Slurry backfilling via
pipelines is practical for processed shale disposal  but requires large amounts
of water.  Transportation by conveyors or trucks and subsequent compaction
using standard machinery is another method.   Pneumatic transport is also a
possibility.
    The advantages of using underground mine backfilling are that the waste
would be protected from the weather, erosion potential  would be diminished,
and the need for surface reclamation and revegetation would be reduced.  Also,
the danger of mine subsidence would be significantly reduced.
    The disadvantages inherent in this disposal  alternative include the
following:
    •    The logistics of simultaneous mining and backfilling operations may
         be complex, requiring substantial  above-ground disposal capacity
         before backfilling can commence.
    •    Because of the difficulties in backfilling, coupled with the
         expansion volume caused by mining,  crushing, and retorting and
         difficulty in achieving a high degree of compaction in underground
         mines, perhaps only 60 percent of all processed shale can be
         accommodated.
    •    Release of volatiles from retorted  and backfilled shales may create a
         fire hazard or otherwise endanger workers.
A.3.5  In-Situ Retort Abandonment
    Although in-situ retorting processes do  not involve surface handling and
disposal  of processed shale, the retorted mass underground is waste that must
be managed.   Although spent retorts may appear in some ways to be equivalent
to backfilled wastes in underground mines,  there are important differences.
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With in-situ retorts, it is not possible to control  the amount and placement
of material, and the extent of ground-water seepage  into the retort cannot be
determined or managed until after the retort field is abandoned and
ground-water levels are no longer depressed.
    The primary concerns associated with the abandonment of in-situ retorts
are ground-water infiltration, the retention of heat in the retorted mass, and
the creation of a combustion hazard caused by air leaking into the retort.
A.3.6  Potential Utilization of Wastes
    Retorted oil shale, particularly decarbonized shales, raw shale fines,
spent catalysts, elemental  sulfur, and biological  treatment sludges may have a
limited potential for use on site.  Decarbonized western oil  shales have
cementing properties similar to those of low-grade commercial  cement and may
be used as a cement substitute.  Raw shale rejects and fines from mining and
raw shale preparation could be processed by some types of retorts or formed
into briquettes for processing by other retort facilities.  Some spent
catalysts could be reclaimed and reused in the upgrading process, although no
facilities presently exist to reclaim them.  Some air pollution control
technologies remove elemental  sulfur, which may have a limited market value if
it is not contaminated by impurities.  Biological  treatment sludges may be
useful on site as soil conditioners for revegetation if they do not contain
significant quantities of harmful contaminants.
    Unfortunately, even if each of these wastes is used to the maximum extent
possible, it will not have a significant impact on the total  amount of solid
oil shale waste requiring disposal.
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                           A.4  CONTROL TECHNOLOGIES
    The  following discussion of the control technologies applicable for oil
 shale waste  disposal  is derived from EPA's Pollution Control Technical Manual
 (1983) for TOSCO II oil shale  retorting and summarizes the major control
 technologies for preventing contamination of surface- and ground-water
 supplies by  runoff or leachate, for preventing the generation of dusts, and
 for preventing mass failure of a surface landfill.  Selecting and applying the
 appropriate  control technologies must be based on site- and plant-specific
 features, and controls must be integrated into the overall disposal design.
 The following sections specify control technologies and practices in the
 following areas:
    t    Surface hydrology
    •    Subsurface hydrology
    •    Surface stabilization.
 (Control technologies for oil shale wastes are similar to those mitigative
measures specified in Section 3 of this report.)
A.4.1  Surface Hydrology Control Technologies
    Solid waste management practices in the area of surface hydrology entail
the handling of surface waters on and around the disposal  facility to prevent
surface streams and precipitation from running onto the waste pile and to keep
contaminated waters (runoff, leachate) from infiltrating natural waters.
Surface hydrology control  technologies that are applicable to surface
landfills include run-on diversion systems, runoff collection systems, and
runoff/Ieachate collection ponds.
A.4.2  Subsurface Hydrology Control  Technologies
    The technologies and practices in the area of subsurface hydrology involve
handling ground-water seepage under  landfills to prevent infiltration  of  the

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pile.  These technologies also prevent leachate from the  pile from
contaminating ground water.   These include liners and covers, leachate
collection systems, and ground-water collection systems.
A.4.3  Surface Stabilization Technologies
    Control technologies in the area of surface stabilization address the
disturbed land surface and the problems associated with the disposal  and
reclamation of waste material.  They include dust controls, such as the use of
water and binders and the paving of haul roads, and erosion controls, such as
mulching, revegetation, and designs that provide slope stability.

                               A. 5  CONCLUSIONS

    The oil shale industry will produce unprecedented volumes of solid waste
consisting primarily of retorted oil shales, raw oil shale fines, overburden
and subgrade ore, wastewater, and smaller quantities of known hazardous
wastes.  Although most known hazardous wastes will be disposed of in licensed
disposal or recycling facilities, a majority of the solid wastes produced will
be  disposed of on or close  to  the plant site.   If this large volume of wastes
is  not properly managed, it may produce leachates that could contaminate the
water supplies of millions  of  people, pose an autoignition hazard, and, if a
mass failure occurred, do extensive property damage and threaten lives.
     Control technologies to prevent serious adverse impacts  resulting  from the
disposal of billions of  tons  of oil shale wastes have been proposed, but their
application to oil  shale wastes on the  scale required has  not been
demonstrated.  Further,  for these technologies  to be effective  they must be
incorporated  into  highly technical and  well-integrated disposal designs that
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are both site- and process-specific.  Finally, there has been no experience in
disposing of wastes having the characteristics and volume of those that will
be generated by the oil shale industry.
                                     A-17

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                          REFERENCES FOR APPENDIX A

Heistand, R.N.  1985.   "Estimating Solid Wastes from Oil  Shale Facilities,"
  Proceedings of the 18th Oil  Shale Symposium.  Golden, Colorado: Colorado
  School  of Mines Press.

USEPA.  1984.  Auto-oxidation  Potential  of Raw and Retorted Oil Shale.
  EPA-600/2-84-153.  A.D. Green, Editor, Research Triangle Institute.
  Cincinnati, OH:  U.S.  Environmental  Protection Agency.

USEPA.  1983.  Pollution Control Technical  Manual: TOSCO II Oil Shale
  Retorting with Underground Mining.  EPA-600/8-83-003.  Cincinnati, OH:
  U.S. Environmental Protection Agency.

USEPA.  1980.  Environmental Perspective on the Emerging Oil Shale Industry.
  EPA-600/2-8-205a.  EPA Oil Shale Research group.  E.R.  Bates and T.L. Thoem,
  Editors.  Cincinnati,  OH:   U.S. Environmental Protection Agency.
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APPENDIX B
METHODOLOGY

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                                  APPENDIX B
                                 METHODOLOGY
    The most important empirical  input  for  this  study was derived  from
analyses of sampling results and information  about  active mines  in the
industry segments of concern.   EPA's  sampling methodology  (described more
fully in Section 4.1) involved sampling waste from  at least  one  mine and mill
in various mining region-commodity categories.   These results were
supplemented by sampling results from other studies so  that  EPA's waste
samples would represent the full  range  of wastes and industries  covered by
this study.  EPA's data base containing information about  active mines in the
industry segments of concern is described below. The Agency's methodology
relied on contractor studies, EPA staff analyses, field and  laboratory
results, engineering estimates, and economic  projections and trends.  This
appendix first describes EPA's data base, and then  discusses how the Agency
determined current industry control practices,  estimated the amounts of waste
involved, and extrapolated from waste volumes at individual  mines  to totals
for all mining industry segments.

                             B.I  EPA'S DATA BASE
    EPA compiled a data base of mines in the following  industry  segments as
follows:
    •    Copper—I3 mines;
    •    Gold—11 mines;
    •    Lead--? mines;
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    •    Silver--9 mines;
    •    Uranium~9 mines;
    t    Zinc--7 mines;  and
    •    Phosphate--!8 mines.
    EPA had the following  information  about  these mines:
    •    Name and location;
    •    Amount of product produced  annually;
    •    Amounts and types  of  wastes existing on site and the amounts
         generated annually;
    •    Expected operating life  of  the  mine; and
    •    Dimensions of waste management  areas (e.g., area and perimeter of
         mine waste piles;  depths, surface areas, height and width of berms of
         tailings impoundments; area and perimeter  of heap/dump leach
         operations, etc.).

                   B.2  CURRENT  INDUSTRY BASELINE PRACTICES
                      FOR  THE  USE OF MITIGATIVE MEASURES
    EPA assessed current industry baseline practices for the use  of various
mitigative measures as follows.   The Agency  assumed that mines located in
states having regulations  as  stringent as RCRA requiring mines to have
mitigative measures (e.g.,  ground-water  monitoring, run-on/runoff controls,
liners for tailings ponds,  leachate  collection and  removal, pads  for heap
leach operations) currently used  the required mitigative measures.  In the
case of closure, EPA assessed  whether  mine sites perform some or  all of the
procedures currently required  by  RCRA.   Mines in states that do not have
regulations requiring a certain mitigative measure, or requiring  measures that
are not as stringent as current RCRA requirements,  were assumed not to be
using a measure unless the Agency had  specific knowledge that a measure was
voluntarily being used at  a specific mine in that state.
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    These assumptions were used to estimate the  percentage  of mines  in  various
industry segments where sufficiently stringent mitigative measures are
currently being used (see Section 3 of this report),  and to determine baseline
industry practices for the analysis of the economic costs of various
regulatory scenarios (presented in Section 5 of  this  report).

         8.3  ESTIMATED AMOUNTS OF POTENTIALLY HAZARDOUS MINING WASTE
    EPA estimated the amount of potentially hazardous mining waste by type of
hazard, industry segment, and type of waste (mine waste, tailings, leach
waste) using EPA's waste sampling results (presented in Section 4.1),
site-by-site estimates of the amount of mining waste at operations at  sites
represented in the data base described above, and estimates of the  total
amount of waste generated by each mining industry segment.
    EPA's first step in estimating the annual generation of potentially
hazardous mining waste was to project the number of mines active in  1985, the
amount of waste generated annually, and the amount of waste existing at these
mine  sites in 1985.  Because of the variability in the number of active mines
in recent years, EPA projected past trends to arrive at 1985 estimates  instead
of using historical data from the most recent year for which such data  were
available.  These projections are based on an extrapolation of mineral  produc-
tion  levels and a review of the current operating status of mines,  amounts of
waste generated, and the amount of existing waste at the mines represented in
the EPA data base.   (These projections are presented in Table 4-17  of the
report.)
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    EPA developed estimates of the amounts  of specific  mining  wastes  that  may
be potential  candidates for listing (copper dump  leach  wastes, silver and  gold
heap leach wastes, silver and gold metal  recovery wastes)  based on annual
generation data for each of these wastes.   EPA estimated the amounts  of waste
that are hazardous because of their characteristics  (i.e.,  corrosivity, EP
toxicity, cyanide content, radioactivity,  asbestos content, acid formation
potential) based on the waste sampling and acid formation  potential  data for
waste management operations represented in  EPA's  data base.
    For sampled mines represented in the EPA data base, Table  B-l  shows the
percentage of all U.S.  mining waste management operations  and  of all  wastes
generated by these operations in 1985, by industry segment. As this  table
shows, the data base used by EPA as the basis for this  report  on hazardous
mining waste represents a considerable portion of the  total number of mining
waste operations and of all mining waste generated by  these industry segments:
    t    For mine waste operations, the data base represents between 5 (gold
         industry) and 43 (lead industry) percent of all mine  waste operations
         in each of the respective segments.
    t    For heap/dump leach operations, the data base  represents between  17
         percent  (gold and silver industry segments),  and 32 percent (copper
         industry) of all such operations in each of the respective segments.
    •    For tailings operations, the data base represents between 6 percent
          (gold industry) and 67 percent (copper industry) of all tailings
         operations.
    In all cases, the percentage of waste represented in the data base is
larger than the  percentage of operations.  For example, in the copper industry
segment, 93 percent of all copper tailings waste but 67 percent of all copper
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    Table B-l   Percentage of Mines and Annual  Amount of Waste  Generated  by
                 Sampled Mines Represented In  EPA's  Data Base
Mining
industry
segment
Type of waste
 management
  operation
   Percentage of
  all mining waste
management operations
in industry segment
     (1985)
   Percentage of
annual  mining waste
    generated by
industry segment in
        1985
Copper
Gold
Lead
Mine waste
Dump leach
Tailings

Mine waste
Heap leach
Tailings

Mine waste
Tailings
Phosphate  Mine waste
           Tailings
Silver
Mine waste
Heap leach
Tailings
Uranium    Mine waste
Zinc
Mine waste
Tailings
        32
        32
        67

         5
        17
         6

        43
        50

        21
        21

        10
        17
        11

        14

        33
        33
         73
         38
         93

         35
         53
         34

         56
         60

         45
         34

         57
         53
         73

         26

         69
         70
Source:  Charles River Associates 1985c.
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tailings operations are represented in the data base.   Although  only 26
percent of all of the mine waste generated annually by the uranium segment is
reflected in the data base, the data base generally reflects  at  least half of
the total amount of waste generated by the waste management operations of each
of the respective industry segments.
    To provide estimates of the maximum amount of potentially hazardous waste
generated by the mining industry segments of concern,  EPA assumed that if any
waste sample from a waste management operation failed  a particular hazard
criterion, all of the waste from that operation failed that hazard criterion.
For example, if one of five samples from a tailings pond was  EP  toxic, EPA
assumed that all waste from that tailings operation was EP toxic.   Similarly,
if a sample of pregnant leachate from a dump leach pile had a pH of less than
or equal to 2, waste from the entire dump leach operation was considered
corrosive.
    Table B-2 shows the number of sampled waste management operations
represented in the EPA data base that had at least one sample that was
classified as hazardous.  It also shows how many of these waste  management
operations had at least one sample classified as hazardous because it was EP
toxic, corrosive, radioactive, or had high acid formation potential.
    To estimate the total amount of potentially hazardous waste  generated
annually, EPA extrapolated results from the sampled wastes represented in the
EPA data base to wastes generated by mines included in the data  base and to
wastes generated by mines included in the data base but not sampled by EPA.
    For mines not sampled by EPA but represented in the EPA data base, EPA
estimated the amount of potentially hazardous waste generated annually as
follows.  The annual amount of waste generated at operations  at  these mines,
                                       B-6

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             Table  B-2  Number of Sampled Waste Management Operations Represented in EPA's
                       Data Base with at Least One Sample Classified as Hazardous
Mining
industry
segment
Copper
Mine waste
Dump leach waste
Ta i 1 i ngs
Gold
Mine waste
Heap leach waste
Tailings
Lead
Mine waste
Tai 1 i ngs
Phosphate
Mine waste
Tailings
Silver
Mine waste
Heap leach waste
Tailings
Uranium
Mine waste
Zinc
Mine waste
Tailings
Number of
hazardous
waste
management
operations

7
3
12

6
5
4

3
3

7
7

5
1
5

6

4
4
EP toxic

0
0
0

1
0
2

1
1

0
0

1
0
1

0

0
1
Corrosive

0
1
0

0
0
0

0
0

0
0

0
0
0

0

0
0
High acid
formation
potential

0
0
4

0
0
0

0
0

0
0

0
0
1

0

0
0
Radium-226
greater than
or equal to
5 pCi/g

0
0
0

0
0
0

0
0

5
4

0
0
0

6

0
0
Radium-226
greater than
or equal to
20 pCi/g

0
0
0

0
0
0

0
0

0
1

0
0
0

5

0
0
Source:  EPA sampling results and  EPA data base.

-------
as reported in the data base, was multiplied by the percentage  of sampled
operations reported in the data base as having potentially hazardous waste.
To estimate the amount of potentially hazardous waste generated annually by
those mining operations not represented in the data base,  EPA multiplied the
percentage of waste found to be potentially hazardous at mines  represented in
the data base by the estimated amount of waste generated by the mines that
were not represented in the data base.  Table B-3 illustrates EPA's
methodology for estimating the total amount of potentially hazardous mining
waste generated annually.
    One limitation of this approach is that not all of EPA's sampling data
could be used in the projections of the total amount of potentially hazardous
waste, i.e., only data for waste operations represented in the  EPA data base
were used to estimate projected amounts of waste.  EPA recognizes that use of
this methodology may overlook some data.  For example, if  EPA had sampling
results showing that a sample taken from an operation that was  not represented
in the data base had a hazardous level of one of the properties considered
hazardous in this report, no waste from such an operation  in that industry
segment was classified as having that property.  To illustrate, one sample
taken by EPA at a copper waste operation was EP toxic, but because this
particular operation was not represented in the EPA data base,  no waste from
this industry segment is reported here to be EP toxic.  A  similar problem
occurs with respect to the acid formation potential of wastes in the gold and
silver industry segments; the analysis of minerals for these industry segments
shows that a significant percentage of these tailings have high acid formation
potential.  However, since none of these tailings operations were located at
mines represented in the EPA data base, no tailings from these  segments are
                                       B-8

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            Table B-3  Methodology for Estimating the Total  Amount
           of Potentially Hazardous Mining Waste Generated Annually
Source of data
Method for determining
   amount of waste
  Method for determining
percentage of potentially
     hazardous waste
Sampled sites
represented in
EPA's data base
Site-by-site estimates
for sites represented
in EPA's data base
Sampling results
Non-sampled sites
represented in
EPA's data base

Sites not
sampled and not
represented in
EPA's data base
Site-by-site estimates
for sites represented
in EPA's data base

Total amount of mining
waste based on Bureau
of Mines estimates
minus amount of mining
waste represented in
EPA's data base
Percentage of all sites
found to have hazardous
waste

Extrapolation based on
relative amount of waste
found to be hazardous in
mines represented in
EPA's data base
                                       B-9

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considered potentially hazardous because of their high  acid  formation
potential.  Despite these anomalies,  EPA decided to base  its estimates  on data
from the sampled operations represented in  EPA's data base because  complete
sampling data and estimates of the amount of waste generated annually were
available only for these operations.   In addition, EPA's  data base  only
included information on mines that were active in 1985.
                                       B-10

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        APPENDIX C
     SELECTED CRITERIA
ANALYZED FOR TOXIC EFFECTS

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                                     TABLE C-l


                  A COMPARISON  OF  LEVELS OF EP TOXIC METALS ALLOWED

                        BY  VARIOUS EPA STANDARDS AND CRITERIA
Metals Measured
by RCRA's EP
Toxldty Test
Levels Specified
by 40 CFR 261.24,
Characteristic of
EP Toxldty, mg/1
Maximum Contaminant
Levels Specified
by 40 CFR 141.11,
National Interim
Primary Drinking
Water Standards,
mg/1
Levels Specified by
45 FR 79318, Nov. 20,
1980 Ambient Water
Quality Criteria for
the Protection of
Aquatic Life, mg/1
(24-hour average)
Arsenic
Barium
Cadmium
Chromium (VI)
Lead
Mercury
Selenium
Silver
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
.05
1.0
.01
.05
.05
.002
.01
.05
NA
NA
.000025
.00029
.0038
.0002
0.035
NA
NA - Not Applicable
                                        C-l

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                                     TABLE C-2
                         ARSENIC TOXICITY TO AQUATIC BIOTA
      Toxic
      Effect
Most Sensitive
Organism Tested
  Toxic
Concentration,
   mg/1
Source
    Acute toxicity
                         Cladocera
                         Simocephalus
                          serruiatus
                    0.812   As
                                                      +3
                     US EPA (1980a)
                         Daphm'a magna
                         Minnows
    Chronic toxicity     Algae
                         Daphm'a magna
                    7.4     As
                                                      +5
                    27-45   As
                                                      +3
                                                      +3
                    2.32    As


                    0.91    As+3

                    0.52    Total  As
                     US EPA (1980a)


                     McKee and Wolf

                     (1963)

                     US EPA (1980a)


                     US EPA (1980a)

                     NRCC (1980)
                         Bass
                    7.6
                     McKee and Wolf

                     (1963)
a   The terms LC50 and EC50 refer to contaminant concentrations lethal  (LC50)
    or causing significant toxic effects (EC50)  to 50 percent of a  test
    population within a selected test duration.

b   100% kill in 2 weeks.
                                        C-2

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                                   TABLE C-3

                       CADMIUM  TOXICITY TO AQUATIC BIOTA
Toxic
Effect
Most Sensitive
Organism Tested
Toxic
Concentration
(mg/1 x 10-3)
Source
    Acute toxicity

    (LC50/EC50)a
                         Cladoceran
                         Simocephalus
                          serrulatus
                       3.5-35
                 US EPA (1980b)
                         Striped bass
                          larvae
                       1.0
                 US EPA (1980b)
Chronic toxicity
Diatoms
Asterionell a
 formosa
2.0
US EPA (1980b)
                         Daphnia pulex
                       1.0
                 US EPA (1980b)
                         Rainbow trout

                         Brook trout
                       0.7-130

                       1.0
                 US EPA (1980b)

                 NRCC (1979a)
    The terms LC50 and EC50 refer to contaminant concentrations lethal  (LC50)
    or causing significant toxic effects (EC50)  to 50 percent of a  test
    population within a selected test duration.
                                        C-3

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                                  TABLE C-4

                      CHROMIUM  TOXICITY  TO AQUATIC BIOTA
Toxic
Effect
Acute toxicity
(LC5Q/EC50)a


Most Sensitive
Organism Tested
(freshwater)
Algae
Mate rmil foil
Scud
Daphnia magna
Toxic
Concentration Level
(mg/1 )
Cr VI Cr III
0.01-0.50
9.9
0.067 3.1
6.4 2.0-59
Source
US EPA (1980c)
US EPA (1980c)
US EPA (1980c)
US EPA (1980c)
                                          0.016-0.7    0.33
                                        NRCC  (1980)
                         Fathead minnow   17.6-66      5.0-67      US  EPA  (1980c)
                         Benthic organisms
                             3.0-60     NRCC (1980)
Chronic toxicity
Daphnia magna
0.066      US EPA (1980c)
                         Rainbow trout    0.073-0.265
                                        US EPA (1980c)
                         Fathead minnow
                             1.02
           US EPA (1980c)
    The terms LC50 and EC50 refer to contaminant concentrations lethal  (LC50)
    or causing significant toxic effects (EC50)  to 50 percent of a test
    population within a selected test duration.
                                         C-4

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Chronic toxicity
                                        TABLE C-5

                              LEAD  TOXICITY TO AQUATIC BIOTA
Toxi c
Effect
Acute toxicity
(LC50/EC50)a



Most Sensitive
Organism Tested
Algae

Invertebrates
(scud)
Daphnia magna
Sticklebacks
and trout
Fathead minnow
Toxic
Concentration
Level (mg/1 )
0.3-30
0.5-1.0
0.124
0.45-1.91
0.30
2.4-482
Hardness
(mg/1 Cs
CaC03)


46
45-152
soft
20-360
Source
NRCC (1979)
US EPA (1980d)
US EPA (1980d)
US EPA (1980d)
NRCC (1979)
US EPA (1980d)
Algae


Daphnia magna


Rainbow trout
0.1-2.0
                                               0.012-0.128    52-151
                                               0.019-0.128    19-128
NRCC (1979)


US EPA (1980d)



US EPA (1980d)
a   The terms LC50 and EC50 refer to contaminant concentrations  lethal  (LC50)
    or causing significant toxic effects  (EC50)  to  50  percent of a  test
    population within a selected test duration.
                                        C-5

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                                  TABLE C-6

                      MERCURY TOXICITY TO AQUATIC BIOTA
Toxic Most Sensitive
Effect Organism Tested
Acute toxicity Phytoplankton
Crayf i sh
Rainbow trout
Chronic toxicity Daphnia magna

Toxic
Concentration
mg/la
0.9-60
0.02
155-400
29
1.27-1.87
0.52-1.00
Compound
Mercury
salts
HgCl2
HgCl2
CH3HgCl
HgCl2
CH3HgCl
Source
McKee
(1963)
US EPA
US EPA
US EPA
US EPA

and Wolf
(1980e)
(1980e)
(1980e)
(1980e)
                         Minnow
                                           0.01
                                                            HgN0
            McKee and Wolf

            (1963)
                         Algae
                                           1,030*
HgCl
US EPA (1980e)
a

b
Expressed as mercury, not the compound.

The terms LC50 and EC50 refer to contaminant concentrations  lethal  (LC50)
or causing significant toxic effects (EC50)  to 50  percent  of a  test
population within a selected test duration.
                                        C-6

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                                    TABLE  C-7

                        SELENIUM TOXICITY TO AQUATIC BIOTA
      Toxi c
      Effect
Most Sensitive
Organism Tested
                                Toxi c
                            Concentration
                                 mg/1
                                                  Selenite (+4)    Selenate (+6)
Acute toxicity
Blue-green algae      15-30
Chronic toxicity
Scud


Fathead minnow


Daphnia sp.


Rainbow trout
                      0.34


                      0.62-11.3


                      0.092-0.69


                      0.088
                                      17-40
                                                                  0.76
                                                                  11.8-12.5
Source:  US EPA (1980f)
a   The terms LC50 and EC50 refer to contaminant concentrations lethal  (LC50)
    or causing significant toxic effects (EC50) to 50 percent of a  test
    population within a selected test duration.
                                        C-7

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                                  TABLE C-8


                      CYANIDE TOXICITY TO AQUATIC BIOTA
         Toxic                    Organism                     Toxic
         Effects                  Tested                    Concentration
                                                                mg/1
         Acute toxlclty           Daphnia pulex             0.083

         
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                               TABLE  C-9

                     SUMMARY OF RADIATION EFFECTS
•    Radiation has been demonstrated to be carcinogenic,  mutagenic,  and
     teratogenic (US EPA 1984).

•    Radium poses a danger to human health because of its property as an
     alpha emitter, and because it is concentrated in bone tissue
     following absorption into the body (US EPA 1984).

•    Chromosome aberrations in human lymphocytes following radiation
     exposure by ingestlon of Ra-226 or by inhalation of Rn-222 have been
     demonstrated (US EPA 1984).

•    An increased incidence of leukemia and osteosarcoma has been observed
     in patients who received injections of Ra-224 for medical  purposes
     (US EPA 1984).

•    US EPA (1984) estimated the radionucllde emissions from a reference
     underground uranium mine of assumed typical  dimensions to be 11,500
     Ci/yr as radon-222, 0.02 Ci/yr as uran1um-238,  and 3 x 10'4 Ci/yr
     as thorium-232.  The most important emission was expected to be
     radon-222.  The lifetime human mortality risk factor for persons
     residing within 2000 meters of the sources of these  emissions was
     estimated to be on the order of 10'2.

•    In general, organisms of lower phyla are more resistant to ionizing
     radiation than are higher vertebrates (McKee and Wolf 1963).

•    Radon, a decay product of radium, poses a danger to  human health
     because it is an inert (noble) gas that diffuses into buildings where
     it builds up (concentrates) in the indoor air.   The  decay products  of
     radon may be inhaled and retained in the lung,  greatly increasing the
     risk of lung cancer.
                                    C-9

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                         TABLE C-10

                EFFECTS OF ASBESTOS EXPOSURE
Chrysotile and amphibole fibers are toxic to the bacteria E.  cpli  and
£. aureus (NRCC 1980).                                    ~

Mussels and freshwater fish have been shown to take up asbestos
fibers from water and store these in muscle tissue, but the effect on
mortality rates was not determined (NRCC 1980, US EPA 1980h).

The ambient water quality criteria for the protection of human health
developed by US EPA (1980h), assuming the ingestion of 2 liters per
day of contaminated water, are 300,000 fibers per liter (f/1), 30,00
f/1. and 3,000 f/1 for a projected cancer incidence rate of 10-5,
10~6, and 10~7, respectively.

Cytotoxicity of intestinal tissue has been observed following
ingestion of asbestos fibers by rats (US EPA 1980h).

Asbestosis, the noncancerous disease resulting from inhalation of
asbestos fibers, is a chronic, progressive pneumoconiosis (US EPA
1980).  The lowest cumulative asbestos respiratory exposure level  at
which severe forms of asbestosis have been detected is 25 fibers -
year/cm3 (US EPA 1980i).

The risk of asbestosis rises with increasing asbestos exposure; the
dose-response curve for asbestosis mortality can be qualitatively
described as linear (US EPA 1980i).

Several studies of worker exposure to asbestos have linked asbestos
respiratory exposure to increased rates of pleural and peritoneal
mesothelioma; cancer of the lung, stomach, esophagus, pharynx,
colon-rectum, skin, and kidney; leukemia; and neoplasms of the
digestive organs and peritoneum (US EPA 1980h).

Several dose-response relationships have been established for
asbestos exposure and human mortality from various diseases.   Over
50% of the deaths among a group of 17,800 asbestos insulation workers
exposed at levels of 10 to 20 f/cm3 and studied over a 10-year
period could be attributed to asbestos-related diseases.  Chronic
exposure at this level was shown to result in death rates from
mesotheliomas from 1.3 to 4 times those of the general U.S.
population of the same age and sex (US EPA 1980h).

Among male asbestos plant workers, respiratory exposure for less than
2 years at asbestos levels of 20 or more f/cm3 resulted in
significantly increased rates of cancer deaths.  Females exposed for
the same duration but at the lower levels of 5 to 10 f/cm3
exhibited significant increases in the rates of death from cancers of
the lung and pleura (US EPA 1980h).
                               C-10

-------
0    Excess malignant respiratory disease has  been  reported  among  asbestos
     mine workers exposed to an average air concentration  of 0.25  f/cm3
     (US EPA 1980h).

•    Estimates of human exposure to asbestos for persons living within 30
     km of asbestos mines or mills are 0.4 f/cm3 compared  with the
     average ambient urban exposure of 5 x 10~3 f/cm3  (electron
     microscope visible fibers) (Suta  and Levine 1979,  as  cited by Colgley
     et al. 1981).
                                   C-ll

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                                  TABLE C-ll

                THE SUMMARY OF  EFFECTS  OF DECREASING pH ON FISH
       PH Range                                  Effects
       9.0 - 6.5          Harmless to most fish;  toxicity  of other  poisons  may
                          be affected by changes  within  this range.

       6.5 - 6.0          Unlikely to be harmful  to  fish unless  free  carbon
                          dioxide  is  present  in excess of  100 mg/1; egg
                          hatchability and growth of alevins of  brook  trout
                          significantly lower at  all  pH  levels below  6.5.

       6.0 - 5.5          Egg production and  hatchability  of fathead  minnow
                          reduced; reduced egg production  and larval  survival
                          of flagfish;  roach  reproduction  may be affected;
                          unlikely to be harmful  to  fish unless  free  carbon
                          dioxide  is  present  in excess of  20 mg/1.

       5.5 - 5.0          Increased hatching  time of Atlantic salmon  eggs;
                          mortality of brown  trout eggs  is high;  threshold  of
                          tissue damage for finger!ing brown trout; growth  of
                          flagfish larvae may be  reduced;  roach  reproduction
                          reduced  at  least 50 percent; may be harmful  to
                          non-acclimated salmonids if the  calcium,  sodium,  and
                          chloride concentrations or the temperature  is low.

       5.0 - 4.5          Harmful  to  eggs and alevins or larvae  of  most
                          salmonids and white sucker, and  to adults
                          particularly in soft water containing  low
                          concentrations of calcium,  sodium,  and chloride;  may
                          be harmful  to carp; roach  recruitment  impaired; fish
                          mortalities can be  expected.

       4.5 - 4.0          Expected to be harmful  to  salmonids at all  stages;
                          likely to be  harmful to tench, bream,  roach,
                          goldfish, carp, fathead minnow,  bluegill;
                          acclimation may increase resistance to  these levels.

       4.0 - 3.5          Lethal to most fish over extended periods.

       3.5 and below      Acutely  lethal  to fish.
Source:   Potter et al.   1982
                                        C-12

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                                  TABLE C-12

          SUMMARY OF DAMAGES TO AQUATIC ECOSYSTEMS WITH DECREASING pH



         pH Range                                        Effects
         8.0 - 6.0           Long-term changes of less than 0.5 pH units are
                             likely to alter the biotic composition of
                             freshwaters to some degree.  The significance of
                             these slight changes is, however, not great.

                             A decrease of 0.5 to 1.0 pH units in the range of
                             8.0 to 6.0 may cause detectable alterations in
                             conmunity composition.  Productivity of competing
                             organisms will vary.  Some species will  be
                             eliminated.

         6.0 - 5.5           Decreasing pH will cause a reduction in species
                             numbers and, among remaining species, significant
                             alterations in ability to withstand stress.
                             Reproduction of some salamander species is
                             impaired.

         5.5 - 5.0           Many species will  be eliminated, and species
                             numbers and diversity will  be reduced.
                             Crustacean zooplankton, phy to plank ton,
                             mamphipods, most mayfly species, and some
                             stonefly species will begin to drop out.   In
                             contrast, several  pH-tolerant invertebrates will
                             become abundant, especially the air-breathing
                             forms (e.g., Gyrinidae, Notonectidae, Corixidae),
                             those with tough cuticles that prevent ion losses
                             (e.g., Sialis lutaris), and some forms that live
                             within the sediments (01igochaeta, Chromomidae,
                             and Tubificidae).   Overall, invertebrate  biomass
                             will be greatly reduced.

         5.0 - 4.5           Decomposition of organic  detritus will  be
                             severely impaired.  Autochthonous and
                             allochthonous debris will  accumulate rapidly.
                             Most fish species  are eliminated.

         4.5                 All  of the above changes  will  be greatly
                             exacerbated, and most fish  will  be eliminated.
Source:  Potter et al.   1982
                                        C-13

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                     REFERENCES FOR APPENDIX C
Colgley, D., Krusell,  N., Mclnnes, R.,  Bell,  1981.   GCA Corporation.
    Lifecycle of asbestos in commercial  and industrial  use including
    estimates of releases to air, water and land.   Draft Report.
    Washington, DC:  U.S. Environmental  Protection  Agency.  Contract
    68-02-2607/68-02-3169.

McKee, J.E., Wolf, H.W.   1963.   Water Quality Criteria.  Sacramento,
    CA:  The Resources Agency of California,  State  Water Quality
    Control Board.  Publication No. 3-A.

NRCC.  National Research Council Canada.  1979a.  Effects of Cadmium
    in the Canadian Environment.  Ottawa, Canada:   NRCC No. 16743.

NRCC.  National Research Council Canada.  1979.b.   Effects of Lead
    in the Environment-!978.  Ottawa,  Canada:  NRCC No. 16736.

NRCC.  National Research Council Canada.  1980.   Executive reports.
    Effects of Chromium,  Alkali Hal ides, Arsenic,  Asbestos, Mercury,
    Cadmium in the Canadian Environment.  Ottawa,  Canada:  NRCC No.
    17585.

Potter, W., Chang Ben K-Y, Adler, D.  1982.  The Effects of Air
    Pollution and Acid Rain on Fish, Wildlife, and  Their Habitats.
    Rivers and Streams.   Fish and Wildlife Service, U.S. Department
    of Interior, FWS 14-16-0009-80-085.

USEPA.  1984.  Radionuclides; Background Information; Document for
    Final Rules, Vol.  1.   Washington,  DC:  EPA-560/12-80-003.

USEPA.  1980.a.  Ambient Water Quality Criteria for Arsenic.  U.S.
    Environmental Protection Agency.  Washington,  D.C.
    EPA-440/5-80-021.

USEPA.  1980.b.  Ambient Water Quality Criteria for Cadmium.  U.S.
    Environmental Protection Agency.  Washington,  D.C.
    EPA-440/5-80-025.

USEPA.  1980.c.  Ambient Water Quality Criteria for Chromium.  U.S.
    Environmental Protection Agency.  Washington,  D.C.
    EPA-440/5-80-035.

USEPA.  1980.d.  Ambient Water Quality Criteria for Lead.  U.S.
    Environmental Protection Agency.  Washington,  D.C.
    EPA-440/5-80-057.

USEPA.  1980.e.  Ambient Water Quality Criteria for Mercury.  U.S.
    Environmental Protection Agency.  Washington,  D.C.
    EPA-440/5-80-058.
                                       C-14

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USEPA.   1980.f.   Ambient Water Quality Criteria for Selenium.   U.S.
    Environmental  Protection Agency.   Washington, D.C.
    EPA-440/5-80-070.

USEPA.   1980.g.   Ambient Water Quality Criteria for Cyanides.   U.S.
    Environmental  Protection Agency.   Washington, D.C.
    EPA-440/5-80-037.

USEPA.   1980h.  Ambient Water quality criteria for asbestos.
    U.S. Environmental Protection Agency.   Washington,  D.C.:
    EPA-440/5-80-022.

USEPA.   1980i.  Support document for proposed rule on friable
    asbestos-containing materials in school  buildings;  health
    effects and magnitude of exposure.  Washington, DC:
    EPA-560/12-80-003.
                                       C-15

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APPENDIX D
 GLOSSARY

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                                   GLOSSARY


ACID DRAINAGE - drainage from mines and mining wastes that has a pH ranging
    from below 2.0 to 4.5; the acidity is caused by the oxidation of sulfides
    exposed during mining, which produces sulfuric acid and sulfate salts.
    The acid dissolves minerals in the rocks, further degrading the quality of
    the drainage water.

ACID FORMATION POTENTIAL - the propensity of exposure and subsequent oxidation
    of naturally ocurring metal sulfides (especially iron pyrite) in ores and
    mining waste to produce acid.  An acid environment greatly increases the
    leaching and mobility of toxic waste constituents, including heavy metals.

WAL6AMATION - a method of extracting a precious metal from its ore by
    alloying it with mercury.

AQUIFER - a water-bearing bed or structure of permeable rock, sand, or gravel
    capable of yielding quantities of water to wells or springs.

BACKFILLING - a waste management practice for mining waste in which the waste
    material is immediately used for refilling previously excavated areas.

BELOW-GRADE DISPOSAL - a disposal  method for tailings in which the
    tailings are placed in an excavated pit so that at closure the entire
    deposit is below the level of the original  land surface.

BENEFICIATION - the treatment of ore to concentrate its valuable constituents.

BERM - a ledge or shoulder, as along the edge of a paved road.

BIOLOGICAL ACID LEACHING - a waste pretreatment method that may be a feasible
    substitute for certain current dump leaching practices.   The biological
    acid leaching process converts sulfur in the ore to elemental  sulfur,
    which is potentially saleable and is less hazardous to the environment
    than sulfuric acid, the usual  dump leach waste constituent.

BLOCK-CAVING - a large production  low-cost method of mining,  in which  the
    greater part of the bottom area of a block  of ore  is undercut,  the
    supporting pillars are blasted away, and the ore caves downward and is
    removed.  As the block  caves and settles,  the cover follows.

COLLECTION TRENCH - a mitigative system used to prevent seepage from reaching
    ground waters or surface waters.   Also  effective in protecting the
    integrity of a tailings pond dam.

COLLOID - an extremely fine-grained material  of particles  having diameters of
    TeTs than 0.00024 mm that can  be easily  suspended  in solution.
                                     D-l

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CONTAINMENT SYSTEMS - a.  mitigative measures  that  prevent  leachate  from
    entering the ground water and posing  a  threat  to  human health and  the
    environment.   These measures  include: liners,  cutoff walls,  interceptor
    wells, hydraulic barriers,  and grouting;   b. a type of run-on/runoff
    control  that collects onsite  stormwater or dike seepage in holding or
    evaporation ponds for the treatment necessary  for final  disposal or to
    prepare the waste for recycling.

CUT-AND-FILL UNDERGROUND MINING (cut-and-fill  stoping) - a mining method  in
    which the ore is excavated  by making  successive flat or inclined slices,
    working upward from the level.  After each slice  is blasted  down,  all
    broken ore is removed and the stope is  filled  with waste to  within a  few
    feet of the back before the next  slice  is  taken out.   During the process,
    there is just enough room between the top  of the  waste pile  and the back
    of the stope to provide working  space.

CUTOFF WALLS - a mitigative measure  employed  as a  containment system to
    prevent seepage from contaminating ground  water.   Walls, collars,  or  other
    structures reduce percolation of  water  along smooth surfaces or through
    porous strata.

DEWATERING - removing water from a mine by  pumping or drainage.  Water produced
    from mine dewatering may be discharged  directly or indirectly to a surface
    stream, used in the milling process in  make-up water,  pumped to a  tailings
    pond, or used on site for dust control, cooling,  or drilling fluid.

DIKE STABILIZATION - a mitigative measure that controls liquids. The
    structural integrity of the dike  or dikes  constructed  to confine the
    wastes is considered, an assessment is  made of the ability of the  dike
    system to withstand additional loads, including the weight of several
    layers of a capping system, and  construction equipment is used  to  place
    and compact the final cover.

DIVERSION METHODS - a type of run-on/runoff control that prevents offsite
    water from entering a waste management  site and causing erosion and
    flooding.

DREDGING - the various processes  by  which large floating machines  (dredges)
    scoop up earth material at  the bottom of  a body of water, raise it to the
    surface, and discharge it into a  pipeline  or barge, return it into a
    pipeline or barge, or return  it  to the  water body after the  removal of  ore
    minerals.

DUMP LEACHING - a beneficiation process in  which sub-ore-grade material is
    leached by acid to recover  copper.  The material  to be leached  is  placed
    directly on the ground and  the leaching may continue for years  or  decades.

DUMP LEACH WASTE - a large-volume waste that  results  from  the dump  leaching
    process.
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ELECTROSTATIC SEPARATION - a process of ore concentration used to separate
    minerals on the basis of their conductivity.   The ore is charged with high
    voltages and the charged particles are dropped onto a conductive rotating
    drum.  The conductive particles discharge rapidly, are thrown off,  and are
    then collected.  The nonconductive particles  keep their charge,  adhere to
    the drum by electrostatic attraction, and are removed separately.

ELECTROWINNING - recovery of a metal from an ore  by means of electrochemical
    processes.

FINAL COVER - a mitigative measure which, when properly installed over  the
    exposed surfaces of a waste impoundment, ensures control  of erosion,
    fugitive dust, and surface water infiltration; promotes proper drainage;
    and creates an area that is esthetically pleasing and amenable to
    alternative level uses.

FRESHWATER INJECTION WELLS (freshwater input wells) - a mitigative measure
    that contains seepage, in which freshwater (water with less than 0.2
    percent salinity) is pumped into wells for pressure maintenance. Used in
    the formation of a hydraulic barrier, and most effective under conditions
    of subsurface homogeneity.

FROTH FLOTATION - often referred to simply as flotation, this process is  the
    separation of finely crushed minerals from one another by causing some to
    float in a froth and others to sink.   Oils and various chemicals are  used
    to activate, make flotable, or depress the minerals.

GANGUE - the valueless rock or mineral aggregates in an ore, that part  of an
    ore that is not economically desirable but cannot be avoided in  mining.
    It is separated from the ore minerals during  concentration and is
    generated as tailings.

GEOCHEMICAL PROCESSES - processes that control the rate of movement  of
    contaminants from the soluble liquid  phase (seepage) to the solid phase
    (soil , geologic material) of the system.

GRAVITY CONCENTRATION - the separation of minerals by a concentration method
    operating by virtue of the differences in density of various minerals;  the
    greater the difference in density between two minerals, the more easily
    they can be separated by gravity methods.

GROUND WATER - water found underground in porous  rock strata and soils.

GROUT CURTAIN - a mitigative system used  to prevent ground-water contamination.
    Seepage losses are controlled by grouting the foundation rock of a  waste
    disposal  facility.  Used when waste presents  a serious pollution hazard to
    groundwater.

HALF-LIFE - the time required for a radioactive substance to lose 50 percent
    of its activity by decay.  Each radionuclide  has a unique half-life.
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HAZARDOUS WASTE - a solid waste,  or  combination  of  solid  wastes,  which,  because
    of its quantity, concentration,  or physical, chemical,  or  infectious
    characteristics, may (1)  cause,  or significantly  contribute to,  an
    increase in mortality or  an increase  in  serious irreversible,  or
    incapacitating reversible illness; or (2)  pose  a  substantial  present or
    potential  hazard to human health or the  environment when improperly
    treated, stored, transported,  disposed of, or otherwise managed.

HEAP LEACHING - an extraction process in  which ore  is leached  by  cyanide to
    recover gold and silver,  or by other  reagents to  recover uranium.  The
    material to be leached is placed on a pad; the  volume of material  leached
    is smaller than in the dump leaching  process.   Leaching continues  for
    months.

HEAP LEACH WASTE - a large-volume waste generated by  the  heap  leaching process.

HYDRAULIC BARRIERS - a mitigative measure used to prevent ground-water contami-
    nation.  A barrier used in conjunction with  interceptor walls  is
    established downgradient  of an embankment  to prevent  seepage  losses
    through the foundation of a waste disposal facility.

HYDRAULIC HEAD - the height of a  free surface of a  body of  water  above a given
    subsurface point.

HYDROGEOLOGIC EVALUATION - a  detection and inspection measure  used in  combi-
    nation with ground-water  monitoring at a waste  disposal or tailings  pond
    facility to identify potential pathways  of leakage and  contamination by
    ground water; determine whether  contamination of  ground-water  has occurred
    and,  if so, the extent of contamination.   If contamination has occurred,
    this  evaluation is used to generate data about  factors  such as the size,
    depth, and rate of flow of a  contaminated  plume to facilitate
    implementation of a mitigative strategy.

HYDROLOGIC PROCESSES - geologic phenomena that determine  the critical  flow
    paths and velocities that control  the leachate  seepage  from a  waste
    disposal area.

INTERCEPTOR WALLS - a mitigative  measure  used  to prevent  ground-water
    contamination.  Interceptor walls installed  at  points that intersect the
    plumes of contaminated seepage control seepage  losses through  the
    foundation of a waste disposal facility.

ISOTOPE (nuclide) - any of two or more species of atoms of  a chemical element
    with  the same atomic number and  position in  the periodic table and nearly
    identical  chemical  behavior,  but with differing atomic  mass or mass  number
    and different physical  properties.

LEACHATE  - 1) the beneficiation solution  (pregnant  liquor)  obtained  from heap
    leach and dump leach processes;  2) the liquid resulting from water
    percolating through, and  dissolving materials in, waste.
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LEACHATE COLLECTION, REMOVAL, AND TREATMENT SYSTEMS - mitigative measures
    used on lined waste piles to prevent the leacnate from building up above
    the liner.  Leachate collection prevents the buildup of water over the
    liner and thus prevents deformation of piles and overflow of the
    containment system.  Collected waste is treated and disposed of by
    treatment methods such as neutralization, precipitation, and flotation.

LINERS - a mitigative measure used to prevent ground-water contamination in
    wn~ich synthetic natural clay, or bentonite materials that are compatible
    with the wastes are used to seal the bottom of tailings ponds and waste
    pi 1 es.

MAGNETIC SCAVENGING (MAGNETIC SEPARATION) - the separation of magnetic
    materials from nonmagnetic materials, using a magnet.   Magnetic scavenging
    is an important process in the beneficiation of iron ores in which the
    magnetic mineral is separated from nonmagnetic material; for example,
    roasted pyrite from sphalenite.

MILL TAILINGS - the waste rock (gangue) discarded after ore milling.   See
    tailings.

MINE WASTE - a large-volume waste consisting of the soil  or rock generated by
    mining operations during the process of gaining access to an ore  or
    mineral  body.  The waste includes the overburden from surface mines,
    underground mine development rock, and other waste rock.

MINE WASTE PILES - a waste management practice used for mine waste or the area
    where mine waste or spoil  materials are disposed of or piled.

MINE WATER - a large-volume waste consisting of the water that infiltrates a
    mine and is subsequently removed to facilitate mining.

MINE WATER PONDS - impoundments used to hold mine water prior to evaporation,
    recycling, or discharge.

NPDES - National  Pollutant Discharge Elimination System,  EPA's system of
    permits  for controlling the discharge of water pollutants to surface
    waters.

OPEN-CAST MINING - a surface mining method in which the overburden is removed
    and minerals are extracted in a series of regular slices called cuts and
    the overburden of each subsequent cut is replaced into the void of the
    preceding  cut.  This method is primarily used in the  mining  of coal.

OPEN-CUT MINING (OPEN-PIT MINING) - a surface mining method involving the
    removal  of the overburden, and breaking and loading the mineral,  as
    happens  in a stone quarry.  This method is primarily used for
    metalliferous ores such as iron and copper.
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OPEN-STOPE MINING - a method of stoping in  which  no regular  artificial  method
    of support is employed,  although  occasional  props  or cribs  may be used to
    hold local patches of insecure ground.   The walls  and roof  are self-
    supporting, and open stopes can be used only  where the ore  and wall  rocks
    are firm.  This method is usually confined to small  ore  bodies because the
    length of unsupported span that will  stand without breaking is limited.

PLACER MINING - a form of mining in which a gravel  deposit containing gold is
washed to extract the gold.

POND-SEDIMENT REMOVAL - a mitigative  measure used to remove  the sediment that
    builds up in wastewater  retention ponds.

OVERBURDEN - consolidated or unconsolidated material  overlying  the mined area.

PICOCURIE - a unit of radioactivity defined as 0.037 disintegrations  per
    second, and abbreviated  as pCi.

POTENTIALLY HAZARDOUS WASTES - wastes that  have  characteristics that may pose
    a threat to human health or the environment.

PRECIPITATION - 1) a process of separating  mineral  constituents from a solution
    by means of a reagent; 2) rain, snow, or hail.

QUARRYING - a method of surface mining used for  stone or mineral deposits.
    This method is primarily used for non-metallic materials such as  limestone
    and building stone.

RCRA - Resource Conservation and Recovery Act, the legislation  under which
    EPA regulates hazardous  waste.

RCRA SUBTITLE C CHARACTERISTICS - criteria  used  to determine if an unlisted
    waste is a hazardous waste under  Subtitle C  of RCRA:

         - corrosivity - a solid waste is considered corrosive  if it is
              aqueous and has a pH less than or  equal  to 2 or greater than or
              equal to 12.5  or if it is a liquid and corrodes steel at a rate
              greater than 6.35 mm per year at a test temperature of 55°C

         - EP toxicity - a solid waste exhibits  the characteristic of EP
               (extraction procedure)  toxicity if, after extraction by a
              prescribed EPA method,  it yields a metal concentration 100 times
              the acceptable concentration  limits set forth  in  EPA's Primary
              Drinking Water Standards.

         - ignitability - a solid waste exhibits the characteristic of
              ignitability if it is a liquid with a flashpoint  below 60°C or a
              non-liquid capable of causing fires at standard temperature and
               pressure.
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          -  reactivity  -  a  waste  Is  considered  reactive  If  It  reacts  violently,
               forms  potentially  explosive  mixtures,  or  generates  toxic  fumes
               when mixed with  water,  or  if it  is normally  unstable and
               undergoes  violent  change without deteriorating.

 RADIONUCLIDE  (radioisotope)  -  an unstable  isotope of an element that decays
     or disintegrates spontaneously, emitting radiation.

 RADIUM-226  -  a radioactive daughter product of the decay of uranium-238.
     Radium  is present  in all uranium-bearing ores; it has  a half-life of 1620
    years.

 RETORTING OF  OIL SHALE - the heat-dependent distillation process  in  which oil
     Is extracted from  the  raw  shale.

 REVEGETATION  - the third step  in the  final  cover procedure of a reclamation
    and closure system,  revegetation  is used during the active operation of
     the tailings pond  and  at closure.  Regrading, contouring, and revegetation
    of tailings areas  prevent  erosion, stream  turbidity and sedimentation, and
     provi de dust control.

 RIP-RAP - a foundation or  sustaining wall  of stones thrown together
     irregularly.

 ROOM-AND-PILLAR MINING - a method of mining used to mine coal  and metal, in
    which the  roof is supported  by pillars left at regular intervals.

 RUN-ON/RUNOFF  CONTROL -  a mitigative measure used to control  liquids and
    involving  diversion methods and runoff acceleration practices.

 RUNOFF ACCELERATION PRACTICES  -  a type of run-on/runoff control  that reduces
    ground-water pollution by  preventing the ponding or percolation of
    rainfall on wastepiles.

 SECURITY SYSTEMS - a mitigative measure used for the security of control
    systems and protection of the public that may include the posting of "No
    Trespassing" signs, locked gates,  security guards,  and fencing.

 SEEPAGE COLLECTION SYSTEMS - mitigative measures that control  seepage by (1)
    restricting seepage outflow,  or (2)  using drainage methods to  discharge
    the seepage without the danger of  piping of material  or buildup  of a high
    ground-water elevation within the  embankment.

SHEEPFOOT ROLLER - an earth compaction machine  with  a roller  of  "feet" used  to
    compact by striking the earth repeatedly.

SLIMES - a material of  extremely  fine  particles encountered in the treatment
    of ore.   Primary  slimes are extremely fine  particles derived from ore,
    associated rock,  or clay.   They  are  usually found  in old dumps and in ore
    deposits that  have  been exposed  to climatic action;  they  include  clay,
    alumina, hydrated iron, near-colloidal  common earths, and  weathered  feld-
    spars.   Secondary slimes  are  very  finely ground minerals from  the true ore.
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SLURRY WALLS - a seepage collection/blockage mitigative system.   Seepage
    losses are controlled by grouting the walls of a waste disposal  facility
    with a slurry compound of cement and water.  This system is  used when
    waste presents a serious pollution hazard to ground water.

SMCRA - Surface Mining Control and Reclamation Act.

SMELTER SLAG - the rough vesicular 1 aval ike waste remaining after the
     processing of ore and minerals.

SOLVENT EXTRACTION - a method of separating one or more substances from a
    mixture, by treating a solution of the mixture with a solvent that will
    dissolve the required substance or substances, leaving the others.

SQUARE-SET STORING - a method of stoping in which the walls and  back of the
    excavation are supported by regular framed timbers forming a skeleton that
    encloses a series of connected, hollow, rectangular prisms in the space
    formerly occupied by the excavated ore and providing continuous lines of
    support in three directions.  The ore is excavated in small, rectangular
    blocks just large enough to provide room for standing a set of timber.
    This method is most applicable in mining deposits in which the ore is
    structurally weak.  The primary function of the square sets is to furnish
    temporary support only for loose fragments of rock and to offer a
    passageway to the working face.  Permanent support for the stope walls is
    supplied by filling the sets with broken waste rock.

STOPE - an excavation where the ore is drilled, blasted, and removed by
    gravity through chutes to ore cars on the haulage level below.  Stopes
    require timbered openings (manways) to provide access for men and
    materials.  Raises connect a stope to the level above and are used for
    ventilation, convenience in getting men and materials into the stope, and
    admitting backfill.

STRIP MINING - mines from which minerals that lie near the surface
    are extracted using a cutting technique by which long, shallow cuts are
    made  in the ground after the removal of overburden.  These mines are
    primarily used in the mining of coal.

SURFACE WATER - water that rests on the surface of the rocky crust of thex
    earth.

SURFACE WATER DIVERSION - this control system consists of canals, channels,
    or pipes that totally or partially surround a waste management site or
    leaching operation and divert surface water flow around it and back into
    the natural system channel downgradient of the waste area.  The most
    important functions of diversion ditches are  to reduce the volume of water
    contacting  the waste  (run-on) and to minimize downstream environmental
    damage  (runoff).
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TAILINGS - a large-volume waste consisting of the materials remaining after
    th~e"~va1 uable constituents (also termed values) of the ore have been
    removed by physical or chemical beneficiation, including crushing,
    grinding, sorting, and concentration by a variety of methods.

TAILINGS PONDS - a waste management practice for tailings consisting of
    an area closed at the lower end by a constraining wall  or dam to which
    mill tailings are run.  The size and design of the ponds vary widely by
    industry segment and location.

TAILINGS SLURRY - the method used to transport tailings from the mill.  The
    slurry consists of 50 to 70 percent (by weight) liquid mill effluent and
    30 to 50 percent solids (clay, silt, and sand-sized particles).

THICKENED DISCHARGE - a disposal method for tailings in which the tailings
    slurry is partially dewatered and discharged from a single point.  The
    result is a gently sloping, cone-shaped deposit.

UMTRCA - Uranium Mill Tailings Radiation Control Act.

UNDERGROUND MINE DEVELOPMENT ROCK - rock removed while sinking shafts or
    accessing or exploiting the ore body.

VALUE - the valuable constituents of an ore.

WASTE ROCK - rock that must be broken and disposed of to gain access to and
    excavate the ore; valueless rock that must be removed or set aside before
    the milling process.

WASTE STABILIZATION - a mitigative measure used to control  liquids; proper
    consolidation and stabilization of the waste are necessary to ensure
    long-term support for the final cover.  The first step in stabilization of
    tailings is dewatering the wastes.  The wastes are then tested to
    determine the amount of settlement of the wastes due to compression from
    the final cover system and the construction used in applying the cover
    system components.

WASTE UTILIZATION - a current mining waste disposal practice that involves:
    (1) the extraction of economically valuable amounts of metals or minerals
    in the waste, and (2) the use of this waste material for productive
    purposes.

WASTEWATER TREATMENT - a mitigative measure used to control liquids.  The
    wastewater that remains onsite after active mining and milling processes
    is treated and then either discharged or transported to a licensed
    disposal site.
• U S GOVERNMENT PRINTING OFFICE  1986 618-851/40390
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