PB94-964421
EPA/ROD/R08-94/102
March 1995
EPA Superfund
Record of Decision:
Silver Bow Creek/Butte Area
(O.U. 3), SUver Bow/Deer Lodge, MT
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RECORD OF DECISION
BUTIE MINE FLOODING OPERABLE UNIT
SILVER BOW CREEK/BUTIE AREA NPL SITE
BUTIE, MONT ANA
September 29, 1994
United States Environmental Protection Agency
Region VIII - Montana Office
Federal Building, 301 South Park, Drawer 10096
Helena, MT 59626..()()96 .
(Lead Agency)
Montana Department of Health and Environmental Sciences
Solid and Hazardous Waste Bureau
. 2209 Phoenix A venue
P.O. Box 200901
Helena, MT 59620-090 I
(Support Agency)
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RECORD OF DECISION
BUITE MINE FLOODING OPERABLE UNIT
SILVER BOW CREEKIBUITE AREA NPL SITE
BUTTE, MONTANA
September 29, 1994
United States Environmental Protection Agency
Region VIII - Montana Office
Federal Building, 301 South Park, Drawer 10096
Helena, MT 59626-0096 .
(Lead Agency)
Montana Department of Health and Environmental Sciences
Solid and Hazardous Waste Bureau
. 2209 Phoenix A venue
P.O. Box 200901
Helena, MT 59620-0901
(Support Agency)
VOLUME I OF ill
4400900
1111111
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RECORD OF DECISION COMPONENT LOCATOR PAGE
(Components in bold are in this volume)
VOLUME I of ill
Record of Decision
. Appendix 1 - ARARs
Appendix 2 - Technical Impracticability Evaluation
Appendix 3 - Monitoring Program
VOLUME n of m
Appendix 4 - Responsiveness Summary (Agencies Responses to Comments)
Attachment 1 - Identification of Comments Received
VOLUME m of III
Appendix 4 - Responsiveness Summary
Attachment 2 - Transcript of Public Hearing
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RECORD OF DECISION
MINE FLOODING OPERABLE UNIT
SIL VER BOW CREEK/BUTrE AREA SITE
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) and the Montana Depanment of Health
and EnvironrT'~ntal Sciences (MDHES) present the Record of Decision (ROD) for the Mine
Flooding Operable Unit (OU) of the Silver Bow Creek/Butte Area National Priorities List
(NPL) site. The ROD is based on the Administrative Record for the site, the Remedial
Investigation/Feasibility Study (RI/FS), the Proposed Plan, the public comments received
(including those from the potentially responsible panies (pRPs) and local government), and
EPA and MDHES response to these comments. The ROD presents a brief outline of the
RI/F~, actual and potential risks to human health and the environment, andthe selected
remedy. EP A guidance was used in preparation of the ROD1. The ROD has the following
three purposes:
1. To certify that the remedy selection process was carried out in accordance with
the requirements of the Comprehensive Environmental, Response,
Compensation and Liability Act (CERCLA) 42 U.S.C. ~~ 9601 er seq., as
amended by the Superfund Amendments and Reauthorization Act (SARA), and
to the extent practicable, the National Contingency Plan (NCP);
2.
To outline the. engineering components and remediation requirements of the
selected remedy; and
3.
To provide the public with a consolidated source of information about the site
history, characteristics, and risk posed by the conditions at the Mine Flooding
au, as well as a summary of the cleanup alternatives considered, their
evaluation, and the rationale behind the selected remedy.
1 Guidance on Preparing Superfund Decision Documents: The Proposed Plan, the Record of Decision.
Explanation of Significant Differences, the Record of Decision Amendment, Interim Final, EPAlS40/G.89/007, July
1989
1
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The ROD is organized into three distinct sections:
1.
The Declaration functions as an abstract for the key information contained in
the ROD and is the section of the ROD signed by the EP A Regional
Administrator and the MDHES Director;
2.
The Decision Summary provides an overview of the site characteristics, the
alternatives evaluated, and the analyses of those options. The Decision
Summary also identifies the selected remedy and explains how the remedy
fulfills statutory requirements. The Decision Summary includes, as an
Appendix, the final applicable or relevant and appropriate requirements
(ARARs) for the site and waivers of any of these ARARs; and "
3.
The Responsiveness Summary addresses public comments received on the
Proposed Plan, the RIfFS, and other information in the Administrative Record,
which were not responded to previously.
".
2
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Silver Bow Cree~/Butte Area NPL site
Butte, Montana
Butte Mine Flooding Operable Unit
STATEMENT OF BASIS AND PURPOSE
This decision document prese~ts the selected remedy for the Butte
Mine Flooding Operable Unit (BMFOU) of the silver Bow Creek/Butte
Area site in Butte, Montana. The selected remedial action was
chosen by EPA, with the concurrence of the Montana Department of
Health and~Environmental Sciences (the State), in accordance with
the requirements of CERCLA, as amended, and the NCP. This
decision is based on the Administrative Record for the site. The
State of Montana has played a significant role during the remedy
selection process for this site and concurs with EPA on the
selected alternative as indicated by coauthorship of this ROD and
cosignature.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at and from
this site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedy selected by EPA, with the concurrence of the State,
addresses contaminated water in the Berkeley Pit and associated
underground mine workings. The alternative selected is a
modification of Alternative 6/7 presented in the BMFOU
Feasibility Studj (FS). The primary objective of the remedy is
to protect human health and the env~ronment from threats posed by
the rising contaminated waters in the Butte Mine Flooding
Operable Unit. To meet the primary objective stated above, the
remedy is intended to maximize control ,of inflow, thereby slowing
the Pit flooding in a cost-effective manner; maintains the water
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level in the bedrock system to prevent the release of
contaminants into the alluvial aquifer and the silver Bow Creek
drainage basin; institutes a comprehensive monitoring program to
insure that discharges to the alluvial groundwater system and
Silver Bow Creek do not occur, and; promotes the development of
innovative treatment and/or metals recovery processes in the
future. The selected alternative has the following major
components:
INFLOW CONTROL
1.
J~~ediate control of the Horseshoe Bend surface water
f~ow to the Berkeley Pit (currently averaging 2.4
million gallons per day (mgd)). No surface flows,
except on a short-term emergency basis, shall be
discharged to the Berkeley Pit. EPA and the State will
consider alternate inflow contro12 measures for control
of Horseshoe Bend surface water inflow if such measures
are equally effective.
2.
Immediate control of contaminated groundwater in the
Horseshoe Bend drainage area. EPA and the State will
consider alternate inflow control measures for the
control of Horseshoe Bend groundwater flow if such
measures are equally effective.
WATER TREATMENT
3.
Treatment of surface water (e.g., Horseshoe Bend) and
. groundwater in the Horseshoe Bend drainage area during
active mining may be accomplished by integrating the
flow into the Montana Resources (MR) mining process or
by treatment in a newly constructed treatment plant.
4.
When water in the Pit System reaches the elevation of
5,260 feet (USGS datum), or 24 months prior to
projected mine closure3, a focused review of treatment
technologies shall be conducted to evaluate
alternatives to the treatment technology selected
2 Inflow control is defined as the interception or pumping of surface water or ground water to prevent this
water from entering the East Camp and West Camp mine systems.
3 For the purposes of this ROD. mine closure is defined as: .when the mill operation is shut down (i.c:., no
concentrate production) for at least a six (6) month period and no minable reserves are left that could be mined at a
profit even if economic factors become more favorable. If EPA, in consultation with the State, determines that,
based on forecasts, assessments of reserves, or other information, that closure of the mine may occur within 24
months. EPA, in consultation with the State. may trigger this requirement by wrinen notice to the PRPs..
2
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during the FS. This focused FS shall use the
applicable EPA FS guidance in effect at that time. A
final decision concerning the technology to employ
shall be made by EPA, in consultation with the State,
at that time.
5.
Upon suspension of mining4 or upon mine closure and
regardless of water levels in the Berkeley Pit/East
Camp System, contaminated surface water (including all
Horseshoe Bend surface inflow) and Horseshoe Bend area
subsurface inflows shall be captured and treated.
Treatment shall be hydroxide precipitation/aeration
followed (if necessary) by reverse osmosis as a
polishing treatment to meet standards for discharge to
surface waters. EPA and the State will consider
alternate inflow control and treatment measures if such
measures are equally effective. If alternate inflow
measures are used, a minimum of 2.4 MGD shall be
treated. Additionally, all significant surface flows
from uncontaminated drainages (e.g., Yankee Doodle
Creek, Silver Bow Creek, North, East, and West
drainages), within the Berkeley pit drainage shall be
diverted around the East Camp/Berkeley System.
If inflow control cannot be accomplished through
integration of inflows into the mining process, or upon
suspension of mining or mine closure, design and
construction for a treatment facility shall begin
immediately and be completed on a schedule approved by
EPA in consultation with the State. In the event that
integration of inflow into the mining process cannot be
accomplished, this inflow may be discharged, on a
short-term and temporary basis, to the Berkeley Pit.
Treatment shall be a tvo stage hydroxide precipitation
and aeration process followed (if necessary) by reverse
osmosis as a polishing treatment to meet standards for
discharge to surface waters. Alternate treatment
technology that meets discharge standards and
objectives will be considered by the agencies. Treated
water shall be discharged to the Silver Bow Creek
drainage or used for other water supply purposes.
6.
7.
Integration of Horseshoe Bend water into the MR tailing
circuit is contingent upon maintaining earthquake
structural integrity and stability of the Yankee Doodle
Tailings Pond Dam as outlined in the Harding Lawson
Associates Report (Seismic Stability Evaluation -
Yankee Doodle Tailings Dam - Butte, Montana, Harding
Lawson Associates, April 9, 1993). If integration of
4 For the purposes of this ROD. suspension of mining is defined as: .when the mill operation is shut down
(i.e., no concentrate production) for at least a six (6) month period with minable reserves left that could be mined at
a profit when economic factors become more favorable..
3
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Horseshoe Bend flow into the tailings circuit is
instituted, all recommendations outlined in this report
shall be followed. In the event that the Yankee Doodle
Tailings Pond/MR tailing circuit cannot accept this
inflow control water and maintain earthquake structural
integrity and stability, there shall be an immediate
cessation of placement of inflow control water into the
MR tailings circuit. In the event that the Pond cannot
accept the inflow control water, on a short-term and
temporary basis, this inflow may be discharged to the
Berkeley Pit. Concurrently, the design and
construction of a treatment facility
(aeration/hydroxide precipitation) shall begin
immediately as provided in paragraph 6. For a period
of six (6) months, starting upon initial integration of
"inflow control" water into the MR tailings circuit,
weekly phreatic data shall be collected to evaluate
compliance with the dam earthquake structural integrity
and stability requirements. This data shall be
collected monthly after this initial six-month period.
If pumping of Horseshoe Bend water to the Yankee Doodle
Tailings Pond continues after suspension of mining or
mine closure, these monitoring requirements shall also
be met.
SLUDGE DISPOSAL
'.
8.
Any sludge(s) generated by a treatment process shall be
disposed of in an onsite disposal facility or in the
Berkeley Pit in compliance with pertinent requirements.
Because the precise chemical nature of the sludges and
quantity is not certain at this time, the exact method
and location of disposal of any such sludge(s) is not
specified in this ROD. After final determination of a
method of treatment and prior to design of a treatment
facility, a focused review of sludge disposal issues
shall be'done, assuming sludge disposal is a necessary
part of the treatment scheme. Such a review shall
determine the sludge(s) chemical characteristics and
compatibility for disposal in either the Berkeley Pit
or in an onsite disposal facility. EPA and the,State
will develop a scope of work (SOW) to direct this
focused review. Sludge disposal must 'be in accordance
with ARARs or appropriate waivers and shall not be
allowed in the Pit unless EPA approval is granted after
consultation with the State.
9.
If disposal of sludge(s) into the Berkeley Pit is
selected, an equivalent volume of Berkeley Pit/East
Camp System water shall be pumped and treated
sufficient to offset the volume that the sludge is
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displacing. The objective of this requirement is to
establish a zero (0) net inflow from the disposal of
sludge(s) into the Berkeley pit.
10.
MONITORING PROGRAM
WATER LEVELS
11.
A comprehensive monitoring program, including both
surface water and groundwater (alluvial and bedrock) ,
shall be employed to track the elevation and quality of
the waters in the East, West, and outer Camps. This
monitoring program is described in more detail in
Appendix 3. Data generated from this program will be
used to ensure that treatment facilities are in place
and operating prior to the time when the mine waters
approach the established critical water levels (CWLs)
and also to ensure the protectiveness of the CWLs. EPA
and MDHES will coordinate yearly updates, in the form
of a written report, that incorporates the new data
with existing data. This report will include, at a
minimum, the data gathered from the previous twelve
months, and an updated prediction of the time when the
CWL for the Berkeley Pit/East Camp System will be
approached. Every three (3) years EPA and MDHES will
review the monitoring program's completeness. This
three year review is to adjust, as determined by EPA
and the State, the requirements of the monitoring
program.
Water levels in the Berkeley Pit/East Camp System and
the Travona/West Camp System shall not be allowed to
rise above the established critical water levels (CWLs)
of 5,410 and 5,435 feet (USGS datum), respectively. In
addition, water levels in the East Camp shall be kept
below West Camp water levels. These levels and
requirements are established to prevent existing
hydraulic gradients from changing and thus to prevent
releases of contaminated water from the Pit System into
the alluvial aquifer or Silver Bow Creek drainage. The
points of compliance for determining water levels for
Berkeley Pit/East Camp System CWL shall be: the
Berkeley Pit, Anselmo, Belmont, Granite Mountain,
Kelley, and Steward shafts, bedrock monitoring wells
installed as part of the RIfFS or monitoring program
(i.e., those wells within the cone of influence of the
East Camp System), and wells DDH-1, DDH-5, andDDH-8
(taken in tandem and treated as one data point). As
there is the potential for collapse/failure of existing
shafts and thus their loss as monitoring locations for
points of compliance, EPA, in consultation with the
state, will evaluate and direct alternative existing
shafts as replacement points of compliance as
necessary. If no satisfactory alternative shafts
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12.
exist, EPA, in consultation with the state, will direct
the installation of bedrock monitoring wells to replace
the lost/failed shaft. The points of compliance for
determining water levels for Travona/West Camp System
CWL shall be: the Travona, Emma and ophir shafts, and
any additional monitoring wells for the Travona/West
Camp System installed as part of the monitoring
program.
When the monitoring program and yearly update reports,
described in paragraph 10 above, indicate the CWL may
be approached within eight years, design of the final
water treatment facility shall begin, with construction
to be completed four (4) years prior to the projected
date for water in the East Camp System to reach the
CWL. This treatment plant shall be capable of
maintaining the water level in the East Camp System
below the 5,410-foot elevation.
13.
WEST CAMP/TRAVONA
EPA took action to control the water level of the West
Camp/Travona Shaft System in 1988 by pumping and
treating Travona shaft water (West Camp/Travona Shaft
System Expedited Response Action). The action taken to
control the West Camp water is still appropriate; it
is, therefore, integrated and incorporated into this
remedy for the BMFOU. The water level in the West Camp
shall continue to be maintained below the CWL of 5,435
(USGS datum) feet by the ongoing pumping to the Butte
pUblicly-owned treatment works (Butte Metro Plant). If
the Metro Plant cannot continue to accept this water,
an alternative treatment plant shall be used (newly
constructed if necessary) to handle this flow.
14.
INSTITUTIONAL CONTROLS
Institutional controls, including controls on
groundwater use, shall be implemented to ensure that
there is no inappropriate use of contaminated bedrock
groundwater which threatens human health and the
environment. EPA and the State plan to request
implementation of this program by local governmental
entities.
These actions will provide containment of contaminated water in
the East and West Camp Systems, and will prevent the release of
contaminated water to the alluvial aquifer and Silver Bow Creek.
As long as surface water and groundwater inflows to the Pit
System are controlled as outlined above and water quality
standards for treated water discharged to the Silver Bow Creek
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drainage are
with respect
discharge of
met, EPA and the state will maintain flexibility
to alternate methods for control, treatment, and
this volume of water.
Implementation of the selected remedy is intended to prevent the
primary threat of exposure to contaminated bedrock groundwater
and surface water by humans and aquatic life. The monitoring and
control of the water levels in the East and West Camp Systems is
intended to ensure that the CWLs are not exceeded, that there is
no reversal of hydraulic gradients, and that contaminated water
does not discharge to the alluvial aquifer or Silver Bow Creek.
Treatment of pit water and surface water inflows is intended to
ensure that water discharged to the Silver Bow Creek drainage
meets State of Montana water quality standards and other
applicable or relevant and appropriate requirements (ARARs).
Implementation of institutional controls associated with the use
of contaminated bedrock aquifer water is intended to ensure the
protection of public health from the dangers posed by direct
ingestion of the contaminated groundwater.
STATUTORY DETERMINATION
The selected alternative is protective of human health and the
environment through the containment of contaminated water within
the BMFOU, treatment of the contaminated water prior to discharge
to the Silver Bow Creek drainage, and the control of
inappropriate use of contaminated bedrock groundwater. The
selected alternative will meet all Federal and state requirements
(i.e., ARARs) except the Federal and State groundwater quality
standards (See Appendix 1 - ARARs for the Butte Mine Flooding OU
and Appendix 3 - Technical Impracticability evaluation) for the
bedrock aquifer. EPA is waiving these requirements based on the
determination that compliance with these standards is technically
impracticable from an engineering perspective. Treated water
discharged to the silver Bow Creek drainage will meet discharge
requirements. Any sludge produced from treatment will be
disposed of in compliance with applicable solid and hazardous
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waste regulations or an appropriate waiver of these
requirements. Although the selected alternative has higher
associated costs than the other alternatives evaluated which
protect human health and the environment, the additional cost is
outweighed by the fact that the selected alternative mandates the
immediate and permanent control of water inflows to the Pit
System. This immediate and permanent control .of inflows slows
down the Pit flooding, allowing for greater opportunity to
address unforseen contingencies and to develop alternative
innovative technology, which may reduce sludge generation and/or
allow the recovery of metals. The selected alternative uses
permanent solutions to the maximum extent practicable for thi~
operable unit and promotes the development of alternate treatment
technologies. It also satisfies the statutory preference for
remedies that reduce the toxicity, mobility, or volume of
contamination through treatment.
Since hazardous substances above health-based levels will remain
onsite, reviews will be conducted within each five year period
after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
~
William Yellowt il
Regional Admini trator
United States Environmental
Region VIII
Protection Agency
Ro~1;2{:£~~
Director /'
Montana Department of Health and
2.q ~£~~tJi/l 1'1'14
Date
I&~'L
Environmental Sciences
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DECISION SUMMARY
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TABLE OF CONTENTS
1.
PAGE
'SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . 1
2.
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . 6
3.
HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . " 13
4.
SCOPE AND ROLE OF THIS OPERABLE UNIT WITHIN SITE STRATEGY. 15
5.
SUMMAR Y OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . 17
6
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
7.
REMEDIAL ACTION OBJECTIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . 34
8.
DESCRIPTION OF AL TERNA TIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
9.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . .. 39
10.
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45
11.
PERFORMANCE STANDARDS ..............................49
12.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
13.
DOCUMENT A TION OF SIGNIFICANT CHANGES. . . . . . . . . . . . . . . . . 52
REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
APPENDIX 1
ARARs
APPENDIX 2
TECHNICAL IMPRACTICABILITY EVALUATION
APPENDIX 3
MONITORING PROGRAM
Attachment 1 - Volume Calculations
APPENDIX 4
RESPONSIVENESS SUMMARY
Attachment 1 - Identification Matrix
Attachment 2 - Transcript of Public Hearing
Attachment 3 - Written Comments
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Table 1
Table 2
Table 3
Table 4
Table 5
Figure 1
Figure 2
Figure 3
Figure 4
TABLE OF CONTENTS (Continued)
LIST OF TABLES
PAGE
Average Concentration of Constituents in Berkeley Pit, Bedrock
Well, and Shaft Water and Established Standards, Butte Mine
Flooding Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Enforcement Action Orders, Butte Mine Flooding Operable Unit. . . . .. 12
Estimated Future Concentrations in the Alluvial Aquifer
Downgradient of the Berkeley Pit and in Silver Bow Creek
Given Three Pit Water Discharge Scenarios. . . . . . . . . . . . . . . . . . . 23
Summary of Potential Carcinogenic and Noncarcinogenic Risk,
Butte Mine Flooding Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . 28
Estimated Future Concentrations in Silver Bow Creek and
Hardness-Adjusted Ambient Water Quality Criteria, Butte Mine
Flooding Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
LIST OF FIGURES
Butte, Montana and Surrounding Area, Mine Flooding Operable
Unit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Water Level Contour Map for the Bedrock Aquifer. . . . . . . . . . . . . . .. 5
Well Level Contour Map for the Alluvial Aquifer. . . . . . . . . . . . . . . .. 7
BMFOU Water Balance Flow Diagram. . . . . . . . . . . . . . . . . . . . . . .19
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DECISION SUMMARY
1. SITE NAME, LOCATION, AND DESCRIPTION
Silver Bow Creek/Butte Area NPL Site
Mine Flooding Operable Unit
Butte, Montana
The Butte Mine Flooding OU is part of the Silver Bow Creek/Butte Area NPL site and is
located in and near the cities of Butte and Walkerville, Montana. It consists of waters within
the Berkeley Pit, the underground mine workings hydraulically connected to the Berkeley Pit,
the associated alluvial and bedrock aquifers, and other contributing sources of inflow to the
Berkeley Pit/East Camp System (including surface runoff, leach pad and tailings slurry
circuit overflows) and the TravonalWest Camp System. For more information about these
systems, refer to the Technical Impracticability (TI) evaluation (Appendix 2). The
boundaries of the OU are approximately the Continental Divide to the east, Metro Storm
Drain/Silver Bow Creek to the south, Missoula Gulch to the west, and the Yankee Doodle
Tailings Pond watershed drainage system to the north. The au is within the Butte mining
district in the upper Silver Bow Creek drainage, and covers about 23 square miles (Figure
1).
Butte residents have access to drinking water through the Butte municipal water system
which acquires water from the Big Hole River and the upper Silver Bow Creek drainage
(Moulton Reservoir). These water supplies are not impacted by contamination in the Butte
Mine Flooding OU or by remedial action taken at this OU. However, the Private Well
Inventory revealed that there are currently more than 800 private and municipal alluvial wells
in the Butte area. There are approximately 140 alluvial wells in close proximity to the Butte
Mine Flooding au that could potentially be impacted by mine flooding waters. The public
does not have access to the few bedrock wells within this OU.
The Berkeley Pit/East Camp System (the Pit System) is located in the northern and eastern
portions of the OU (Figure 1). The Berkeley Pit is the major feature of the OU, and it is
1
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Butte, Montana
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Mine FloodiDg
Operable Unit
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1,780 feet deep, encompassing an area of 675 acres and a volume of 26 billion gallons of
contaminated water. This system also encompasses more than 3,000 miles of underground
mine workings. The West Camp System is located in the southwest comer of the OU and
includes the Travona, Emma, and Ophir mines and their associated underground workings.
These two systems are separated by bulkheads installed in the late 1950s and are considered
to be separate hydrologic systems; however, the bulkheads may be leaking, thereby allowing
water to flow from the West Camp System to the Pit System.
An important C M!X>nent of the current mining operation is the leach pads area, which is
located northeast of the Berkeley Pit and covers an area of 775 acres. The pads consist of
low-grade ore and waste rock. An acidic leaching solution is pumped from the MR
Precipitation Plant and distributed to the pads. This solution percolates through the pads,
leaching copper from the ore. The "pregnant" (copper-laden) solution is collected and piped
to the Precipitation Plant for extraction of the dissolved copper.
A major seepage area originates in the Horseshoe Bend area, located in the northwest comer
of the Precipitation Plant area. Acidic water discharging (about 2.4 mgd) in the Horseshoe
Bend area is routed to a storage pond located immediately west of the Precipitation Plant. A
portion of the acidic Horseshoe Bend water (about 0.9 mgd) is presently routed to the
Precipitation Plant, mixed with the leaching solution, and pumped to the leach pads area or
the tailings pond. The remaining acidic Horseshoe Bend water is channeled past the
Precipitation Plant area and discharged into the Berkeley Pit.
Tailings from the milling process at the MR Concentrator are pumped as slurry to the
Yankee Doodle Tailings Pond. The tailings pond is a settling basin used to decant water
from the tailings slurry. Decanted water in the pond is then pumped back to the
concentrator for use "in the milling operation. The tailings pond occupies an area of about
960 acres.
-------
The MR Concentrator is located near the south rim of the Berkeley Pit. Currently only ore
(approximately 50,000 tons/day) from the Continental Pit, located east of the Berkeley Pit, IS
milled and processed at the concentrator. The milling process uses water decanted from the
tailings pond, imponed water from the Silver Lake pipeline, and excess water pumped from
the Continental Pit area.
Silver Bow Creek is the main stream drainage within the Butte Mine Flooding OU.
Originally the creek flowed from its origin in the mountains nonheast of the tailings pond
through the area presently altered by mining activities. Mining and other activities in the
area have greatly changed the original channel alignment. Surface water flow above the
tailings pond is intercepted by the tailings pond and used as makeup water in the milling
process. From the tailings pond to the MR Concentrator, the original Silver Bow Creek
channel no longer exists. Surface water in the active mining area is controlled by a series of
ditches and ponds which convey runoff and mine process water to various locations,
including the Berkeley Pit, leach pads, and concentrator area (Figure 2). From the MR
Concentrator to the confluence with Blacktail Creek, the former creek has been reconfigured
and is knoWn as the Metro Storm Drain. Currently, Silver Bow Creek begins at the
confluence of the Metro Storm Drain and Blacktail Creek, from which it receives the
majority of its flow. From there, the creek flows west and then nonb, terminating at Warm
Springs Ponds.
The principal geologic rock units within the Butte Mine Flooding au are the alluvium ~d
the bedrock. The alluvium is a sedimentary deposit consisting of unconsolidated and
discontinuous layers of sand, silt, clay, and gravel. The alluvium thickness ranges from 130
feet near the leach pads to 600 feet or more southeast of the Berkeley Pit. Underlying the
"alluvium is igneous bedrock consisting primarily of quartz monzonite. The upper 100 to 200
feet of the bedrock is weathered (oxidized and decomposed) to a clayey material interspersed
with rock fragments.
-------
COI'lTINEI'lTAl PIT
N
YANK~E DOODLE
TAIUNGS POND
r
, MARGARET
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LOCATIOH -AND~ DESIGNATION
." . ''''''.' . - .'4 .''".
DDH-~Ii -DWoIOND DRILL HOL£ LOCATION'
. ..."AND DESIGNATION" ..:' -.~ .
~. .... .'" '.~" ~
PARROT MUNICIPAL MONITORING WElL
PARK. LOCATION ANO DESIGNATION
~
KEU.£Y
MINE SHAFT LOCATION AND
DESIGNATION
BEDROCK WATER LEVEl ELEVATION,
F1IT ABOVE MEAN SEA LEVEl
(5082,.1)
-5080- BEDROCK WATER LEVEL ELEVATION,
F1IT ABOVE MEAN SEA LEVEl
+-c
DIRECTION OF GROUND WATER FLOW
~
1. BEDROCK ADUIFER MONITORING WELL E NOT
USED FOR CONTOUR MAP INTERPRETATION
BECAUSE OF ANOIolALOUS WATER L£\IEL
t.I£ASURENENTS.
2. AU. WATER L£VEl.S t.lEASURED DURING
JULY 1993.
3, FOR CONTINENTAL FAULT, D INDICATES
DOWN1HROWN SIDE AND U INDICATES
UPTHROWN SIDE.
4. WATER LEVEl ElEVATIONS IN THE TRAVONA
SHAFT AND THE CHESTER STEElE AND
H£BGEH PARK WELLS ARE AfftCTED BY
PUMPING IN THE TRAVONA SHAFT,
SCAl£
~
1800
o
,
1800 Ft:£T
WAT[R lEVEL COI'lTOUR MAP
FOR THE BEDROCK AOUIFER
FIGURE 2
Source: ARCO 19943
~
t
-------
The two main aquifers in the area are the bedrock, which underlies the entire OU, and the
alluvium, which was deposited over the bedrock in valleys and drainages. Groundwater in
the bedrock occurs in fractures, joints, and mine workings. Currently, groundwater levels in
the surrounding bedrock aquifer are higher than the water level in the Berkeley Pit, resulting
in radial flow of groundwater from the bedrock toward the Pit (Figure 2).
Groundwater in the alluvium flows south from the leach pads area and then west toward the
Berkeley Pit (Figure 3). An alluvial groundwater divide exists approximately one mile south
of the Berkeley Pit. North of this divide, groundwater flows toward the Pit; south of the
divide, groundwater flows parallel to the Metro Storm Drain toward Silver Bow Creek.
The Berkeley Pit is filling with water originating from the surrounding bedrock and alluvial
aquifers and also from surface inflows. The water accumulating in the Berkeley Pit and in
the bedrock aquifer is acidic and contains high concentrations of metals (Table 1). The
source of the contamination is AMP1 from the bedrock in the mine workings, waste rock
dumps, and leach pads. Presently, because all bedrock groundwater flow in the area is
toward the Berkeley Pit, contaminated mine water is being contained in the East and West
Camps (refer to TI evaluation - Appendix 2). However, if water levels continue to rise
uncontrolled, the hydraulic gradient could change and contaminated water could begin to
flow out of the East and West Camps into the surrounding alluvial groundwater and
eventually to Silver Bow Creek. To prevent this from occurring, EPA and the State
determined that the water levels in the OU must not rise above the CWLs (East Camp -
5,410 feet, West Camp - 5,435 feet (USGS datum».
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Underground mining of silver and copper began in Butte in the late 1800s. By 1950, over
400 underground mines, consisting of several thousand miles of interconnected mine
I AMD (acid mine drainage) results from the oxidation of sulfide minerals such as pyrite exposed to oxygen in
air and water forming iron hydroxide. sulfate. and free hydrogen ions.
6
~ \
~./'
-------
N
~
~.IIII .,.~l'
,,'
,-
,
I
I
f
f
\
)
I
I
\
\
\
\ '
-"
,.
,-
I
J
I
I
i Source: ARCa 1994.
ILGDiIt
CII-'13
"'0 1108' CMD aJII::Uo IfIDCD,III.
8M:S!I:oA.1IQN IiIOIGtIDC .o..a. s::r
~ NG CDICIMIICIII (0f.J1II ....... It1O)
Me. a.e.o.. .cwr..... I'Q.( CDIQ.I. 1nL
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~C&.~.:u.LlICA1IJIrI
- CIDD8UDI (t8ICL tlU)
.~..
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......... UJQGDI " ~ CDfttCI
~ I.DCGDI fI1 aIft'8CNPL f'NLf.
"'r MXAIIS ~ ... v ...:aID
--
~ --- CII wmI &nIL
- 5flI(J- == ~DZJ81Dt rID '8M
..... ....- fir - .... ....
JIIII£S;
t. -.JD I.hrLS IIIAII.8ID D8C IUIMJ llU.
1. c::om:u IJaIJI8LI ..,.
P"""'I
WAtER l£VEl CONTOUR MAP
FOR niE AI..UMAI. AQUIf[R
FIGURE 3
... r ..--. -.-.. -. . ,-,,. -..._..,.....~-
-
-------
TABLE I
AVERAGE CONCENTRATION OF CONSTITUENTS IN BERKELEY PIT, BEDROCK WELL, AND SHAFf WATER
AND ESTABLISHED STANDARDS
Bt.rrTE MINE FLOODING OPERABLE UNIT
/
Constituent Berkeley Pit Bedrock Well Shaft Wate.-J MCLs4 (pg/L) WQC' (pg/L)
Waterl (pglL) Water (pglL) (pglL)
Acute Chronic
Aluminum 270,000 244 675 None 7S0 87
Arsenic6 710 52 211 50' 360 190
Cadmium 1,790 2.4 100 5' 3.9 1.1
Calcium 440,000 127,610 276,321 Non~ Non~ Non~
Chloride 26,200 4,400 NA 2S0,OOOs 19 II
Copper 167,000 26.4 1,581 1,3O
-------
workings, had operated or were operating in Butte.
In July 1955, the Anaconda Copper Mining Company began open pit mining in the Berkeley
Pit. In 1963, the Weed Concentrator (now known as the MR Concentrator) became
operational. are from the Berkeley Pit was processed at this facility, and concentrates were
transponed to Anaconda, Montana for smelting. The Atlantic Richfield Company (ARCO)
purchased the Anaconda Copper Mining Company in 1977 and owned the Pit and associated
propeny until it was sold to Dennis Washington/Montana Resources, Inc. (MRI) in 1985. In
1989, a panne:~hip known as Montana Resources (MR) was formed betWeen MRI and AR
. Montana Corporation, a subsidiary of American Smelting and Refining Company
(ASARCQ). MR was formed to own and operate the propeny.
Mining in the Berkeley Pit was discontinued in 1983. Since JuJy 1986, open pit mining has
been conducted in the East Continental Pit, located east of the Berkeley Pit. Ore from this
pit is transponed to the MR Concentrator for milling.
To allow underground and later open pit mining in the Butte area, groundwater was lowered
by pumping. In latter years, the pumping system was located in the Kelley Mine shaft, just
west of the Berkeley Pit. In 1982, pumping was discontinued. As a result, the artificially
lowered groundwater level in the area has been rising toward its pre-mining level in the
underground mines and the Berkeley Pit. The Pit filling rate is decreasing with time and as
the water level rises. For example, the 1988 filling rate was estimated to be 7.6 mgd; the
Pit is currently estimated to be filling at a rate of 5 mgd. In December 1993, the elevation
of the water in the Pit was 5,062.67 feet (USGS datum) and was increasing by about 2 feet
per month. It is currently projected that the CWL of 5,410 feet (USGS datum) for the East
Camp/Berkeley Pit System will be reached around the year 20132, if no remedial actions are
taken.
1 Assumes current inflow rates and that the water level in the Anselmo Mine remains 20 feet above the Berkeley
Pit water level.
-------
The history of pollution problems aSsociated with mining activities in the Butte area led to
listing of the Silver Bow Creek Site on the NPL in September 1983. Tailings released from
early Butte milling operations and solids eroded from waste rock dumps had covered much of
the floodplain of Silver Bow Creek. Another major source of contamination was discharge
of metal-enriched mine waters from the Weed Concentrator to the creek. RIfFS work for the
Silver Bow Creek site began in late 1984.
During the course of the Silver Bow Creek RIfFS, the imponance of Butte as the source of
the contaminati0!1 of Silver Bow Creek was formally recognized. The original listing on the
NPL characterized the Silver Bow Creek Site as approximately 28 stream miles beginning at
the Metro Storm Drain and extending downstream to Deer Lodge. The EP A proposed
modifying the existing Silver Bow Creek NPL Site to include the Butte area. Preliminary
results from the Silver Bow Creek RIfFS indicated that sources upstream of the .storm drain
were partly responsible for the contamination observed in the creek. After a thorough
analysis of the relationship between the two areas (Butte and Silver Bow Creek), EP A
concluded that the geographical relationship of the headwaters of Silver Bow Creek and the
portion of the creek downstream of the city of Butte favored treating these areas as one site
under CERCLA (EPA 1986). The site was expanded as proposed to include the Butte area
and the formal name of the sit~ was changed to the Silver Bow Creek/Butte Area Site in July
1987 (52 Fed. Reg. 1987).
The Silver Bow Creek/Butte Area site has been divided into seven OUs: Mine Flooding,
Priority Soils, Non-Priority Soils, Active Mining Area, Warm Springs Ponds, Rocker, and
Streamside Tailings. EPA is the lead agency for the first six OUs, and the State of Montana
is the lead agency for remedial activities at the last au.
Preliminary Butte Mine Flooding au RIfFS forward planning studies began during the
summer of 1987. In support of the Butte Mine Flooding OU, EPA conducted an evaluation
of mine flooding in the Berkeley Pit and West Camp (Camp Dresser and McKee, Inc.
[CDM] 1988a, b), and an evaluation of the Pit water chemistry (CDM 1988c). These
-------
evaluations indicated that it would be necessary to control the rate of Pit filling to prevent
impact to the alluvial aquifer and Silver Bow Creek. The evaluations further demonstrated
the need to treat the Pit water prior to discharge to Silver Bow Creek.
ENFORCEMENT HISTORY AND ACTIONS
A removal action was implemented in the West Camp area to control potential impacts of
rising mine waters. The purpose of the removal action was to prevent flooding of basements
and discharge of contaminated groundwater to Silver Bow Creek. An Engineering
Evaluation/Cost Analysis (EE/CA) of potential response alternatives was conducled by EPA
in suppon of the West Camp removal action (CDM 1989).
On March 31, 1989, EPA entered into an Administrative Order on Consent (AOC) with
ARCO and Dennis Washington (the consenting PRPs) pursuant to Section 106(a) of
CERCLA as amended by SARA in connection with the West Camp removal action (Table
2). The West Camp order required the consenting PRPs to convey water from the Travona
Shaft to the Butte Metro Plant for treatment and discharge to Silver Bow Creek. In the event
that the Metro Plant could not accept this water, the consenting PRPs would be required to
construct a treatment plant for treatment of Travona Shaft effluent prior to discharge to
Silver Bow Creek. This AOC established a preliminary CWL for the West Camp and
required the consenting PRPs to maintain water level elevation below 5,435 feet (USGS.
datum).
A unilateral Order was issued to the non-consenting PRPs (Table 2) to install the pipeline
which carried Travona shaft water to the Butte-Silver Metro Sewer Plant line. The non-
consenting PRPs complied with this Order.
EPA completed the RI/FS Work Plan for the Butte Mine Flooding OU in April 1990 (CDM
1990). This document outlined the work to be conducted during the RI/FS, the schedule for
the work, and the parties responsible for each portion of the work. EP A and the State then
entered into an AOC with the consenting PRPs to implement the major portion of this work
-------
TABLE 2
ENFORCEMENT ACTION ORDERS
BUTI'E MINE FLOODING OPERABLE UNIT
,.
/
ACTION DATE DOCKET NO. ISSUED TO
Administrative Order on Consent March 31, 1989 CERCLA-VIII-89-19 I) ARCO
for the West Camprrravona Shaft 2) Dennis Washington
Administrative Order (UAO) for March 31, 1989 CERCLA - VIII-89-18 I) New Butte Mining Inc.
the West Camprrravona Shaft 2) Tzarina-Travona Mining Corp.
Administrative Order on Consent May 17, 1990 CERCLA-VIII-90-09 I) Atlantic Richfield Company
for the Remedial Investigationl 2) Mr. Dennis Washington
Feasibility Study 3) Montana Resources Inc.
4) AR Montana Corporation
5) ASARCO, Inc.
6) Montana Resources
Administrative Order (UAO) for May 17, 1990 CERCLA-VIII-90-10 I) Central Butte Mining Company
the Remedial Investigationl 2) North Butte Mining Company
Feasibility Study 3) Tzarina-Travona Mining Corp.
4) Mountain Con Mining Co.
5) West Butte Metals, Inc.
6) Blue Bird Mining Co.
7) Eureka Mining Co.
8) Yankee Mining Co.
9) East Ridge Mining Co.
10) Black Rock Mining Co.
-------
plan (Table 2). This AOC directed the PRPs to conduct the work according to the Work
Plan with EP A and MDHES oversight. The AOC also established a preliminary CWL of
5,410 feet (USGS datum) for the East Camp/Berkeley Pit System and required the PRPs to
maintain the water elevation below this level. A unilateral Order was also issued to the
non-consenting PRPs to implement a small portion of the RI/FS work plan. The RI/FS was
conducted from July 1990 through January 1994. Site investigations, results, arid remedial
alternative development and evaluation are presented in the Draft RI Report (ARCO 1994a)
and the Draft FS Report (ARCO 1994b).
-
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation is required by CERCLA Sections 113 and 117. These sections require
that before adoption of any plan for remedial action to be undertaken by EPA, by a State
(MDHES), or by an individual (PRP), the lead agency shall:
1.
Publish a notice and brief analysis of the Proposed Plan and make such plan
available to the public; and
2.
Provide a reasonable opportunity for submission of written and oral comments
and an opportunity for a public meeting at or near the site regarding the
Proposed Plan and any proposed findings relating to cleanup standards. The
lead agency shall keep a transcript of the meeting and make such transcript
available to the public. The notice and analysis published under item #1 shall
include sufficient information to provide a reasonable explanation of the
Proposed Plan and alternative proposals that were considered.
Additionally, notice of the final remedial action plan adopted must be published and the plan
must be made available to the public before commencing any remedial action. Such a final
plan must be accompanied by a discussion of any significant changes to the preferred remedy
presented in the Proposed Plan along with the reasons for the changes and a response
(Responsiveness Summary) to each of the significant comments, criticisms, and new data
-------
submitted in written or oral presentations during the public comment period.
EP A has conducted the required community participation activities through presentation of
the RIfFS and Proposed Plan, a 90-day public comment period (after a public request for
extension), three informational meetings, a formal public hearing, and a presentation of the
Selected Remedy in this ROD. Specifically included with this ROD is a Responsiveness
Summary that summarizes public comments and EP A responses.
The RIfFS a. . .'roposed Plan for the Butte Mine Flooding OU were released for public
comment on January 27, 1994. The RIfFS and Proposed Plan were made available to the
public in the Administrative Record located at the EPA Record Center (Helena, Montana),
the Butte EPA Office (Butte, Montana), and the Montana Tech Library (Butte, Montana).
The notice of availability of the RIfFS and the Proposed Plan was published in the Butte
newspaper, The Montana Standard, on January 23 and 27, 1994. A formal public comment
period was designated from January 27, 1994 to March 14, 1994. After a request from the
Clark. Fork Pend Orielle Coalition and others, this public comment period was extended an
additional 45 days to April 29, 1994.
The Proposed Plan was mailed to all individuals on the Silver Bow Creek/Butte Area NPL
mailing list on January 27, 1994. This list includes 1,000 individuals, the majority residing
in Butte, Montana. The RI and FS were supplied to all individuals requesting those
documents.
EP A held an informational meeting in Butte on January 27, 1994 to explain the RIfFS
process, outline the Proposed Plan and the preferred alternative, and to answer questions
regarding the alternatives. A press conference and meeting of elected officials was also held
on January 27, 1994. At this press conference, EPA explained the Proposed Plan, the
preferred alternative, and answered questions from the press and public officials. EP A held
an informational meeting in Butte on February 1, 1994 to explain technical information
relating to the RIfFS, the Proposed Plan, and the preferred alternative. Another
-------
informational meeting was held by EPA in Butte on March 8, 1994. The March 8th meeting
was informal in nature and allowed for one-on-one discussions with EPA, MDHES, and PRP
officials. A notice of each meeting was published in the Butte newspaper, The Monrana
Standard, (January 27; February 1; March 8, 1994).
In addition to the formal meetings, EP A made presentations, answered questions, and
discussed the Proposed Plan and RIfFS with several groups, including the Citizens Technical
Environmental Committee (CTEC), Clark Fork Pend Orielle Coalition, the Butte-Silver Bow
Council of Commissioners, the Silver Bow Kiwanis, and the Big Butte Kiwanis. The EP A
Project Manager discussed the Proposed Plan, RIfFS, and preferred alternative on a radio
call-in show (Party Line--February 22, 1994) and a television public affairs show (Focus--
March 13, 1994).
A formal public hearing was held in Butte on April 26, 1994. At this hearing,
representatives from EP A answered questions about remedial altem~tives under
consideration, as well as the preferred remedy. A portion of the hearing was dedicated to
accepting formal oral comments from the public. A court reporter transcribed the formal
oral comments and EP A made the transcript available by placing it in the Administrative
Record. A response to comments received during the public comment period is included in
the Responsiveness Summary, which is part of this ROD. Also, community acceptance of
the selected remedy is disc~ssed in Section 9 (Summary of Comparative Analysis of
Alternatives) of this Decision Summary.
4. SCOPE AND ROLE OF THIS OPERABLE UNIT WITHIN SITE STRATEGY
EP A has identified seven Ous within the Silver Bow Creek/Butte Area site. These are:
Mine Flooding, Priority Soils,. Non-Priority Soils, Active Mining Area, Warm Springs
Ponds, Streamside Tailings, and Rocker. EPA is the lead agency for remedial activities at
the first five Ous, and the State of Montana is the lead agency for the Streamside Tailings
and Rocker OUs.
-------
Actions at the Silver Bow Creek/Butte Area site OUs are concerned with the impactS of
mining activities on surface waters, groundwater and soils and the potential health effects
resulting from mining activities in the areas of Butte and Silver Bow Creek. The Butte Mine
Flooding OU is located in the upstream ponion of the Silver Bow Creek/Butte Area site and,
thus, a release of contamination from this OU would cause funher detrimental impacts to
surface water and groundwater in downstream OUs. Remediation in the Butte Mine
Flooding OU is considered a priority by EPA because of the rate of flooding (currently 5
mgd) and extremely high toxicity to aquatic life of the water contained in the bedrock system
and the potentiaJ downstream impacts and risks to human health and the environment which
would be caused by the release of the contaminated waters. Remedial actions undertaken in
the Mine Flooding OU will complement future actions in the other Silver Bow Creek/Butte
Area site OUs. Significant cleanup actions have already been initiated for other OUs at this
site to improve water quality in Silver Bow Creek and the Clark Fork River. The action
described herein will ensure that contamination in the Butte Mine Flooding au will not
contribute to the degradation of Silver Bow Creek or the Clark Fork'River.
The Butte Mine Flooding RIfFS was conducted by the PRPs with EP A and State oversight
from 1990 to 1994 to identify and evaluate the nature and extent of contamination associated
with mine flooding and to identify and evaluate potential remedial alternatives. The major
objectives of the RIfFS were:
1.
To establish safe elevations below which the water in the Berkeley Pit/East
Camp and TravonalWest Camp Systems must be maintained in order to
contain contaminated ~ater in these systems;
2.
To identify and evaluate alternatives that protect the alluvial aquifer and Silver
Bow Creek from contaminated bedrock system waters;
3.
To evaluate alternatives that would maintain the water levels in the au below
the safe water levels; .
4.
To develop alternatives to ensure that treated water discharged to the Silver
Bow Creek drainage meets Federal and State standards.
-------
The remedy presented in this ROD represents the final re~edial actions for the Butte Mine
Flooding OU. The purpose of the remedy is to contain contaminated water within the East
and West Camp Systems by keeping the water levels below the established CWLs. This is
intended to prevent the release of contaminated water to the alluvial aquifer and Silver Bow
Creek. All water treated in conjunction with this remedy shall meet Silver Bow Creek
discharge standards. These actions are intended to prevent the exposure of human and
aquatic life to contaminated groundwater and surface water. The remedy for the Butte Mine
Flooding OU is intended to be consistent with remedial action objectives identified for and
remedial actions undertaken at other site OUs.
5. SUMMARY OF SITE CHARACTERISTICS
Water in the Berkeley Pit, surrounding bedrock aquifer, and the shafts contains high levels of
toxic metals and arsenic as a result of water levels rising in the mine workings, and from
contaminated surface water inflows (see Table 1). The source of the contamination is AMD
which results from the oxidation of sulfide minerals (in the presence of oxygen) to form iron
hydroxide, sulfate, and free hydrogen ions. Water in the alluvial aquifer between the leach
pads and Pit is also contaminated with high levels of metals as a result of seepage from the
leach pads. Due to the presence of the Berkeley Pit and a groundwater divide located south
of the Pit, all gr~undwater in the OU is presently flowing toward the Pit and contaminated
water has not migrated offsite.
The preliminary CWLs have been established by EP A to contain the contaminated water in
the Berkeley Pit and West Camp Systems. If either CWL is exceeded, there is the potential
for the present hydraulic gradient to change, resulting in the flow of contaminated water
away from the OU. This water could potentially move in the alluvial aquifer or on the
ground surface toward Silver Bow Creek and could result in the potential exposure of human
and aquatic life to contaminants.
REMEDIAL INVESTIGATION
During the RI, the Inflow Control Investigation collected data on the mine operation and Pit
17
-------
water balance. This information was used in the FS to evaluate alternatives for controlling
the rate of Pit filling. The Neutralization Investigation collected chemical information on the
Berkeley Pit water for evaluating treatment alternatives. The Alluvial Aquifer Investigation in
the area of the leach pads evaluated the impact of the leach pads on the alluvial aquifer. The
Bedrock Aquifer Investigation ascertained the quality and level of water in the deeper
aquifer, determined flow direction, and assessed the potential impact of the rising bedrock
aquifer on the alluvial aquifer. The major findings of the RI are as follows:
.
The prel1_minary CWLs corresponding to the 5,410 foot elevation (USGS datum) for
the Pit System and 5,435 foot elevation (USGS datum) for the West Camp System
were confirmed as being protective of Silver Bow CreeklBlacktail Creek and the
associated alluvial aquifer from contaminated bedrock aquifer waters. These water
levels are considered ~e levels (i.e., protective of human health and the
environment) because the alluvial water elevations adjacent to the Pit are at least 50
feet higher than these CWLs.
.
The Inflow Control Investigation found that the average rate of surface inflow to the
Berkeley Pit is 1.68 mgd, the majority of which comes from the Horseshoe Bend
area. The investigation further determined that outflow from the seeps in the
Horseshoe Bend area average 2.4 mgd, part of which flows to the Pit (1.54 mgd), and
part of which is re-used in the leach pads operation and integrated into the tailings
circuit (0.86 mgd) (Figure 4). The quality of the Horseshoe Bend water was similar
to the quality of the 'Berkeley Pit water. It was determined that if surface water in the
Horseshoe Bend area is controlled and prevented from entering the Berkeley Pit, the
water level in the Pit System (East Camp) would not reach the CWL until after the
year 20253. Total inflow into the East Camp System is about 5 mgd. About half of
this flow is uncontrollable bedrock recharge and about 0.58 mgd is uncontrollable
flow from the alluvial aquifer..
.
The Bedrock Aquifer Investigation and monitoring program confirmed that the
contaminated bedrock aquifer groundwater is moving toward the Berkeley Pit.
Bedrock aquifer water in un mined areas at the periphery of the East Camp cone of
depression showed low concentrations of metals, while samples from mine shafts
exhibited elevated metals concentrations.
.
The Leach Pads Area Alluvial Aquifer Inve~tigation demonstrated that the alluvial
aquifer in the leach pads area has been contaminated by the leach pads operation.
J Assumes Anselmo Mine water level remains 20 feet above the Berkeley Pit water level.
-------
HORSESHOE
BEND
NET
(0.86) EVAPORATION
(NEe)
PRECIPITATION
PLANT
(1.45)
NET
EVAPORATION
(1.54)
(15.80)
(0.12)
( 14.43)
(0.30)
(??)
NET PRECIPITATION.
RUNOfT AND
EVAPORAt1ON
.LEWm;
FlOW VOLUME. MIWON
GALLONS PER DAY
MOISTURE IN
CONCENTRATB
(0.37)
(NEe)
(??)
FlOW IS NEGUGIBLE
FlOW I~ UNKNOWN
liQIES;
1. REFER TO TABLE 10.2 FOR
WATER BALANCE PARAMETERS.
2. FLOW FROM McQUEEN BOOSTER STATION
INTO BERKELEY PIT EQUALS 0.14 MGD
OF SLURRY OR 0.12 MGD OF WATER ONLY.
Source: ARCO 1994a
(0.21)
(0.34)
(0.15)
YANKEE DOODLE
TAiUNGS POND
(NEe)
ALLUVIUM
(0.17)
NET EVAPORATION
(3.10)
(0 TO 2.68)
(21.82)
(??)
(18.80)
(??)
(4.44)
MR
CONCENTRATOR
(0.37)
(NEC)
CONSUMm
(0.47)
BMFOU WATER BALANCE
flOW DIAGRAM
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This investigation also showed that flow in the alluvial aquifer in the leach pad area is
presently toward the Berkeley Pit. Alluvial water levels in the area adjacent to the Pit
were found to be at least 50 feet higher than the CWL.
.
The Neutralization Investigation was conducted to evaluate the feasibility of using
alkaline mine tailings to treat acidic water present in the Berkeley Pit. Samples of Pit
water were collected to characterize Pit water chemistry. Results showed that the Pit
water is an acidic, moderately oxidizing, sulfate solution with elevated concentrations
of numerous constituents, including aluminum, arsenic, copper, iron, lead,
manganese, and zinc. Levels of aluminum, copper and zinc are more than 1,000
times greater than the chronic water quality criteria for the protection of aquatic life.
Iron is also significantly greater (more than 900 times) than the water quality criteria.
Primary .!T1aximum contaminant levels (MCLs) were exceeded for arsenic, copper,
lead and cadmium.
FEASmll.ITY STUDY
The FS was conducted to identify, screen, develop, and evaluate remedial alternatives
designed to reduce or eliminate the human health and/or environmental risks identified during
the RI. Phase I of the FS included the initial evaluation and screening of treatment
technologies.; Phase II included treatability testing and evaluation of treatment technologies
which survived the initial screening process; and Phase III included the detailed analysis of
remedial alternatives. Three primary treatment technologies and 5 polishing treatment
technologies survived the initial evaluation and screening (Phase I) and 10 technologies were
eliminated. The Phase II testing/evaluation narrowed the technology range to hydroxide
precipitation for primary treatment and reverse osmosis for polishing treatment. These
technologies were then assembled with several flow/process options to form 19 alternatives
for further evaluation. After further screening of alternatives, seven alternativ~s were carried
through the Phase III detailed analysis of alternatives. These seven alternatives were
narrowed down to the preferred alternative presented in the proposed plan.
The specific alternatives evaluated in the FS are presented in Section 8 and details of this
evaluation are presented in Section 9 of this ROD. Significant findings of the Treatability
Study are as follows:
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.
The addition of tailings slurry to the Berkeley Pit to neutralize the acidic Pit water
was found to be infeasible due to the excessive volume of tailings slurry required for
neutralization. The addition of the necessary volume of slurry to the current volume
of water in the Pit would significantly reduce the time to reach the CWL.
.
Water Quality Standards for Silver Bow Creek can be met through a two-stage
hydroxide precipitation and aeration process followed (if necessary) by a reverse
osmosis polishing step.
6. SUMMARY OF SITE RISKS
A baseline Risk Assessment (RA) was conducted by EP A to evaluate potential future human
health and environmental risks associated with mine flooding if no remedial actions are
undertaken at the OU (CDM Federal 1993). The RA was prepared in accordance with EPA
guidance documents (see the RA report for a listing of the specific guidance).
It is important to note that the PRPs have an agreement with EPA (see Enforcement History
and Action section) that directs them to maintain the water level belo~ the 5,410-foot
elevation in the Berkeley Pit and at other designated points in the East Camp System. EPA
and MDHES believe that this agreement precludes any direct impacts on the alluvial aquifer
and/or Silver Bow Creek from contamination originatin~ from the Pit System. However, in
the absence of compliance with this agreement and any. remedial actions, contaminated water
in the Pit System could eventually flow into the alluvial aquifer (with eventual flow into
Silver Bow Creek) or may overflow to Silver Bow Creek. In this evaluation of the no-action
alternative, it was assumed that the CWL in the Pit System would be exceeded. The risks
associated with the no-action alternative must be evaluated as a basis for comparison with
other remedial alternatives.
CONTAMINANTS OF CONCERN
The contaminants of concern (COCs) in groundwater and surface water that were considered
in the human health RA were arsenic, cadmium, lead, sulfate, .and zinc. The COCs
considered in the evaluation of ecological risks were aluminum, arsenic, cadmium, copper,
iron, lead and zinc. These contaminants exhibit carcinogenic and/or toxic characteristics.
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They are found at elevated levels in the Berkeley Pit water. The estimated future
concentrations of the COCs on which the RA was based are presented in Table 3.
HUMAN HEALTII RISK ASSESSMENT
The human health risk assessment was developed from surface water and groundwater
concentrations measured during the RI for three future discharge scenarios:
1.
A drinking water well located in the alluvial aquifer containing water discharged from
the Berkeley Pit,
2.
Surface water in Silver Bow Creek resulting from discharge of Pit water to the
alluvial aquifer and eventually to the creek, and
3.
Surface water in Silver Bow Creek resulting from Pit overflow directly into the creek.
HUMAN EXPOSURE ASSESSMENT
Exposure assessment is the estimation of magnitude, frequency, duration, and route of
exposure to COCs. This includes the estimation of exposure point concentrations and the
development of chemical intake estimates.
Since current exposure pathways do not exist, current exposure scenarios were not evaluated
in the RA. However, exposure could occur to future residents of the area if there was a
release of water from the contaminated bedrock system into the alluvial system and Silver
Bow Creek. A future residential scenario was developed for the RA that assumes no
restriction of access to Silver Bow Creek or the alluvial aquifer as a source of drinking
water. Receptors evaluated in the RA included lifetime residents and children. Exposure
pathways included 1) direct ingestion of contaminated drinking water (groundwater or surface
water), 2) incidental ingestion of contaminated surface water during recreational activities,
and 3) dermal absorption of contaminated surface water during recreational activities.
Exposure point concentrations were developed previously for the three discharge scenarios
(Table 3). The magnitude of exposure was then estimated by calculating chronic daily
22
L!.
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TABLE 3
ESTIMA1'ED FUTURE CONCENTRATIONS IN TilE ALLUVIAL AQUlF~R DOWNGRADIENT OF TilE BERKELEY PIT
AND IN SILVER BOW CREEK GIVEN TUREK PIT WATER DlSCUARGE SCENARIOS
Chemica) Concentrations
Discharge Scc:nario Aow Regime Aluminum Arsenic Cadmium Copper Iron Lead Zip~ Hardness Sulfate pH
("gIL) (pgIL) (pgIL) ("g/L) (pgIL) (pglL) (pgIL) (mgIL) (mglL) (Standard
Units)
Scenario No. I Not 262,000 1,010 2,020 111,00 1,021,500 134 526,000 2,164 6,530 3.2
Alluvial Drinking Applicable
Water Well
Scenario No.2 Chronic' 21,840 118 210 18,810 94,050 10 55.830 412 183 5.11
Discharge to ------------ ---------- ------- --------- ------- --------- ------- -------- --------- -------- -----------
Alluvial Acute1 49,540 206 380 33,440 116,810 10 99,380 630 1361 4.94
Aquifer
Scenario No.3 Low Flow). 80,150 332 620 54,540 302,410 20 162,140 941 2192 4.65
Pit Overflow Chronic
------------ ---------- ------- --------- -------- --------- ------- -------- --------- -------- -----------
Low Flow. 122,300 500 940 82,600 413,580 30 245,570 1359 3293 4.30
Aeute
------------ ---------- ------- --------- ------- --------- ------- -------- --------- -------- -----------
lIi,h Flow.. 100,430 412 110 67,800 383,110 20 201,440 1139 2712 4.48
Chronic
------------ ---------- ------- --------- ------- --------- ------- -------- --------- -------- -----------
High Flow- 143,150 581 1,110 91,090 558,470 30 288,590 1547 3866 3.98
Acute
Source: CDM Federal 1993.
Chronic refers to potential in-stream concentrations during average streamflow conditions (14.1 cfs).
Acute refen to potential in-stream cuncentrations during the 1-day, IO-year low flow event (1.23 cfs).
Low Aow refers to the lower end of the discharge range estimated for the Berkeley Pit overtopping scenario (4 mgd =6.2 cfs).
High Aow refers to the upper end 01' the discharge range estimated for the Berkeley Pit overtopping .ceitario (5.6 mgd=8.6 cfs).
.Bold print in I10w regime represents the concentrations used in the risk .assessment Cor discharge to the alluvial aquifer and pit overflow into Silver Bow Crc:c:k.
"gIL = micrograms per liter
mglL = milligrams per liter
CFS = cubic feet per second
mgd = million gallons per day
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intakes (CDIs) for each exposure pathway. To calculate CDIs, many assumptions were made
in accordance with EP A guidance. These intakes were then compared to toxicity values to
quantify risks for each exposure pathway. Lead intake estimates for children were estimated
using the Integrated Exposure/Uptake/Biokinetic (IEUBK) lead model.
. HUMAN TOXICITY ASSESSMENT
The toxicity assessment examined the potential for each COC to cause adverse effects in
exposed individuals. The assessment also provided an estimate of the dose-response
relationship bet~een the degree of exposure to a COC and adverse effects. Criteria for
carcinogens are presented as cancer slope factors and criteria for noncarcinogens are
presented as reference doses, with the exception of lead, which was evaluated using the EP A
IEUBK lead model. A thorough explanation of the health effect criteria for potential
carcinogens and non-carcinogens and the toxicity profiles for the COCs are presented in the
Baseline Risk Assessment (CDM Federal 1993). A summary of these is presented below.
Health Effects Criteria For Potential Carcinogens'
Cancer slope factors are developed by EP A's Carcinogen Assessment Group (CAG) for
potentially carcinogenic chemicals. In the case of arsenic, the slope factor was derived from
the results of human epidemiological studies. The cancer slope factor describes the increase
in an individual's risk of developing cancer over a 70-year lifetime per unit of exposure.
When the cancer slope factor is multiplied by the lifetime average dose of a potential
carcinogen, the product is the upper-bound lifetime individual cancer risk associated with
exposure at that dose. This calculated risk is an estimate of the increased likelihood of
cancer resulting from exposure to a COCo These estimates of the upper limits on lifetime
risk are unlikely to underestimate risks. Therefore, while the actual risks associated with
exposures to potential carcinogens are unlikely to be higher than the risks calculated using a
cancer slope factor, they could be considerably lower.
EP A also assigns weight-of-evidence classifications to potential carcinogens. Under this
system, arsenic is classified as a Group A chemical, or a human carcinogen. This
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classification indicates that there is sufficient evidence to suppon the causal association
between exposure to arsenic in humans and cancer. Cadmium has been classified as a Group
Bl or probable human carcinogen for inhalation exposure only. This classification is for
chemicals with sufficient evidence of carcinogenicity in animals but limited evidence in
humans. Lead has been classified as a Group B2 or probable human carcinogen. This
means that there is sufficient evidence of carcinogenicity in animals, but inadequate evidence
of carcinogenicity in humans. Zinc has been assigned classification D, which indicates that
the evidence for carcinogenicity in animals is inadequate.
-
Health Effects Criteria For Noncarcinoeens
Health effects criteria for chemicals exhibiting noncarcinogenic effects are generally
developed using reference doses (RIDs) developed by the EPA RID Work Group, or RIDs
obtained from Health Effects Assessment Summary Tables (HEAST). The chronic RID is an
estimate of the daily exposure to the human population (including sensitive subpopulations)
that is likely to be without an appreciable risk of deleterious effec~ during a lifetime. These
RIDs are usually derived either from human studies involving workplace exposures or from
animal studies, and are adjusted using uncertainty factors. The uncertainty factors used in
developing RID.s use conservative assumptions based on the differences between the
environmental human exposure situation and the animal bioassay from which the data were
derived. Due to the conservative nature of these factors, a margin of safety is implicit in
their use. The RID provides a benchmark to which chemical intakes by various routes (e.g.,
via exposure to contaminated environmental media) may be compared.
Human Toxicity Profiles
The major adverse health effects associated with lead are alterations in blood and nerves.
Exposure to high levels of lead will result in severe lead poisoning, which may cause coma,
convulsions, profound and irreversible mental retardation, seizures, and even death. Less
severe effects at lower dosages include damage to receptor nerves, anemia, delayed cognitive
development, reduced IQ,. high blood pressure, and impaired hearing. Even smaller dosages
have been implicated in enzyme inhibition, changes in red blood cell chemistry, interference
25
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with Vitamin D metabolism, cognitive dysfunction in infants, changes in the ability of nerves
to transmit signals, and reduced childhood growth. Because their nervous systems are still
developing, fetuses and children 0-3 years of age are most affected by the lower doses and
are, therefore, the most sensitive population.
Arsenic is also a well-known poison and human carcinogen. Chronic oral exposure of
humans to arsenic can produce toxic effects on the entire nervous system, age spots and
warts, thickening and darkening of the skin, skin lesions, blood damage, and cardiovascular
damage. Ingestion of arsenic has been linked to a form of skin cancer and mor~ recently to
bladder, liver, and lung cancer.
Cadmium, when ingested, has been shown to be associated with kidney disease, bone
damage, high blood pressure, anemia, and suppression of the immune system.
Ingestion of large amounts of sulfate can result in diarrhea, catharsis,' and possible
dehydration. Infants appear to be a sensitive subpopulation.
Acute toxicity of ingested zinc results in gastrointestinal distress and diarrhea. Long-term
zinc ingestion may result in copper deficiency and anemia. Liver and kidney effects have
been observed in experimental animals after chronic exposure to zinc.
HUMAN HEALTH RISK CHARACTERIZATION
Risks from all exposure routes and pathways were combined to provide an estimate of total
carcinogenic and. noncarcinogenic health risks. A detailed analysis of the risks for these
pathways is presented in the RA. It should be noted, however, that the direct ingestion of
contaminated drinking water is the predominant exposure pathway. Incidental ingestion and
dermal contact were much less significant pathways. For lead, estimated blood lead levels
were compared to blood lead levels considered to be of concern to human health.
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Carcino~enic Risks
The RA estimated the excess lifetime cancer risk from exposure to arsenic at the BMFOU.
EPA's acceptable cancer risk range for Superfund sites is from one in 10,000 (lE-04) to one
in 1,000,000 (lE-06) additional probability that an individual may develop cancer over a 70-
year lifetime. EPA's (Superfund guidance) maximum acceptable risk probability is one in
10,000 (lE-04). A risk of one in 10,000 means that one person out of 10,000 could develop
cancer as a result of a lifetime exposure to the site contaminants. This refers to the
incremental risk that is above and beyond the chance that an individual may develop some
form of cancer from other sources.
The estimated lifetime arsenic cancer risks for the exposure pathways evaluated in the RA
are summarized in Table 4. Under both the reasonable maximum exposure (RME) and the
central tendency exposure (CTE), the RA (CDM Federal 1993) predicted that all future
exposure scenarios would result in cancer risks from arsenic that exceed EPA's maximum
risk probability of lE-04. The RME is the maximum exposure that is reasonably expected to
occur for an individual while the CTE uses exposure parameters that represent average
exposure.
Noncarcino~enic Risks
To evaluate the potential for adverse noncarcinogenic effects, CDls were compared to
reference dose values. A CDI:RID ratio (hazard quotient) exceeding one indicates that
adverse effects could occur. A Hazard Index (HI) is equal to the sum of the hazard quotients
for all COCs for a specific pathway/source. When the HI exceeds one, there is a potential
for adverse health effects to . occur for that pathway/source combination.
Noncarcinogenic risks from exposure to arsenic, cadmium, sulfate, and zinc are also
summarized in Table 4. The RA showed the HI to exceed one for all receptors and exposure
pathways evaluated, indicating the potential for future adverse health effects. These were
found to be mainly associated with exposure to arsenic and cadmium.
27
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TABLE 4
SUMMARY 011 POTENTIAL CARCINOGENIC AND NONCARCINOGENIC RISK
BU1TE MINI~ FLOODING OI"ERABLE UNIT
future exposure I'athways and Contaminant Sources ~!I Jgenic Noncarcinogenic Risk1
.isk'
Lifetime Reasonable Maximum Exposure (RME)
Drinking Alluvial Groundwater plus the Incidentaliligestion of Surface Water (source: alluvial groundwater discharge) S.27E-03 3.93E+02
Drinking Surface Water (source: alluvial groundwater discharge) plus the Incidental Ingestion of Surface Water (source: S.8IE-04 4.3SE+OI
alluvial groundwater discharge)
Drinking Surface Water (source: Berkeley Pit overl1ow) plus the Incidental Ingestion or Surrace Water (source: Berkeley 2.03E-03 I.SbE+02
Pit overflow)
Drinking Alluvial Groundwater plus the Incidental Ingestion of Surrace Water (source: Berkeley Pit overOow) S.27E-03 3.96E+02
Lifetime Central Tendency Exposure (CTE)
Drinking Alluvial Groundwater plus the Incidental Ingestion of Surface Water (source: alluvial groundwater discharge) \.OIE-03 2.16E+02
Drinking Surface Water (source: alluvial groundwater discharge) plus the Incidental Ingestion of Surface Water (source: 1.I1E-04 2.33E+OI
alluvial groundwater discharge)
Drinking Surface Water (source: Berkeley Pit overOow) plus the Incidentullngestion or Surrace Water (source: Berkeley 3.89E-04 8.33E+01
Pit overflow)
Drinking Alluvial Groundwater plus the Incidental Ingestion of Surface Water (source: Berkeley Pit overOow) \.01 E-03 2.16E+02
Source: CDM Federal 1993.
Arsenic carcinogenic risk.
Each figure is the total hazard index and represents the sum of the individual risks from anenic, cadmium, sulfate and zinc ror the specific pathway/source combination.
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Lead Exposure
Lead exposure was evaluated by estimating future blood-lead levels in children using EPA's
IEUBK Lead Model. EP A's acceptable level is 95 percent of the exposed population with a
blood-lead level below 10 micrograms per deciliter (JLg/dl). The RA showed that if
contaminated bedrock aquifer water was discharged to the alluvial groundwater and used as
drinking water, over 50 percent of the exposed children would have a blood-lead level
greater than lOJLg/dl. Predicted percentages of children with blood-leads greater than
lOJLg/dl for the incidental ingestion of surface water from the alluvial groundwater and the
Pit overflow ~ ~~Iiarge scenarios were 0.7 and 2.25 percent, respectively.
ECOLOGICAL RISK ASSESSMENT
The ecological risk assessment qualitatively evaluated potential risks to aquatic receptors by
comparing potential surface water metals concentrations to Ambient Water Quality Criteria
(A WQc) for the protection of freshwater aquatic life.
POTENTIAL ECOLOGICAL RECEPTORS
Aquatic Communities
Silver Bow Creek adjacent and downstream from the BMFOU does not support a fisheries
population. Westslope cutthroat trout and bull trout are reported to have once been caught in
the vicinity of Butte prior to intensive mining activities. Mining related wastes still prevent
the establishment of a fishery in Silver Bow Creek.
Five species of trout have been recorded within the Silver Bow Creek watershed and,
therefore, were selected as potential ecological receptors. fhese'include the westslope
cutthroat trout, rainbow trout, brook trout, bull trout, and brown trout. Although no 'trout
species are found in Silver Bow Creek due to historical metals contamination in this area,
there is potential for these species to occur if water quality in Silver Bow Creek improves
due to their presence in associated tributaries to Silver Bow Creek. A viable aquatic
community, including fish, does occur in Blacktail Creek, a tributary to Silver Bow Creek
just above the study area. Blacktail Creek contributes the largest flow to the creation of
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Silver Bow Creek. Fish and other aquatic animals may move downstream from Blacktail
Creek into the study area.
Benthic invenebrate communities have re-established themselves within Silver Bow Creek
since the cessation of direct mine process waste water discharges. Mayflies, caddis, and
stoneflies have been collected, although they demonstrate low density and limited diversity.
The Aquatic Resources Injury Assessment Repon for Upper Clark Fork River Basin (June,
1993) stated that the U.S. Fish and Wildlife Service (USFWS) and University of Wyoming
(1992) measur~ hazardous substances in benthic invenebrates in Silver Bow Creek near
Warm Springs Ponds. Although the concentrations of hazardous substances in the
macroinvenebrates collected were high, macroinvenebrates would be expected to flourish in
a remediated Silver Bow Creek, as they are found in nearby tributaries which are not
contaminated with mining wastes.
Aquatic vegetation and algae have been observed in and collected f!om Silver Bow Creek. A
survey conducted in 1984 indicated the presence of an emergent aquatic grass, downstream
of the BMFOU in Silver Bow Creek. However, the current status of aquatic vegetation is
not known.
Terrestrial Communities
Although terrestrial ecological risks were not evaluated in the RA, the environmental setting
for terrestrial communities is presented in the RA. No terrestrial communities within the
BMFOU have been identified as critical habitat or communities of special concern. No rare .
or endangered plants were identified within the BMFOU or downstream of this area.
Vegetation growing adjacent to Silver Bow Creek within the study area is limited to common
willows and grasses. Shrubs indicative of dry conditions are found throughout the study
area. The USFWS has stated that there are no threatened or endangered wildlife species
present in the BMFOU or in the near vicinity. Although no wildlife surveys have been
conducted within the BMFOU, it is anticipated that wildlife typical of disturbed and rural
residential areas would be found. This could include medium-sized mammals such as rabbits
-------
and foxes, and small mammals that are commonly found in disturbed areas such as field mice
and rats. Also included in this category would be songbirds, waterfowl, and birds of prey.
Downstream of the study area, as the impacts from human activities decrease, larger
mammals such as elk, deer, and coyote may be found.
ECOLOGICAL EXPOSURE P A THW A YS
The RA evaluated the potential risk to aquatic receptors in Silver Bow Creek and in offsite
reference locations in the event that contaminated Berkeley Pit System water discharged to
Silver Bow Creel<:. In the event that the water level in the Pit System was allow..d to rise
unrestricted, this contaminated water could reach Silver Bow Creek by flowing through the
alluvial aquifer and/or by overflowing the Pit rim. Under either scenario, the contaminated
water entering Silver Bow Creek would have approximately the same concentration of
contaminants as the Berkeley Pit System water.
The primary exposure route for aquatic receptors is ingestion of surface water/sediment,
aquatic vegetation, and contaminated prey such as macroinvenebrates. In accordance with
EPA guidance, sediment and surface water were considered as an integrated exposure
pathway because of the complex chemical equilibrium between these two media. However,
for risk assessment, only surface water was evaluated as a potential exposure pathway for
aquatic life. This is sufficient to demonstrate the severity of the problems that this
contaminated water presents to ecological receptors.
POTENTIAL EXPOStJ1ffi CONCE~lM7IONS AND REGULATORY CRI1ERIA.
Table 3 presents the predicted concentrations oi the COCs in Silver Bow Creek water under
the combination of flow regimes (average [chronic] and low [acute]) and the ranges of water
flow rates from the Berkeley Pit System. For example, if the Berkeley Pit were to discharge
at a high rate and the flow in Silver Bow Creek was at the 7-day, lo-year low, then the
concentration of copper in the creek is predicted to be 97,090 p.g/L.
31
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. ECOLOGICAL RISK CHARACTERIZATION
Table 5 compares the estimated concentrations of the COCs in Silver Bow Creek if Berkeley
Pit System water discharged to the creek to the EPA hardness-adjusted Ambient Water
Quality Criteria (A WQc). The two discharge scenarios used were discharge through the
alluvium and from the Pit overflowing. Impacts to the aquatic ecosystem were evaluated in
the RA (CDM Federal 1993) for the alluvial discharge scenario by comparing the Silver Bow
Creek surface water concentrations under average (Le., chronic) flows to the hardness-
adjusted acute and chronic A WQC. For the Pit overflow scenario, the estimated high flow
from the Berkeley Pit was combined with the average Silver Bow Creek flow and then
compared to the hardness-adjusted acute and chronic A WQC.
Results of the RA indicate that if Berkeley Pit System water were allowed to discharge to
Silver Bow Creek the concentration of the cacs in the creek would exceed the A WQC
. .
. (Table 5). The impact to the down gradient aquatic ecosystems under either discharge
scenario would be catastrophic in both nature and extent. Trout are particularly sensitive to
copper and zinc (see Toxicity section of the RA). If Pit water discharged through the
alluvium to Silver Bow Creek the copper (18,810 ",g/L) and zinc (55,830 ",g/L)
concentrations in the creek could be more than 480 and 164 times the chronic A WQC,
respectively. This concentration of copper and zinc would preclude the establishment of a
viable. fishery in Silver Bow Creek.
HUMAN REALm AND ENVIRONMENTAL RISK ASSESSMENT SUMMARY
The RA focused on the potential risks associated with alluvial groundwater and surface water
contaminated with Berkeley Pit water in a future residential scenario, and on potential risks
to aquatic life. The results of the RA showed that future risks to human health and the
environment exist above the level considered acceptable to EP A if no remedial actions are
taken for this au. The major future health risk to area residents is associated with the
ingestion of contaminated groundwater or surface water. The major future ecological risk is
associated with exceedences of standards intended to protect aquatic life. The results .of the
RA indicate that to protect human health and the environment, it will be necessary to prevent
32
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TABLE 5
ESTIMATED FUTURE t_ONCENTRATIONS IN SILVER BOW CREEK AND HARNESS-ADJUSTED AMBIENT WATER QUALITY CRITERIA
. BUTrE MINE FLOODING OPERABLE UNIT
,
Discharge Plow Regime Chemical Concentrations
Aluminum Cadmium Copper Iron Lead Zinc Hardness
w21L) fu2lL) ~21L) (pglL) (pg/L) (pg/L) (mg/L)
Through the Alluvial Chronic' 21,840 210 18,810 94,050 10 55,830 412
Aquifer
---------------------- --------------- ------------ ----------- ----------- ---------- ----------- ---------
From Pit Overflow Hi2h Flow-Chronic' 100,430 110 61,800 383,110 20 201,440 1139
Acute A WQC 150 19 65 1,000 411 380 4001
Ambient
---------------------- --------------- ------------ ----------- ----------- ---------- ----------- ---------
Water Quality 81 39 4001
Criteria Chronic A WQC 3.4 1,000 19 340
Source: CDM Fcderall993 and EPA Ambient Water Quality Criteria.
Chronic refers to potential in-stream concentrations during average streamflow conditions (14.1 ds).
High Flow refers to the upper end of the discharge range estimated for the Berkeley Pit ove~opping scenario (5.6 mgd=8.6 cfs).
The maximum allowable hardness for A WQC adjustment is 400 mglL.
pglL = micrograms per liter
mglL = milligrams per liter
cr. = cubic fed per sccond
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water in the Pit System from escaping through the alluvial aquifer, or by overland flow, and
ultimately discharging into Silver Bow Creek.
7. REMEDIAL ACTION OBJECTIVES
EPA and the State's overall remedial action objective for this OU is to prevent human and
aquatic exposure to contaminated groundwater and surface water. This objective was
developed based on evaluations of the site RA and ARARs and will be met by accomplishing
the following specific remedial action objectives:
-
1.
Ensuring that the CWLs (i.e., the safe water levels) for the Pit System (5,410
feet, USGS datum) and the West Camp System (5,435 feet, USGS datum) are
not exceeded 50 that contaminated mine water is contained and does not
discharge to the alluvial aquifer or Silver Bow Creek,
2.
Ensuring that treated water discharged to the Silver Bow Creek drainage meets
State of Montana and other pertinent water quality standards,
3.
Implementing institutional controls on the public's access to contaminated
bedrock aquifer water to ensure the protection of public health, and
4.
Implementing a comprehensive monitoring program to verify the
protectiveness of the CWLs and to ensure that contaminated water is being
contained. .
8. DESCRIPTION OF ALTERNATIVES
Nineteen remedial alternatives for addressing the mine flooding problem were evaluated in
the screening portion of the FS. Seven of these remedial alternatives (1, 2/3, 4/5, 6/7) for
addressing the mine flooding problem were retained for detailed analysis in the FS. The
other 11 alternatives were eliminated because of exorbitant costs or implementability
limitations.
The alternatives were developed based on water treatment technologies and flow options that
were selected via the initial screening process and subsequent treatability testing. Each
alternative was divided into time periods that included current mining, post-mining, and the
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period after which the CWL is approached in the Pit System. For the purpose of the FS
analysis, current mining was assumed to continue until 2005; and the post-mining period was
assumed to extend from 2006 to the time when the CWL is approached for the specific
remedial alternative. These assumptions are in no way meant to be a prediction of future
mining, rather they are used as uniform assumptions that allow the comparative evaluation of
remedial alternatives.
The estimated costs presented for each alternative reflect the net present value of capital and
annual operating.:and maintenance (O&M) costs. With the exception of the no-action
alternative, capital costs include the costs for constructing a treatment facility and sludge
. disposal area, and purchasing the required pumps and piping. O&M costs for the
alternatives (excluding no-action) include costs for the monitoring programs, maintaining the
treatment facility, pumps and. pipelines, and purchasing treatment supplies and chemicals.
It should be noted that costs associated with the alternatives presented in the FS do not
include the cost of controlling the West Camp System (present Worth of $1.7 million). An
alternatives analysis (Engineering Evaluation/Cost Analysis - CDM 1989) and decision
document (Action Memorandum - see Enforcement History and Actions section) for
mitigating the West Camp was. prepared by EPA.
Each alternative includes institutional controls (ICs). These ICs include local government
land use and development regulations and controls on groundwater access. For the post-
mining period, institutional controls are the same as listed above.and should complement
dedicated development and mine reclamation. Currently, Butte-Silver Bow County
Government is developing an institutional control package for all Superfund activities within
the County. EPA and the State plan to work with Butte-Silver Bow in the development of
. .
these institutional controls to ensure that there is no inappropriate use of contaminated
bedrock aquifer water that would threaten human health or the environment. It is EP A . s and
the State's preference that any needed institutional controls be implemented through local
government. In the event that ICs cannot be implemented through local government, state
35
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and federal authority to implement needed ICs will be examined. The public will be
included in all discussions concerning implementation of ICs.
A comprehensive monitoring program would be implemented under all alternatives. This
program would monitor surface water and groundwater (alluvial and bedrock) quality and
levels in the Pit System and the West Camp System in shafts and other designated monitoring
points. Based on this information, the Agencies will ensure that water levels do not rise
above the CWLs. Monitoring program data would be used to ensure that treatment facilities
are in place an~ operating prior tp mine waters reaching the CWL and to provide information
for assessing the impact of the rising waters. Monitoring program data will be used to verify
the protectiveness of the CWLs.
Each alternative, except the no-action alternative, contains variations of pumping and/or
treatment schemes necessary ~o maintain the Pit System and West Camp System waters
below the CWLs. The alternatives are summarized below.
ALTERNATIVE 1: No Action-
TOTAL COST: SO
Under this alternative, no remedial actions would be taken to control mine flooding. During
the current mining period, about 1.5 mgd of water from Horseshoe Bend would flow to the
Berkeley Pit, and 0.9 mgd would be pumped to the leach pads or tailings pond. In the post-
mining period, 2.4 mgd of Horseshoe Bend water would flow to the Pit, and the Pit System
CWL would be approached in the yc:;ar 2015. Evaluation of this alternative is required by
the NCP and is evaluated only as a basis for comparison as- it does not provide protection of
human health and the environment. The risks to human health and the environment are
summarized in Section 6 of the ROD.
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ALTERNATIVE 2/3:
TOTAL COST:
No Change in the Current Flow Regime During Active Mining;
No Control of Horseshoe Bend Water During Post Mining; A
Comprehensive Monitoring Program; Treatment as the Pit
System CWL is Approached.
Disposal of Treatment Sludge in Berkeley Pit (Alternative 2) -
$35.91 million
Disposal of Trea~ment Sludge Onsite (Alternative 3) - $42.7
million
Under this combined alternative, limited actions would be taken to control mine flooding
during the mining and post-mining periods. A comprehensive monitoring program and
institutional conkols would be implemented. As with Alternative 1, the Pit System CWL
would be approached in 2015, at which time water from the Pit System and Horseshoe Bend
would be pumped to a treatment plant for primary treatment by hydroxide precipitation and
aeration, followed, if neces.sary, by polishing treatment by reverse osmosis. A total of 8.48
mgd (2.4 mgd from Horseshoe Bend and 6.08 mgd from the Pit System) would be pumped
for treatment. Treated water would be discharged to Silver Bow Creek, and treatment sludge
would be disposed of in the Pit or in an onsite disposal facility. The water level in the Pit
System would be maintained below the CWL.
The differences in the costs for this alternative are dependent upon the option chosen for
disposal of treatment sludge. If the disposal option involves an onsite facility, less water
(only 4.35 mgd) would need to be pumped to stabilize the water level in the Pit System.
ALTERNATIVE 4/5:
TOTAL COST:
Change Flow Scheme to Control Horseshoe Bend Water During
Active Mining; No Control of Horseshoe Bend Water During
Post-Mining, A Comprehensive Monitoring Program; Treatment
as the Pit System CWL is Approached. .
Disposal of Treatment Sludge in Berkeley Pit (Alternative 4) -
$27.63 million
Disposal of Treatment Sludge Onsite (Alternative 5) - $32.33
million
Under this combined alternative, 2".4 mgd of Horseshoe Bend water would be pumped to
Yankee Doodle Tailings Pond during active mining operations. Lime would be added to the
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tailings at the MR Concentrator prior to discharge into the pond in order to increase the
neutralization capacity of the tailings for the Horseshoe Bend water. A comprehensive
monitoring program and institutional controls would be implemented.
During the post-mining period, no actions would be taken to control mine flooding, and 2.4
mgd of Horseshoe Bend water would flow to the Pit. The Pit System CWL would be
approached in the year 2018, at which time water from the Pit System and Horseshoe Bend
would be pumped to a treatment plant as described for Alternative 2/3. The water level in
the Pit System would be kept below the CWL.
The differences in the costs for this alternative are dependent upon the disposal choice.
Treatment sludge would be disposed of in the Pit or in an onsite disposal facility.
ALTERNATIVE 617:
Pennanent Control and Treatment of Horseshoe Bend Water; A
Comprehensive Monitoring Program; Treatment Initiated Upo~
Suspension of Mining; Expanded Treatment as the .Pit System
CWL is Approached.
TOTAL COST:
Disposal of Treatment Sludge in Berkeley Pit. (Alternative 6) -
$41.82 million .
Disposal of Treatment Sludge in an Onsite Facility (Alternative
. 7) - $52.77 million
Under this combined alternative, 2.4 mgd of Horseshoe Bend water would be pumped to the
Yankee Doodle Tailings Pond during mining, as described for Alternative 4/5. Primary and
polishing treatment (of Horseshoe Bend water only) would begin during the post-mining
, period at a newly constructed treatment plant, with treated water discharged to Silver Bow
Creek and treatment sludge disposed of in the Pit or in an onsite facility. Treatment would
be in tWo steps: hydroxide precipitation and aeration would remove most metals, followed,
if necessary, by reverse osmosis as a polishing treatment to meet S~te of Montana surface
water quality standards.
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The Pit System CWL would be approached in 2022, at which time water from the Pit System
(6.08 mgd) would also be treated at an expanded treatment facility. The water level in the
Pit System would be kept below the CWL.
The differences in the costs for this alternative are dependent upon the selected place for
disposal of treatment sludge.
9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP requires that each alternative be evaluated in terms of nine criteria, which are
divided into three categories as listed below.
The first category includes the threshold criteria:
1.
Overall protection of human health and the environment; and
2.
Compliance with ARARs.
The second category includes the primary balancing criteria:
3.
Long-term effectiveness and permanence;
4.
Reduction of toxicity, mobility, or volume through treatment;
5.
Shon-term effectiveness;
6.
Implementability; and
7.
Costs.
The third category includes the modifying criteria:
8.
State acceptance; and
9.
Community acceptance.
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The selected alternative must meet the first two criteria and provide the best balance of the
five primary balancing criteria. EP A and the State evaluated and compared the seven
remedial alternatives described in Section 8 based upon their expeCted compliance with these
criteria. EPA and the State believe that all the alternatives (except the no-action alternative)
meet the above criteria to some degree and provide a reasonable range of options for
addressing the mine flooding problem. EP A and the State selected Alternative 6/7 with
modification as the remedy for the Butte Mine Flooding au. This evaluation is briefly
described below.
CRITERION 1: OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT
This criterion addresses whether a remedy is protective of human health and the
environment. It also .describes how potential no-action alternative risks estimated for each
pathway are eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.
All the alternatives, except Alternative I, ar~ protective of human health and the environment
through the containment of contaminated water in the au, treatment of the contaminated
water prior to discharge to Silver Bow Creek, and the control of access to contaminated
groundwater.
CRITERION 2: COMPLIANCE WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
This criterion addresses whether a remedy will comply with identified Federal and State
environmental laws and regulations and/or whether there is a basis for a waiver from any of
these laws. Applicable requirements must be met to the full extent requir~ by the law.
Alternative I does not meet Federal and State ARARs. The remaining alternatives will meet
Federal and State ARARs, except Federal Primary Drinking Water Standards and State
groundwater quality standards for the bedrock aquifer. EPA intends to waive these
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requirements based on the determination that compliance with these standards is technically
impracticable from an engineering perspective (see Technical Impracticability evaluation -
Appendix 2). Treated water discharged to Silver Bow Creek will meet State discharge
requirements. Sludge produced would be disposed of in compliance with State solid and
hazardous waste regulations.
CRITERION 3: LONG- TERM EFFECTIVENESS AND PERMANENCE
This criterion refers to expected residual risk and the ability of a remedy to maintain reliable
protection of human health and the environmen~ over time once remediation g:.,::ls have been
met.
Alternatives 4/5 and 6/7 achieve the greatest degree of long-term effectiveness and '
, permanence because Horseshoe Bend water is kept from' entering the Pit. Alternative 6/7
provides greater long-term effectiveness than the other alternatives'because water control and
treatment will be implemented on a permanent basis. The treatment component would be
implemented 10 to 13 years sooner than for Alternatives 2/3 and 4/5, and the water control
component would be implemented, almost 20 years sooner than for Alternative 2/3.
Alternative 4/5 is a "stop-gap" alternative that involves control of Horseshoe Bend water
during mining, but no control of this water until the Pit System CWL is approached. The
no-action alternative provides neither long-term effectiveness nor permanence.
CRITERION 4: REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREA TMENT
This criterion refers to the degree that an alternative reduces toxicity, mobility, and volume
of contamination.
All alternatives (except the no-action alternative) provide for the active treatment of
contaminated water and ensure that the water levels in the Pit and West Camp Systems are
maintained below the CWLs. Negative impac~ to the environment at the OU would not
occur unless CWLs are reached or exceeded. Assuming maximum inflow to the Pit System
41
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from the bedrock and alluvial aquifers, all the. alternatives would be equally effective at
reducing the toxicity, mobility, or volume of contaminated water. However, if additional
post-mining inflow controls (e.g., control of clean upgradient flows) are employed and
. bedrock aquifer inflow does decline as predicted, Alternative 6/7 has the potential to stabilize
the Pit System water at a lower elevation compared to the other alternatives. In this way,
Alternative 6/7 would be more effective at reducing the total volume of contaminated water
accumulating in the Pit System than the other alternatives.
CRITERION 5:- SHORT-TERM EFFECTIVENESS
This criterion addresses the period of time needed to complete the alternative and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation period. None of the alternatives would result in adverse
short-term effects.
CRITERION 6: IMPLEMENT ABILITY
Implementability refers to the technical and administrative feasibility of an alternative,
-including availability of materials and services needed to implement a particular option. All
the alternatives are readily implementable. However, EPA and the State believe that
Alternative 6/7 is more implementable than the other alternatives. Construction, startup, and
operation of a smaller, expandable treatment plant to handle contaminated water when mining
operations are suspended allows 'for greater opportunity to address unknown contingencies
(i.e., unanticipated.flow patterns or release from the bedrock system), rather than waiting to
build a larger treatment plant when the Pit System CWL is approached.
CRITERION 7: COSTS
Cost evaluates the estimated capital costs and O&M costs of each Alternative for 30 years.
Alternative 4/5 is the least expensive ($27.6-3~.3 million), while 6/7 ($41.8-52.8 million)
has the highest associated costs. Alternative 4/5 is less expensive because it involves
handling of Horseshoe Bend water within the mining process and does not mandate control of
Horseshoe Bend water if mining is suspended until the Pit System CWL is approached. In
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contrast, Alternative 6/7 mandates the immediate and permanent control of Horseshoe Bend
inflow (currently 2.4 mgd) to the Pit System.
CRITERION 8: STATE ACCEPTANCE
This criterion indicates the State's preferences regarding the various alternatives. Alternative
6/7 has a higher level of State acceptance than the other alternatives. The State has indicated
general suppon for the major objective of Alternative 6/7 because it involves early and
continual/permanent control (i.e., control during any suspension of mining plus post-mining
control) of 2. . '6d of water inflow to the Berkeley Pit System. However, the State has
recommended flexibility in the specifics of Alternative 6/7, such as method of treatment,
discharge point, point of control, etc.
CRITERION 9: COMMUNITY ACCEPTANCE
Public comment indicated that the community preferred Alterative 6/7 over the other final
five (5) alternatives. EP A and the State received considerable public comment opposing
certain aspects of the preferred alternative presented in the Proposed Plan. The major
comments revolved around 3 issues: 1) the designated critical water level (CWL); 2) the
treatment of water sooner rather than later; and 3) the use of innovative treatment/metals
recovery technology, The public generally commented that a lower critical water level is
necessary to account for uncertainties relating to the impact of the rising water in the system. .
Considerable comment was also received concerning the use of innovative treatment/metals
technology. Numerous commenters expressed concern about the amount of sludge generated
by the hydroxide precipitation/aeration treatment process selected and voiced their opinion
that a technology which reclaims metals from the Berkeley Pit System is preferable.
SYNOPSIS OF ALTERNATIVES
Alternative 6/7, the alternative selected by EPA and the State (with modifications) utilizes
technologies that are readily available and requires typical construction techniques. During
construction, risks to workers, to the community, and to the environment would be reduced
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by employing engineering, health, and safety controls.
Protecting human health, including offsite protection. at the OU is achieved by: 1)
maintaining the water levels in both the Pit System and the West Camp System below the
CWLs and treating any water to be discharged; 2) implementing a comprehensive monitoring
\
program; and 3) implementing institutional controls to prevent water use.
Overall compliance with most ARARs at the OU would be met by the selected alternative.
Chemical-spe" . ARARs for water discharged to Silver Bow Creek would be met; however,
Federal and State groundwater quality standards would not be met for the bedrock aquifer
because of technical impracticability. Action-specific ARARs would be met for this
alternative by standard industry controls and monitoring programs during operation. The
location-specific ARARs would be met for this alternative by eliminating the potential
migration of contaminated water from the OU and by meeting the discharge criteria for
treated water prior to discharge to Silver Bow Creek.
In summary, the selected alternative:
.
Protects human health and the environment;
.
Is implementable and creates no unacceptable shon-term impact;
.
Complies with ARARs, with the exception of Federal and State groundwater
quality standards for the bedrock aquifer (a Technical Impracticability evaluation
has been issued for these standards - see Appendix 2);
.
Is cost-effective relative to the benefits and in comparison to the other alternatives
evaluated;
.
Encourages flexibility for water management and treatment;
.
Utilizes permanent solutions;
.
Satisfies the statutory preference for treatment as a principal element of the'
remedy; and
44
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.
Has State acceptance.
10. THE SELECTED REMEDY
The selected alternative should achieve the remedial action objectives and goals, provide
protection to human health and the environment, and meet Federal and State requirements
designated as applicable or relevant and appropriate for this au except those for which a
waiver has been granted in accordance with CERCLA and the NCP. EPA and the State
believe that this alternative provides the best balance of tradeoffs among the alternatives with
res~t to the five primary balancing criteria. It combines the components of a
comprehensive monitoring program (to ensure that the safe water levels are not exceeded),
institutional controls, inflow controls, extraction of Pit. System water, onsite external primary
and polishing water treatments, and disposal of sludges in either an on site disposal facility or
the Berkeley Pit. .
The selected alternative provides greater long-term effectiveness and permanence, eliminates
the potential for migration of water from the au, meets short-term effectiveness criteria, is
cost effective, and has equivalent or greater implementability than the other three
alternatives. This alternative is also preferred by the State over the other alternatives. .
Although the selected alternative is more costly (50%) than Alternative 4/5, it is more,cost
effective because the positive aspects of this alternative (Le., greater long-term effectiveness
and permanence, greater implementability, reduced volume of contaminated water) outweigh
the ill~!~ cost.
We also acknowledge that there was significant public opposition to certain aspects of the
preferred alternative presented in the Proposed Plan. Many citizens generally favored
. .
establishment of a lower critical water level and employment of alte",ative treatment/metals
recovery technology in lieu of the technology proposed.
The public generally commented that a lower critical water level is necessary to account for
45
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uncertainties relating to the impact of the rising water in the system. EPA and the State
believe that the established critical water levels are safe water levels. By allowing the system
to recover to the maximum extent practical (with a safety buffer) without allowing a
discharge to the alluvial system, the long-term acid mine drainage (AMD) production is
reduced. Several steps have been incorporated into the ROD (see Declaration) to account for
future uncertainty. All such comments are addressed in more detail in the RS (Appendix 4).
1. The ROD requires that the critical water level of 5,410 feet apply to the entire East
Camp system, not just for the Pit. Currently, alluvial groundwater levels a ~ at least 50
feet above die 5,410 foot elevation (i.e., current alluvial groundwater levels are no lower
than 5,460 feet). This is a 50 foot safety buffer between the bedrock and alluvial
aquifers. For the bedrock aquifer to discharge to the alluvial aquifer, bedrock aquifer
water would have to rise above 5,460 feet. The water level in the Anselmo Mine (which
is the point of compliance furthest from the Pit) is currently 40 feet above the Berkeley
Pit. If this groundwater gradient remains there will be a buffer of 90 feet betWeen the
Berkeley Pit and the surrounding alluvial aquifer levels (5,460 feet). Even with a
reduction in the water gradient between the Anselmo Mine and the Berkeley Pit, a buffer
of at least 50 feet is guaranteed between the East Camp System and the alluvial aquifer.
2. The ROD requires the inflow of water to be reduced significantly to allow a much slower
rise in the system water level. This allows much more time for the Agencies to react to
any unanticipated impacts.
3. The ROD requires a comprehensive monitoring program to be employed to thoroughly
monitor the system and act as an early warning system in the event that current
assumptions are proven incorrect.
4. The ROD has a requirement to have construction of a final treatment plant completed 4
years prior to when the water in the East Camp system is predicted to reach the CWL.
This allows for plant testing and early start-up if necessary.
46
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5. EP A and the State retain authority under applicable Federal and State law to establish a
lower CWL or take alternative action if necessary to address unanticipated threats to
human health or the environment.
6. Although not formally part of the ROD, EP A and the State are evaluating alternative'
financial assurances from the PRPs such as bonding to reduce uncertainties associated
with the funding of the long-term components of this remedy.
Considerable comment was also received concerning the use of innovative treatment/metals
recovery technology. Numerous commenters expressed concern about the amount of sludge
generated by the hydroxide precipitation/aeration treatment process selected and voiced their
opinion that a technology which reclaims metals from the Berkeley Pit System is preferable.
The hydroxide/aeration treatment technology is presently the most cost effective, proven
technology available for this action. EP A and the State recognize that employment of this
technology generates large volumes of sludge. The final treatment plant may generate from
500 - 1000 tons per day of sludge (40% solids). However, the amount of sludge generated is
only 1-2% of the tailings generated daily by the current mining operation. This amount of
sludge can be managed effectively. Large areas are available in the active mine area for
disposal of this material. If sludge disposal in the Berkeley Pit is selected, an equivalent
volume of Berkeley Pit/East Camp System water will be pumped and treated to ensure that
there is no net rise in the Pit water elevation.
We do recognize, however, the public's concern about the sludge generated by the selected
technology and their preference for a technology which would recover metals. To address
these issues we have taken several steps:
1. The ROD requires that Montana Solid Waste Disposal regulations or a waiver based on
the attainment of an equivalent standard of performance be met for any waste repository
utilized.
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2. EPA and the State are actively involved in a consultative role (the Technical Coordinating
Committee) with the U.S. Department of Energy (DOE) resource recovery project which
is actively pursuing demonstration of innovative water treatment/metals recovery
technologies using the Berkeley Pit waters as a test media.
3. EPA and the State remain flexible in the implementation of alternate treatment/metals
recovery technology proposed jointly by the developers of that technology and the PRPs,
if that technology meets the performance (discharge) standards established for this action.
4. The ROD requires (see Declaration) that a reevaluation of treatment technology be
conducted when the water level of the Pit reaches the 5260' (presently projected in 2009).
This reevaluation is to assess alternative technologies to hydroxide precipitation with
emphasis on innovative treatment and/or metals recovery technologies developed in the
interim.
5. EPA Region VIII and the State will actively pursue Federal monies for research and
development of innovative treatment/metals recovery technology for Berkeley Pit water.
In summary, the selected alternative is protective of human health and the environment by
accomplishing the following: permanently controlling major surface inflows into the Pit
thereby slowing the present rate of flooding by over 40%; maintaining the water level in the
Pit System below the CWI. elevation of 5,410 feet and the West Camp CWL elevation of
5,435 feet, thereby preventing discharge of contaminated bedrock aquifer water into the
alluvial aquifer and Silver Bow Creek; treating all discharges of water to Silver Bow Creek
to -I- classification standards thereby improving water quality in the Creek and enhancing
the quality of the aquatic environment; disposing of sludges g~nerated by treatment processes
in accordance with appropriate Montana Solid Waste Disposal reg~lations, thereby preventing
any threats to the environment from sludge disposal practices; implementing a comprehensive
monitoring program which provides the basis for ongoing assessment of the mine flooding
cond~tion in the future; providing for monitoring and design criteria for operation of Yankee
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Doodle Tailings Pond to provide further assurances that there is no cataStrophic failure of the
dam; providing an institutional control program that restricts inappropriate use of any of the
contaminated bedrock aquifer water.
The remedy also provides flexibility in the method used to control inflow, method of
treatment, bedrock water withdrawal point, and use of collected and/or treated water to most
cost effectively address the mine flooding problem yet meets the identified remedial action
objectives; encourages development of innovative treatment/metals recovery technology and
requires a reevaluation of such technology in the future, thereby allowing for potential
application of innovative technology in the future; requires that construction of a treatment
plant, capable of maintaining the Pit System below the CWL, be completed 4 years prior to
the projected date that the water level in that system reaches the CWL; and provides yearly
updates for the public concerning the ongoing monitoring and water level projections,
thereby keeping the public well informed on any developments that may occur.
11. PERFORMANCE STANDARDS
Performance standards for this action are defined in the declaration (see 14 components) and
the accompanying documents including the ARARs analysis (Appendix 1) and the Post-ROD
monitoring program (Appendix 3). These performance standards revolve around the
following subjects: maximum allowable groundwater elevations (CWL), "I" classification
discharge standards, sludge disposal standards, Yankee Doodle Tailings Pond design and
operating standards, inflow control minimum flow standards, and ground water and surface
water monitoring requirements. More detailed standards addressing. specific construction and
operating requirements will be developed during the remedial design phase. Design of a
water treatment and sludge disposal facility must be approved by EP A in consultation with
the State; and the construction and operation and maintenance of the facility will be
monitored by EPA and/or the State. The facility must be designed to meet State and Federal
water quality standards. Design, construction, maintenance, and monitoring of the facility
will be conducted according to the engineering standards established during remedial design,
and must be approved by EP A in consultation with the State.
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12. STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undenake
remedial actions that achieve the overall protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory requirements and
preferences. These specify that, when complete, the remedial action selected for this site
must comply with applicable or relevant and appropriate environmental standards established
under Federal and State environmental laws unless a statutory waiver is justified. The
selected remedy also must be cost-effective and must utilize permanent solutions and
alternative treatl'!1ent technologies or resource recovery technologies to the maximum extent
practicable. Finally, the statute includes a preference for remedies t~at employ treatments
that permanently and significantly reduce the volume. ~oxicity, or mobility of hazardous
substances as a principal element. The following subsections discuss how the selected
alternative meets these statutory requirements.
PROTECTION OF HUMAN HEALm AND mE ENVIRONMENT
The selected alternative is protective of human health and the environment through the
containment of contaminated water in the 0t!, treatment of the contaminated water prior to
discharge to Silver Bow Creek, and the control of access to contaminated groundwater.
COMPLIANCE WIm ARARS
The selected alternative is expected to meet Federal and State requirements ~at are legally
applicable or relevant and appropriate, except Federal and State groundwater quality
standards for the bedrock aquifer. Specifically, Maximum Contaminant Levels (MCLs) for
arsenic, cadmium, copper, and lead may not be met. These requirements are waived based
on the determination that compliance with these standards is technically impracticable from
an engineering perspective (See Technical Impracticability evaluation - Appendix 2). Treated
water discharged to Silver Bow Creek shall meet all state discharge requirements (WIW
classification discharge standards). Sludge produced s~all be disposed of in compliance with
Federal and state solid waste regulations. Appendix 1 provides a list of the ARARs for the
selec~ remedy.
50
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COST EFFECTIVENESS
The selected alternative is cost effective compared to the other alternatives evaluated. Based
on an analysis of costs, the selected alternative has the highest associated costs of the final 7
alternatives evaluated (present worth (PW) value of $45 to 55 million). This increased cost
is outweighed by the fact that the selected alternative mandates the immediate and permanent
control of water inflows into the Pit System thereby making this alternative more cost
effective. The selected alternative has a much lower cost than any alternative that seeks to
stabilize the Pit System at its current level (PW of $180 to 215 million) or seeks to drain the
Pit System (PW in excess of $300 million). EPA and the State believe that there is not a
significant reduction in threat to human health and the environment if the Pit System is
stabilized at its current level or drained rather than allowed to approach the CWL.
UTll..IZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOWGIES)
The selected alternative uses permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. EP A and the State have determined that the
selected remedy provides the best .balance in terms of long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume achieved through treatment; shott-
term effectiveness; implementability; and cost, while also considering the statutory preference
for treatment as a principal element, and State and community acceptance.
The selected remedy will be designed as a permanent solution. Adherence to the
performance standards for the remedy will ensure. the continued safety of the surrounding
population and environment. Although resource recovery (metals recovery) is not presently
an element of the action, the ROD calls for .reevaluation of innovative treatment/metals
recovery technology when the water level in the Pit reaches the 5260' elevation. At that
time EPA, in consultation with the State,. will determine if the selected remedy should be
modified to include innovative water treatment/metals recovery technology.
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PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT
The selected remedy combines inflow control and wastewater treatment as two of the most
imponant elements of the action. The remedy reduces acid mine drainage (AMD) and treats
the'residual AMD. This satisfies the statutory preference for remedies that reduce the
toxicity, mobility, or volume of contamination through treatment.
13. DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section 117(b) requires an explanation of any significant changes to the selected
alternative as presented in the Proposed Plan, which was made available for public comment.
In developing the final remedy, five (5) significant changes were made to the Proposed Plan
(see Declaration for details). These changes are as follows:
1.
The ROD requires that construction of a treatment plant, capable of maintaining
the East Camp/Berkeley Pit System below the CWL, be completed 4 years prior
to the projected date that the water level in that system reaches the CWL. This
addition to the proposed plan was in response to significant public comment,
including the Butte-Silver Bow government (BSB). which requested that a
treatment plant be on-line (and that a "shake-down" or testing program be
completed) before the CWL was approached.
2.
The ROD requires a reevaluation of innovative treatment/metals recovery
technology when the water level in the Berkeley Pit reaches the 5260' elevation,
presently projected in the year 2009. This addition to the proposed plan is in
response to public comment, including the Butte Silver Bow Government who
believe that additional evaluation of treatment technology which produces less
sludge or recovers metals is needed, especially since the final expanded treatment
plant may not be necessary for at least 25 years. This addition to the ROD
formally institutionalizes this reevaluation.
3.
The ROD requires additional evaluation of the potential effects of placing large
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volumes of sludge in a body of water with the chemistry of Berkeley Pit water.
This change was in response to technical comments received. The commenters
noted that placement of hydroxide sludges in an acidic body of water this large
has never been done before. They hypothesized that placement of treatment plant
sludge in the Pit might produce some unexpected negative geochemical impacts.
EPA and the State, however, do not want to completely preclude this option at
this time because there are also some potential benefits of placing the sludge in the
Pit (neutralization benefits, cost savings, etc.).
-
4.
The ROD requires capturing groundwater as well as all surface water in the
Horseshoe Bend drainage area. This addition is in response to the public's desire
to not limit the capture of inflow to only surface water.
5.
As was expressed earlier in this document, there was significant public comment
concerning the need for additional research, development, and demonstration of
innovative treatment/metals recovery technology. EPA and the State a~ree that
. this additional R&D is appropriate to advance technology in this area. Although
not formally a binding or enforceable part of the ROD, EPA and the State, in
cooperation with local government and the PRPs, are committed to pursuing
additional funding for this effort. .
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REFERENCES
Camp Dresser and McKee, Inc. (CDM). 1988a. Preliminary Water Balance for the
Berkeley Pit and Related Underground Mine Workings.
CDM. 1988b. Preliminary Evaluation of Flooding in the West Camp Area Mine Workings.
CDM. 1988c. Factors Affecting the Geochemistry of the Berkeley Pit, Butte, Montana.
CDM. 1989. Engineering Evaluation and Cost Analysis for West Camp Mine Flooding
Project.
CDM. 1990. final Work Plan for Remedial Investigation/Feasibility Study. Butte Mine
Flooding Operable Unit. April 27, 1990.
CDM Federal. 1993. Draft Baseline Risk Assessment, Mine Flooding Operable Unit.
December 15, 1993.
ARCO 1994a. Draft Remedial Investigation Repon, Butte Mine Flooding Operable Unit
Remedial Investigation/Feasibility Study, prepared for ARCO, Anaconda, Montana by
Canonie, January 1994.
ARCO 1994b. Draft Feasibility Study Repon, Butte Mine Flooding Operable Unit Remedial
Investigation/Feasibility Study, prepared for ARCO, Anaconda, Montana by Canonie.
January 1994. .
Federal Register. 1987. 52 FR.27627, July 22, 1987, Final Rule.
U.S. EPA. 1986. Descriptions of 87 Sites Not Covered in the May 1986 Final Rule
Making National Priorities List HW8.8. U.S. EPA Remedial Response Program,.
Washington, D.C.' .
U.S. EPA. 1989. Guidance on Preparing Superfund Decision Documents: The Proposed
Plan, the Record of Decision, Explanation of Differences, the Record of Decision
Amendment, Interim Final, EPA/540/G, July 1989.
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IDENTIFlCATION AND DESCRIPI10N OF
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
APPENDIX 1
BUTIE MINE FLOQDING OPERABLE UNIT
RECORD OF PECISION
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SECTION
I.
II.
III.
TABLE OF CONTENTS
PAGE
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. I
FEDERAL CONTAMINANT SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . . .. 4
A. Groundwater Standards - Safe Drinking Water Act. . . . . . . . . . . . . . . . . . .. 4
B. Air Standards - Clean Air Act (Applicable) ........,................ 4
C. Surface Water - Ambient and Point Source Discharges. . . . . . . . . . . . . . . . . .. 5
FEDERAL LOCATION SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . . . . . .. 5
A. Fish and Wildlife Coordination Act (Applicable) . . . . . . . . . . . . . . . . . . . . .. 5
B. The Endangered Species Act (Applicable) . . . . . . . . . . . . . . . . . . . . . . . . .. 5
C. The National Historic Preservation Act (Applicable) . . . . . . . . . . . . . . . . . . .. 5
D. Archaeological and Historic Preservation Act (Applicable) . . . . . . . . . . . . . . .. 6
E. Historic Sites, Buildings, and Antiquities Act (Applicable) . . . . . . . . . . . . . . .. 6
F. Migratory Bird Treaty Act (Applicable) ...........................' 6
G. Bald Eagle Protection Act (Applicable) . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
H. Resource Conservation and Recovery Act (Relevant and Appropriate) . . . . . . . .. 6
FEDERAL ACTION SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . .. 7
A. Solid Waste (Applicable) and RCRA (Relevant and Appropriate) Requirements. .. 7
B. Point Source Water Discharges (Applicable) . . . . . . . . . . . . . . . . . . . . . . . .: 8
C. Underground Injection Control (Applicable) . . . . . . . . . . . . . . . . . . . . . . . ., 8
D. Transportation of Hazardous or Contaminated Waste (Relevant and
Appropriate) ............................................ 8
IV.
TO BE CONSIDERED DOCUMENTS (TBCs) .. ...................,.... 8
OTHER FEDERAL LAWS (NON-EXCLUSIVE LIST) ...................... 9
V.
VI.
MONTANA CONTAMINANT SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . .. 10
A. WATER QUALITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
" 1. Surface Water Quality Standards (Applicable) . . . . . . . . . . . . . . . . .. 10
2. " Groundwater Pollution Control System (Applicable) . .. . . . . . . ". . . . .. 12
AIR QUALITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
B.
VII.
MONTANA LOCATION SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . . . .. 13
A. Solid Waste Management Regulations (Applicable) ................... 13
VIII. MONTANA ACTION SPECIFIC REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . .. 13
A. WATER QUALITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
1. Groundwater Act (Applicable) ....................,...... 13
2. Water Quality Act (Applicable) . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
3. Montana Surface Water Quality Regulations (Applicable) . . . . . . . . . .. 14
4. Public Water Supply Regulations (Applicable) ................. 14
AIR QUALITY. . . . . . . . .". . .". . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
1. Air Quality Regulations (Applicable) ....................... 14
2. Control of Odors. . . . . . . . . . . . . . . . . . . . . . . . . . . . .". . . . .. 15
B.
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TABLE OF CONTENTS
(continued)
SECTION
PAGE
c.
D.
3. Monitoring. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 16
SOLID WASTE MANAGEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 16
MONTANA DAM SAFETY ACT (Applicable) ""'.'."""""..' 17
IX.
OTHER MONTANA LAWS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
A. Groundwater Act. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
B. Occupational Health Act. . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
C. Montana Safety Act. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
D. . Employee and Community Hazardou~ Chemical Information Act. . . . . . . .. 18
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ARAR
ATSDR
BAT
BCT
BPCTCA
BPJ
BTCA
CERCLA
DNRC
DSL
EPA
FIFRA
HWM
LNAPL
MCL
MCLG
MDHES
MGWPCS
MPDES
NCP
NESHAPS
NPL
NPDES
PAH
PCP
POHC
POTW
PSD
RCRA
RIfFS
ROD
SHPO
SIP
TBC
TU
VIC
WQB- i
LIST OF ACRONYMS
Applicable or Relevant and Appropriate Requirements
Agency of Toxic Substances and Disease Registry
Best Available Technology Economically Achievable
Best Conventional Pollutant Control Technology
Best Practicable Control Technology Currently Available
Best Professional Judgment
Best Technology Currently Available
Comprehensive Environmental Response. Compensation. and Liability Act of 1980
Department of Natural Resources and Conservation (Montana)
Department of State Lands (Montana)
U.S. Environmental Protection Agency
Federal Insecticide. Fungicide, and Rodenticide Act
Hazardous Waste Management
Light Non-aqueous Phase Liquid
Maximum Contaminant Level
Maximum Contaminant Level Goal
Montana Department of Health and Environmental Sciences
Montana Groundwater Pollution Control System
Montana Pollutant Discharge Elimination System
National Contingency Plan
National Emissions Standards for Hazardous Air Pollutants
National Priorities List
National Pollutant Discharge Elimination System
Polynuclear Aro~atic Hydrocarbon
Pentachlorophenol
Principal Organic Hazardous Constituents
Public Owned Treatment Works
Prevention of Significant Deterioration
Resource Conservation and Recovery Act
Remedial Investigation/Feasibility Study
Record of Decision
State Historic Preservation Officer (Montana)
State Implementation Plan
To Be Considered
Turbidity Unit
Underground Injection Control
Circular Water Quality Bt;, ~au 7
ARARS-iii
i
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INTRODUCTION
Section 121(d) of CERCLA, 42 U .S.C. 9 962l(d), certain provisions of the current National Contingency
Plan (the NCP), 40 CFR Pan 300 (1990), and guidance and policy issued by the Environmental
Protection Agency (EPA) require that remedial actions taken pursuant to Superfund authority shall require
or achieve compliance with substantive provisions of applicable or relevant and appropriate standards,
requirements, criteria, or limitations from state environmental and facility siting laws, and from federal
environmental laws at the completion of the remedial action, and/or during the implementation of the
remedial action, unless a waiver is granted. These requirements are threshold standards that any selected
remedy must meet. See Section 121(d)(4) of CERCLA, 42 U.S.c. 9 962 I (d)(4); 40 CFR 9
300.430(t)(1). EPA calls standards, requirements. criteria. or limitations identified pursuant to section
121 (d) "ARARs," or applicable or relevant and appropriate requirements.
ARARs are eith '1' applicable or relevant and appropriate. Applicable requirements are those standards.
requirements, \.:.u;~ria, or limitations promulgated under federal or state environmental or facility siting
laws that specifically address a hazardous substance, pollutant, or contaminant, remedial action, location.
or other circumstance found at a CERCLA site. Relevant and appropriate requirements are those
standards, requirements. criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that, while not "applicable" to hazardous substances, pollutants,
contaminants, remedial actions, locations, or other circumstances found at a CERCLA site, address
problems or situations sufficiently similar to those encountered at the CERCLA site such that their use
is well suited to the panicular site. Factors which may be considered in making this determination are
presented in 40 CFR 9 300.400(g)(2). Compliance with both applicable and relevant and appropriate
requirements is mandatory. 1
Each ARAR or group of related ARARs identified here is followed by a specific statutory or regulatory
citation, a classification describing whether the ARAR is applicable or relevant and appropriate, and a
description which summarizes the requirements, and addresses how and when compliance with the ARAR
will be measured (some ARARs will govern the conduct of the implementation of the remedial action,
some will govern the measure of success of the remedial action, and some will do both).2 The
descriptions given here are provided to allow the user a reasonable understanding of the requirements
without having to refer constantly back to the statute or regulation itself. However, in the event of any
inconsistency between the law and the summary provided in this document, the applicable or relevant and
appropriate requirement is ultimately the requirement as set out in the law, rather than any paraphrase
of the law provided here.
Also contained in this list are policies, guidance or other sources of information which are "to be
considered" in the selection of the remedy and implementation of the ROD. Although not enforceable
requirements, these documents are important sources of information which EP A and the State of Montana
Department of Health and Environmental Sciences (MDHES) may consider during selection of the
See CERCLA Section 121(d)(2)(A). 42 U.S.C. Seclion 9621(d)(2)(A).
40 CFR Section 300.435(b)(2); Preamble 10 tile Proposed NCP. 53 Fed. Reg. 51440 (December 21. 1988); Preamble to
tile Final NCP. 55 Fed. Reg. 8755-8757 (Marcil 8. 1990). The Atlantic Ricllfield Company (ARCO), the narned liable
party for the site. argues that this NCP requiremenl is nOI consistent with the CERCLA statute. However. ARCO did not
cllallenge the NCP in tile District of Columbia Coun of Appeals in a timely manner. and therefore have waived the rigllt
to UICrt thil argument. See Section 113(a) of CERCLA, 42 U.S.C. Section 9613(a).
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remedy, especially in regard to the evaluation of public health and environmental risks; or which will be
referred to, as appropriate, in selecting and developing cleanup actions.J
Finally, this list contains a non-exhaustive list of other legal provisions or requirementS which should be
complied with during the implementation of this ROD.
ARARs are divided into contaminant specific, location specific, and action specific requirementS, as
described in the NCP and EPA guidance. For contaminant specific ARARs. ARARs are listed according
to the appropriate media.
Contaminant specific ARARs include those laws and regulations governing the release to the environment
of materials possessing certain chemical or physical characteristics or containing specific chemical
compounds. Contaminant specific ARARs generally set health or risk based numerical values or
methodologies which, when applied to site-specific conditions, result in the establishment of numerical
val~es. These values establish the acceptable amount or concentration of a chemical that may be found
in, or discharged JO, the ambient environment.
Location specific ARARs are restrictions placed on the concentration of hazardous substances or the
conduct of cleanup activities because they are in specific lo~ations. Location specific ARARs relate to
the geographic or physical position of the site, rather than to the nature of the site contaminantS.
Action specific ARARs are usually technology or activity based requirementS or limitations on actions
taken with respect to hazardous substances.
Only the substantive portions of the requirementS are ARARs.. Administrative requirementS are not
ARARs and thus do not apply to actions conducted entirely on-site. Administrative requirementS are
those which involve consultation, issuance of permitS, documentation, reporting, record keeping, and
enforcement. The CERCLA program has itS own set of administrative procedures which assure proper
implementation of CERCLA. The application of additional or conflicting administrative requirementS
could result in delay or confusion.' Provisions of statutes or regulations which contain general goals that
merely express legislative intent about desired outcomes or conditions but are non-binding are not
ARARs.6
Many requirementS listed here are promulgated as identical or nearly identical requirementS in both
federal and state law, usually pursuant to delegated environmental programs administered by EPA and
the states, such as the requirementS of the federal Clean Water Act and the Montana Water Quality Act.
The preamble to the new NCP stateS that such a situation resultS in citation to the state provision as the
appropriate standard, but treatment of the provision as a federal requirement. ARARs and other laws
which are unique to state law are identified separately by the State of Montana.
40 CFR Section 300.400(g)(3); 40 CFR Sec:tion 300.4IS(i); Preamble to the Final NCP. SS Fed. Reg. 8744-8746 (March
8. 1990).
40 CFR Section 300.S. See also Preamble to the Final NCP. SS Fed. Reg. 87S6-87S7 (March 8. 1990).
. Preamble to the Final NCP. SS Fed. Reg. 87S6-87S7 (March 8. 1990); Compliance with Other Law. Manual. Vol. I. pp.
I-II through 1-12.
Preamble to the Final NCP. SS Fed. Reg. 8746 (March 8. 1990).
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This list constitutes EPA's and MDHES' detailed identification and description of ARARs for use in the
implementation of the remedy at the Butte Mine Flooding Operable Unit. The major response actions
designated in the ROD revolve around treatment of contaminated groundwater before discharge to the
Upper Silver Bow Creek drainage. Primary ARARs therefore revolve around discharge standards and
sludge disposal requirements.
The ARARs analysis is based on section 121(d) of CERCLA. 42 U.S.C. ~ 9621(d); CERCLA
Compliance with Other Laws Manual, Volumes I and II. OSWER Dirs. 9234.1-01 and-02 (August 1988
and August 1989, respectively); various CERCLA ARARs'Fact Sheets issued as OSWER Directives; the
Preamble to the Proposed NCP, 53 Fed. Reg. 51394 et seq. (December 21. 1988); the Preamble to the
Final NCP, 55 Fed. Reg. 8666-8813 (March 8, 1990); and the Final NCP, 40 CFR Part 300 (55 Fed.
Reg. 8813-8865, March 8, 1990).
It should be noted that EPA has granted a waiver of ground water standards for this action because of
technical impracticability of remediating the bedrock aquifer from an engineering perspective, as allowed
by 40 CFR 9300.430(t)(1)(ii)(C). The National Primary Drinking Water Standards (40 CFR Part 141)7,
better known as maximum contaminant levels and maximum contaminant level goals (MCLs and MCLGs)
and the state Ground Water Quality Standards (ARM 16.20.1003) are ARARs for the bedrock
groundwater that are waived for this action. EPA and the State of Montana recognize that, because of
the size and complexity of the underground mining system (3000 miles of workings reaching over 5000
feet in depth), the bedrock aquifer within the Mine Flooding Operable Unit (East Camp/Berkeley Pit and
West Camp systems) can not be fully remediated to these groundwater standards. The federal Safe
Drinking Water Act MCLs and the state Ground Water Quality Standards are, therefore, waived with
respect to the bedrock aquifer, because of the technical impracticability of remediating the bedrock aquifer
within the foreseeable future. This waiver applies only to the bedrock aquifer for the area outlined on
the map shown as Figure 2 in the Technical Impracticability Evaluation attached as Appendix 2 of the
Record of Decision. These standards have not been waived in respect to discharges from the bedrock
aquifer within the TI waiver area into the alluvial aquifer. It should be noted, however, that the remedy
does not allow such a discharge because it requires eventual pumping of the system to maintain an inward
hydraulic gradient.
42 U.S.C. Sec:tions JOOf~.
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FEDERAL ARARS
I.
FEDERAL CONTAMINANT SPECIFIC REQUIREMENTS
A.
Groundwater Standards - Safe Drinking Water Act
Although the Safe Drinking Water Act MCLs and MCLGs are relevant and appropriate requirements,
these regulations have been formally waived for the bedrock aquifer because of the technical
impracticability of meeting these standards in the bedrock aquifer in the foreseeable future. However.
MCL and non-zero MCLG standards, 40 CFR Part 141. promulgated under the Safe Drinking Water
Act are relevant and appropriate for the alluvial aquifer and the bedrock aquifer outside the TI waiver
area. Contaminated water from the TI waiver area of the bedrock aquifer, therefore, cannot
discharge and contaminate the alluvial aquifer or the bedrock aquifer outside the 11 waiver area in
concentrations .above MCLs and non-zero MCLGs. The remedy is structured to preclude such a
discharge by keeping an inward gradient towards the bedrock aquifer waiver area by an inflow
control, and a pump and treat system.
See the end of the introduction for more discussion on this issue.
B.
Air Standards - Clean Air Act (Applicable)
Considerable construction activities, including construction of a sludge disposal area, will occur at the
site. Fugitive dust therefore will need to be controlled during construction and operation of any
treatment and disposal facilities. The following standards, promulgated pursuant to section 109 of the
Clean Air Act,S are applicable to any releases into the air from Mine Flooding Operable Unit cleanup
activities.
1. Lead:
No person shall cause or contribute to concentrations of lead in the ambient air which
exceed 1.5 micrograms per cubic meter (jLg/m3) of air, measured over a 90-day
average.
These standards are promulgated at ARM 16.8.815 as part of a federally approved State
Implementation Plan (SIP), pursuant to the Clean Air Act of Montana, ~~ 75-2-101 ~, MCA.
Corresponding federal regulations are found at 40 CFR ~ 50.12.9
2. PM-I0:
No person shall cause or contribute to concentrations of PM-lO in the ambient air
which exceed:
150 micrograms per cubic meter of air, 24 hour average, no more than one expected
exceedence per calendar year;
42 V.S.C. n 7401 ~.
The ambient air standards established as part of Montana's approved Swe Implementation Plan in many cases provide
more stringent or additional standards. The federal standards by themselves apply only to "major sources" , while the
Swe standards are fully applicable throughout the swe and are not limited to "major sources". ~ ARM 16.8.808 and
16.8.811-.821. As part of an EPA-approved State Implementation Plan. the state standards are also federally enforc:cable:.
Thus, the state standards which are equivalent to the fede:raI standards are: identified in this section together with the:
federal standards. A more defAiled list of State standards. which includes standards which are not duplic:a1ed in federal
regulations. is contained in the Swe ARAR identification section.
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50 micrograms per cubic meter of air, annual average.
These regulations are promulgated at ARM 16.8.821 as part of a federally approved SIP, pursuant to
the Clean Air Act of Montana, ~~ 75-2-101 et seq., ~CA. Corresponding federal regulations are
found at 40 CFR ~ 50.6.
Ambient air standards under section 109 of the Clean Air Act are also promulgated for carbon
monoxide, hydrogen sulfide, nitrogen dioxide, sulfur dioxide, and ozone. If emissions of these
compounds were to occur at the site in connection with any cleanup action, these standards would also
be applicable. ~ ARM 16.8.811 - 16.8.820 and 40 CFR Part 50.
C.
Surface Water - Ambient and Point Source Discharges.
CERCLA and the NCP provide that federal water pollution criteria that match designated or
anticipated surface water uses are the usual surface water standards to be used at Superfund cleanups,
as relevant and appropriate standards, unless the state has promulgated surface water quality standards
pursuant to the delegated state water quality act. The State of Montana has designated uses for Silver
Bow Creek and the Clark Fork River, and has promulgated specific standards accordingly. Those
standards and their application to the Mine Flooding Operable Unit, as well as other surface water
standards, are included in the state ARARs identitied below. These standards are the primary
standards driving this action and will be applied to all point source discharge of contaminants of
concern identified in the Mine Flooding Operable Unit remedial investigation.
II.
FEDERAL LOCATION SPECIFIC REQUIREMENTS
A.
Fish and Wildlife Coordination Act (Applicable)
These standards are found at 16 U.S.C. ~~ 1531 - 1566 and 40 CFR ~ 6.302(g). They require that
federally funded or authorized projects ensure that any modification of any stream or other water
body affected by a funded or authorized action provide for adequate protection of fish and wildlife
resources. Compliance with this ARAR necessitates consultation with the U.S. Fish and Wildlife
Service and the State of Montana Department of Fish, Wildlife, and Parks. Further consultation with
these agencieS will occur during cleanup design and implementation, and specific mitigative or other
measures may be identified to achieve compliance with this ARAR.
B.
The Endangered Species Act (Applicable)
This statute and implementing regulations (16 V.S.C. ~~ 1531 - 1543,50 CFR Part 402, and 40 CFR
~ 6.302(h» require that any federal activity or federally authorized activity may not jeopardize the
continued existence of any threatened or endangered species or destroy or adversely modify a critical
habitat.
Compliance with this requirement involves continued consultation with USFWS, on the topic of
whether any proposed activities will impact such wildlife or habitat.
C.
The National Historic Preservation Act (Applicable)
This statute and implementing regulations (16 U.S.C. ~ 470,40 CFR ~ 6.310(b), 36 CFR Part 8(0)
require federal agencies or federal projects to take into' account the effect of any federally assisted
undertaking or licensing on any district, site building, structure, or object that is included in, or
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eligible for, the Register of Historic Places. If effects cannot be avoided reasonably, measures should
be implemented to minimize or mitigate the potential effect. In order to comply with this ARAR,
EPA, MDHES, and the PRPs may consult with the State Historic Preservation Officer (SHPO), who
caD assist in identifying listed or eligible resources, and in assessing whether proposed cleanup actions
will impact the resources and any appropriate mitigative measures. Additionally, in April 1992,
ARCO, EPA, MDHES, SHPO, the National Council on Historic Preservation, and local governments
entered into a Programmatic Agreement to ensure the appropriate consideration of cultural and
historical resources in a systematic and comprehensive manner throughout the Clark Fork Basin, in
connection with response actions at the four Clark Fork Basin Superfund sites. A Second
Programmatic Agreement was agreed upon in September 1994. The results of the Programmatic
Agreements may provide additional consideration of the factors to be addressed under this ARAR and
the two historical ARARs described below.
D.
Archaec'logical and Historic Preservation Act (Applicable)
The statute and implementing regulations (16 V.S.C. 9469,40 CFR 9 6.301(c» establish
requirements for evaluation and preservation of historical and archaeological data, which may be
destroyed through alteration of terrain as a result of federal construction projects or a federally
licensed activity or program. If eligible scientific, prehistorical, or archaeological artifacts are
discovered during site activities, they must be preserved in accordance with these requirements.
E.
Historic Sites, Buildings, and Antiquities Act (Applicable)
This requirement states that" in conducting an .environmental review of a proposed EP A action, the
responsible official shall consider the existence and location of natural landmarks using information
. provided by the National Park Service pursuant to 36 CFR 9 62.6(d) to avoid undesirable impacts
upon such landmarks. The Programmatic Agreement activities described above should aid all parties
in compliance with this ARAR.
F.
Migratory Bird Treaty Act (Applicable)
This requirement (16 V.S.C. 99 703 ~.) establishes a federal responsibility for the protection of
the international migratory bird resource and requires continued consultation with the V.S. FWS
during remedial design and remedial construction to ensure that the cleanup of the site does not
unnecessarily impact migratory birds. Specific mitigative measures may be identified for compliance
with this requirement.
G.
Bald Eagle Protection Act (Applicable)
This requirement (16 V.S.C. ~~ 668 et seq.) establishes a federal responsibility for prot~ion of bald
and golden eagles, and requires continued consultation with the U.S. FWS during remedial design and
remedial construction to ensure that any cleanup of the site does not unnecessarily adversely affect the
bald and golden eagle. Specific mitigative measures may be identified for compliance with this
requirement.
H.
Resource Conservation and Recovery Act (Relevant and Appropriate)
Any discrete waste units created by the Mine Flooding cleanup, especially those related to sludge
disposal, must comply with the siting restrictions and conditions found at 40 CFR 9 264. 18(a) and
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(b). These sections require management unitS to be designed, constructed, operated, and maintained
to avoid washout, if they are within or near the 100 year flood plain.
m.
FEDERAL ACTION SPECIFIC REQUIREMENTS
A.
Solid Waste (Applicable) and RCRA (Relevant .and Appropriate) RequirementS
Sludge generated in the treatment of mine waters in the Mine Flooding Operable Unit using the
technology described in the ROD may not be RCRA characteristic hazardous waste, although EP A
reserves itS rightS to make a more formal determination in this regard at a later date. For this reason,
cenain RCRA regulations, although considered to be potentially relevant and appropriate, are not
employed substantively in this action. The State and EPA have indicated that development of
alternate innovative technology for the treatment of the Berkeley Pit water is encouraged. If the ROD
is amended to employ an alternate treatment process or metals recovery process, the sludge generated
by any other process may be hazardous. If this is Qie case or if the technology selected in the ROD
produces a chara~eristic hazardous waste. the RCRA regulations (or the corresponding State
hazardous waste regulations) are applicable and will be fully utilized. The ROD indicates that
possible disposal of sludges in the Berkeley Pit 'will be considered by the agencies when sludge
disposal becomes necessary. In considering options for disposal, the agencies will determine whether
cenain of the otherwise applicable hazardous or solid waste requirementS may be waived on the basis
that such disposal will attain a standard of performance that is equivalent to that required under the
otherwise applicable standard or requirement through use of another method or approach, as provided
in 40 CFR ~ 300.430(t)(l)(ii)(C)(4).
At a minimum (Le., assuming the sludges are not characteristic hazardous waste) , any disposal of
sludge shall comply with the following regulations pertaining to the operation of solid waste disposal
facilities.
1.
RequirementS described at 40 CFR Part 257.3, which preclude negative impactS on
floodplains, surface water, and ground water.
2.
RequirementS described in 40 CFR Part 258, Subparts B, C, D, E, and F, which
describe location restrictions. and ground water monitoring, operating, design, and
closure criteria.
3.
RCRA regulations found at 40 CFR U 264.116 and .119 (governing notice and deed
restrictions), 264.228(a)(2)(i) (addressing de-watering of wastes prior to disposal), and
264.228(a)(2)(iii)(B), (C), and (D) and .251(c), (d), and (t) (regarding run-on and
run-off controls), are relevant and appropriate requirementS for any waste
management unitS created or retained at the Mine Flooding Operable Unit.IO
10
As noted earlier. federal RCRA regulations are incorporated by reference into applicable State HazardoUi Wute
Management Act regulations. See ARM 16.44.702. Use of select RCRA regulations to mining Wute is appropriate
when discrete units are addr~sed by a cleanup and site conditions are distinguishable from EPA'5 generic determination
. of low toxicityfhigh volume status for mining waste. See Preamble to the Final NCP, SS Fed. Reg. 8763 - 8764 (March
. 8. 1990), CERCLA Compliance with Other Laws Manual, Volume II (August 1989 OSWER Dir. 9234.1-02) p. 6-4;
Preamble to Proposed NCP, S3 Fed. Reg. SI447 (Dec. 21. 1988). and guidance entitled 'Consideration of RCRA
Requirements in Performing CERCLA Responses at Mining Wutes Sites.' August 19, 1986 (OSWER).
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B.
Point Source Water Discharges (Applicable)
Clean Water Act standards would be applicable for all point source discharges of water containing
contaminants associated with remedial activities in the Mine Flooding Operable Unit. The regulations
are discussed in the contaminant specific ARAR section in the State of Montana identification of
ARARs. Point source discharges created by the Mine Flooding Operable Unit remedial action must
meet cenain effluent standards for industrial categories. 40 CFR Part 440 establishes effluent limits
for mines that produce copper, lead, zinc. gold or molybdenum. In most cases the State "I" .
classification discharge standards will be more strict than these industrial category standards but
depending on the previous "one-half of the mean instream concentration," the industrial category
discharge standard could be more stringent. 40 CFR 9 440.10411 lists effluent limits for new
sources based on the application of the best available demonstrated technology (BADT). These
standards are as follows:
Parameter
A verae:e
Daily
Maximum
Daily
TSS
Copper
Zinc
Lead
Mercury
Cadmium
Ph
20.0 mg/l
0.15 mg/I
0.75 mg/l
0.3 mg/l
.001 mg/l
0.05 mg/l
from 6.0 to 9.0
30 mg/I
0.3 mg/l
1.5 mg/l
0.6 mg/l
.002 mg/I
0.1 mg/I
C.
Underground Injection Control (Applicable)
Requirements found at 40 CFR Part 144, promulgated pursuant to the Safe Drinking Water Act,
allow the re-injection of treated groundwater into the same formation from which it was withdrawn
for aquifers such as the bedrock aquifer in the Mine Flooding Operable Unit, and address injection
well construction, operation, maintenance, and capping/closure. These regulations would be
applicable to any reinjection of treated groundwater.
D.
Transportation of Hazardous or Contaminated Waste (Relevant and Appropriate)
40 CFR Pan 263 establishes regulations for the transportation of hazardous waste. These regulations
would govern anyon-site transportation of material. Any off-site transponation would be subject to
applicable regulations.
IV.
TO BE CONSIDERED DOCUMENTS (TBCs)
The use of documents identified as TBCs is addressed in the introductory ponion of the ARAR
identification. A !i$! C'f TBC documents is included in the Preamble to the NCP, 55 Fed. Reg. 8765
(March 8, 1990). Those documents, plus any additional similar or related documents issued since
that time, will be considered by EPA and MDHES during remedy implementation.
II
This requirement is also incorporated as a state MPDES standard at ARM 16.20.923.
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V.
OTHER FEDERAL LAWS (NON-EXCLUSIVE LIST)
CERCLA defines as ARARs only federal environmental and state environmental and siting laws.
Remedial design, implementation, and operation and maintenance must nevertheless comply with all
other applicable laws, both state and federal. if the remediation work is done by parties other than the
federal government or its contractors.
There are "other laws" which are legally applicable requirements for actions being conducted at the
Mine Flooding Operable Unit. They are not included as ARARs because they are not "environmental
or facility siting laws." An example is the federal Occupational Health and Safety Act regulations
found at 29 CFR ~ 1910.95 which are applicable to worker protection during conduct of remedial
activities, including operation and maintenance activities.
Section 121(e) of CERCLA exempts removal or remedial actions conducted entirely on-site from
federal, state, or local permits. This exemption is not limited to environmental or facility siting laws,
but applies to oth:r permit requirements as well.
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STATE OF MONTANA ARARS
As provided by Section 121 of CERCLA, 42 U.S.C. 99621, only those state standards that are more
stringent than any federal standard and that have been identified by the state in a timely manner are
appropriately included as ARARs.
The State has not identified as ARARs for this operable unit those requirements applicable to
reclamation of mining areas. Such requirements are nOt included for this operable unit because the
scope of the operable unit is confined to issues relating to mine tlooding and the treatment of
discharges of water from specific mining impacted areas. Other ARARs, including reclamation
requirements, may be included in the ARARs identitied for related operable units, such as the Active
Mine Area Operable Unit.
VI.
MONTANA CONTAMINANT SPECIFIC REQUIREMENTS
WATER QUALITY
A.
1.
Surface Water Oualitv Standards (ADDlicable)
Under the state Water Quality Act, 9975-5-101 et sea., MCA. the state has promulgated regulations
to protect, maintain, and improve the quality of surface waters in the state. The requirements listed
below are applicable water quality standards with which any remedial action must comply.
ARM 16.20.604(l)(b)'2 (Applicable) provides that Silver Bow Creek (mainstem) from the confluence
of Blacktail Deer Creek to Warm Springs Creek is classified "I" for water use.
The "I" classification standards are contained in ARM 16.20.623 (Applicable) of the Mo~tana water
quality regulations. This section states:
[T]he goal of the state of Montana is to have these waters fully support the following
uses: drinking, culinary, and food processing purposes after conventional treatment;
bathing, swimming, and recreation; growth and propagation of fishes and associated
aquatic life, waterfowl, and furbearers; and agricultural and industrial water supply.
These beneficial uses are considered supported when the concentrations of toxic, carcinogenic, or
harmful parameters in these waters do not exceed the applicable standards specified in department
circular WQB-7 for aquatic life and human health when stream flows equal or exceed the stream
flows specified in ARM 16.20.631(4) (10-year 7-day low flow, Le., minimum consecutive 7-day
average flow which may be expected to occur on the average of once every 10 years). Alternatively,
for aquatic life standards, site-specific criteria may be developed using procedures given in the Water
Quality Standards Handbook (USEPA, Dec. 1983), provided that other routes of exposure to toxic
parameters by aquatic life are addressed.
To allow a gradual attainment of these requirements in already impacted streams, the I classification
allows point source discharges to be permined at the higher concentration of: (l) the applicable
standards specified in department circular WQB-7, (2) the site-specific standards, or (3) one-half of
II
Unless otherwise spe<:ified. all regulatory citations are to the Administrative Rules of Montana.
ARARS-I0
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the mean instream concentrations" immediately upstream of the discharge point. The effect of this
requirement is to require eventual attainment of the circular WQB-7 levels or site-specific standards in
the stream, while allowing consideration of the current, impacted stream quality (a graduated
reduction of point source discharge concentrations based on the mean instream concentration where
the stream is substantially degraded). As the quality of the stream improves due to control of other
sources, including cleanup of non-point source areas, point source dischargers must improve the
quality of their discharges down to the instream standards (either WQB-7 or, for aquatic life only,
site-specific standards).I.
It should be noted that, because of the ability of the PRPs to integrate tlows mandated to be controlled
by this action into the active mining operation. a point source discharge from this operable unit may
not occur for several years. The "I" classitication discharge standards therefore will be upgraded
every 3 years even if no discharge occurs. Specific discharge standards applicable for the first three
years of this action, effective on the date of the signature of this ROD (assuming a discharge within 3
years of the ROD into Silver Bow Creek below the Colorado Tailings) are shown in Table 1 of this
ARARs analysis..:
Additional "I" classification standards also include the following criteria:
1.
Dissolved oxygen concentration must not be reduced below 3.0 milligrams per liter.
2.
Hydrogen ion concentration (Ph) must be maintained within the range of 6.5 to 9.5.
3.
No increase in naturally occurring turbidity, temperature, concentrations of sediment
and senleable solids, oils, floating solids, or true color is allowed which will or is
likely to create a nuisance or render the waters harmful, detrimental, or injurious to
public health, recreation, safety, welfare, livestock, wild animals, birds, fish or other
wildlife.
4.
No discharges of toxic or deleterious substances may commence or continue which
lower or are likely to lower the overall water quality of these waters.
Additional restrictions on any discharge to surface waters are included in:
ARM 16.20.633 (Applicable), which prohibits discharges containing substances that will:
(a)
settle to form objectionable sludge deposits or emulsions beneath the surface of the
water or upon adjoining shorelines;
(b)
create floating debris, scum, a visible oil film (or be present in concentrations at or in
excess of 10 mi11i~rams per liter) or globules of grease or other floating materials;
IS
Mean insucarn c:onc;c:ntrlllion is the monthly mean instrcarn c:onc:cntrlllion. as defined by the MDMES Water Quality Bureau.
'0
With respcc:t to IIllcast one parameter. arsenic:, it may not be possible to anain the WQB-7 level. The level for .arlCllic:. 18
mg/I. is substantially below the c:ommon c:urrent detcc:tion limit, 111 approximately 3.18 pg/I. Thus anaiDment of this level
may be impouible to verify from an analytic:al perspcc:tive and, for arsenic:, the detection limit may be viewed as the clolCit
prac:tic:a1 substitute for the applic:able WQB-7 standard. Therefore, under the I c:lau standard, the applic:able standard for
arsenic: may prac:tic:a1ly be regarded as one half the monthly mean in the atrcarn, reduc:cd, as inatream quality is improved.
down to the dCleCtion limit.
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(c)
produce odors, colors or other conditions which create a nuisance or render
undesirable tastes to fish flesh or make fish inedible;
(d)
create concentrations or combinations of materials which are toxic or harmful to
human, animal, plant or aquatic life;
(e)
create conditions which produce undesirable aquatic life.
ARM 16.20.925 (Applicable), which adopts and incorporates the provisions of 40 C.F.R. Pan
125 for criteria and standards for the imposition of technology-based treatment requirements
in MPDES permits. Although the permit requirement would not apply to on-site discharges,
the substantive requirements of Pan 125 are applicable, i.e., for toxic and nonconventional
pollutants treatment must apply the best available technology economically achievable (BAT);
for conventional pollutants, application of the best conventional pollutant control technology
(BCT) is required. Where effluent limitations are not specified for the panicular industry or
industrial category at issue, BCT IBA T technology-based treatment requirements are
determined on a case by case basis using best professional judgment (BPJ). ~ CERCLA
Compliance with Other Laws Manual, Vol. I, AUgu.5t 1988. p. 3-4 and 3-7.
2.
Groundwater Pollution Control System (Applicable)
ARM 16.20.1002 (Applicable) classifies groundwater into Classes I through IV based on the present
and future most beneficial uses of the groundwater, and states that groundwater is to be classified .
according to actual quality or actual use, whichever places the groundwater in a higher class. Class I
is the highest quality class; class IV the lowest.
ARM 16.20.1003 (Applicable) establishes the groundwater quality standards applicable with respect to
each groundwater classification. Concentrations of dissolved substances in Class I or II groundwater
(or Class III groundwater which is used as a drinking water source) may not exceed the human health
standards listed in department circular WQB-7. Concentrations of other dissolved or suspended
substances must not exceed levels that render the waters harmful, detrimental or injurious to public
health. Maximum allowable concentration of these substances also must not exceed acute or chronic
problem levels that would adversely affect existing or designated beneficial uses of groundwater of
that classification. ARM 16.20.1003 specifies cenain references that may be used as a guide in
determining problem levels unless local conditions make these values inappropriate.
ARM 16.20.1011 (Applicable) provides that any groundwater whose existing quality is higher than
the standard for its classification must be maintained at that high quality unless the board is satisfied
that a change is justifiable for economic or social development and will not preclude present or
~ticipated use of such waters.
The groundwater quality standards of ARM 16.20.1003, above, have been waived for a ponion of the
bedrock aquifer. because of the impracticability of remediating the bedrock aquifer (see discussion at
the end of the introduction section) in the foreseeable future. However, state ground water quality
standards as well as the state non-degradation standards are applicable for the alluvial aquifer and the
bedrock aquifer outside the TI waiver area. These standards prohibit discharge of contaminated water
from the TI waiver area of the bedrock aquifer to the alluvial aquifer or the bedrock aquifer outside
the TI waiver area. The remedy is structured to preclude such a discharge by keeping an inward
gradient towards the bedrock aquifer waiver area bv an inflow control, and a pump and treat system.
-------
An additional concern with respect to ARARs for groundwater is the impact of bedrock groundwater
upon the alluvial groundwater system or surface water. The remedy mandated by the ROD precludes
any discharge of contaminated groundwater from the East Camp Berkeley Pit and West Camp systems
into the alluvial aquifer and the upper Silver Bow Creek drainage. Any discharge of groundwater
will be through a point source discharge where such a discharge meetS all "I" class standards.
B.
AIR QUALITY
In addition to the standards identified in the federal contaminant-specific ARARs above, the State of
Montana has identified certain air quality standards in the action-specific section of the State ARARs
below.
VII.
MONTANA LOCATION SPECIFIC REQUIREMENTS
A.
Solid W~te Management Regulations (Applicable)
Regulations promulgated under the Solid Waste Management Act, 99 75-10-201 ~~, MCA,
specify requirementS that apply to the location of any solid waste management facility (sludge disposal
facility).I~ Under ARM 16.14.505 (Applicable), a facility for the treatment, storage or disposal of
solid wastes:
(a)
may not be located in a IOO-year floodplain;
(b)
may be located only in areas which will prevent the pollution of ground and surface
waters and public and private water supply systems; and
(c)
must be located to allow for reclamation and reuse of the land.
Additional State Waste Management Regulations are identified below in 'the State Action Specific
requirementS .
VIII. MONTANA ACTION SPECIFIC REQUIREMENTS
In the following action-specific ARARs, the nature of the action triggering applicability of the
requirement is stated in parentheses as part of the heading for each requirement.
A.
WATER QUALITY
1.
Groundwater Act (ADDlicable) (Construction and maintenance of groundwater wells)
Section 85-2-505, MCA, (Applicable) precludes the wasting of groundwater. Any well producing
waters that contaminate other waters must be plugged or capped. and wells must be constructed and
"
These requirements apply, inter alia, to the treatment. storage, or disposal of solid wure. See ARM 16.14.S02( 17).
While 'solid waste' docs not include mining wastes regulated under the mining and reclamation laWi administered by the
Dcpanment of State Lands. !5£ ~ 7S-IO-203( II). MCA. ' DSL has not adopted regulations addrcasing the disposal of
sludgCl or wastes from a water treatment facility such as that proposed for the Mine Flooding Operable Unit. Also, the
current permits issued by DSL for mining operations at this facility do not addrcas disposal of thClC aludgCl. Therefore,
thesc requirements are applicable to the treatment. storage and disposal of thClC sludgCl or wutea. If thesc requirements
were not viewed as applicable. they would be relevant and appropriate requirements for the disposal of thClC aludgCl.
-------
maintained so as to prevent waste, contamination, or pollution of groundwater. This requirement
would apply to the numerous monitoring wells (alluvial and bedrock) employed in .the project.
2.
Water Quality Act (Applicable) (Discharge toPQTW)
Section 75-5-602, MCA, empowers MDHES to require the owner or operator of any point source or
of any facility that discharges to a municipal sewage system to which this chapter's pretreatment
standards apply to keep records, make reports, install, use, and maintain monitoring equipment and to
sample effluent using specified monitoring methods at designated locations and intervals. This
requirement would apply because of the use of the municipal waste water treatment plant in
conU'olling the West Camp system.
3.
Montana Surface Water Qualitv Regulations (Aoolicable) (Sampling Activities)
ARM 16.20.635 (Applicable) provides standards for sampling and analysis of water to determine
quality .
ARM 16.20.642 (Applicable) requires that bioassay tolerance concentrations be determined in a
specified manner.
4.
Public Water Suoolv Regulations (Aoolicable) (Reconstruction or modification of public water
or sewer lines on the site) .
If remedial action at the site requires any reconstruction or modification of any public water supply
line or sewer line, the construction standards specified in ARM 16.20.401(3) (Applicable) must be
observed.
B.
AIR QUALITY
1.
Air Quality Retrulations (Applicable) (Excavation/earth-moving/construction; transportation)
Dust suppression and control of certain substances likely to be released into the air as a result of earth
moving, transportation and similar actions may be necessary to meet air quality requirements.
Certain ambient air standards for specific contaminants and particulates are set forth in the federal
contaminant-specific section above and the state regulations below.
ARM 16.8.814 (Applicable) specifies that no person shall cause or contribute to
concentrations of hydrogen sulfide in the ambient air which exceed the following standard:
hourly average~.05 pans per million, not to be exceeded more than once per year.
ARM 16.8.815 (Applicable) specifies that no person shall cause or contribute to
concenU'ations of lead in the ambient air which exceed the following: 9O-day average-l.5
micrograms per cubic meter of air, 90-day average, not to be exceeded.
Additional air quality regulations under the state Clean Air Act, ~~ 75-2-101 m~, MCA, are
discussed below.
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ARM 16.8.1302 (Applicable) listS certain wastes that may not be disposed of by open
burning16, including oil or petroleum productS, RCRA hazardous wastes, chemicals, and
treated lumber and timbers. Any waste which is moved from the premises where it was
generated and any trade waste (material resulting from construction or operation of any
business, trade, industry or demolition project) may be open burned only in accordance with
the substantive requirementS of 16.8.1307 or 1308.
ARM 16.8.1401(1) and (2) (Applicable) provides that no person shall cause or authorize the
production, handling, transportation or storage of any material; or cause or authorize the use
of any street, road, or parking lot; or operate a construction site or demolition project, unless
reasonable precautions to control emissions of airborne particulate matter are taken.
Emissions of airborne particulate matter must be controlled so that they do not "exhibit an
opacity of twenty percent (20%) or greater averaged over six consecutive minutes." ARM
16.8.1401(1) and (2) (Applicable) and ARM 16.8.1404 (Applicable).
ARM ~ 1~.8.818 (Applicable) provides an ambient air quality standard for settled particulate
matter. Particulate matter concentrations in the ambient air shall not exceed the following 30-
day average: 10 grams per square meter.
The Butte area has been designated by EP A as non-attainment for total suspended particulates, as well
as PM-IO. State requirementS associated with this designation are discussed below.
ARM 16.8.1401(4) (Applicable) requires that any new source of airborne particulate matter
that has the potential to emit ~ than 100 tons per year of particulates shall apply best
available control technology (BACT); any new source of airborne particulate matter that bas
the potential to emit more than 100 tons per year of particulates shall apply lowest acbievable
emission rate (LAER). The BACT and LAER standards are defined in ARM 16.~.t430. A
significant source of the non-attainment for particulates and PM-tO in the Butte area is road
dust. Accordingly, special precautions should be taken in this area to limit dust emissions
from remedial activities.
ARM 26.4.761 (Relevant and Appropriate) specifies a range of measures for controlling
fugitive dust emissions during mining and reclamation activities. Some of these measures
could be considered relevant and appropriate to control fugitive dust emissions in connection
with excavation, earth moving and transportation activities conducted as part of the remedy at
the site. Such measures include, for example, paving, watering, chemically stabilizing, or
frequently compacting and scraping roads, promptly removing rock, soil or other dust-
forming debris from roads, restricting vehicle speeds, revegetating, mulcbing, or otherwise
stabilizing the surface of areas adjoining roads, restricting unauthorized vehicle travel,
minimizing the area of disturbed land, and promptly revegetating regraded lands.
2.
Control of Odors
ARM ~ 16.8.1427 (Applicable). If a business or other activity (Le. treatment facility) will create
odors, those odors must be controlled, and .no business or activity may cause a public nuisance.
..
"Open burning' means combustion of-any material directly in the open air without a receptacle. or in a receptacle other
than a furnace, multiple chambered incinerator or wood waite burner.... ARM 16.8.1301(5).
ARARS-IS
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3.
Monitorine:
ARM 16.8.807 (Applicable) states the methods that must be followed in all ambient air monitoring.
ARM 16.8.809 (Applicable) specifies that sampling, data collection, recording and data analysis must
be performed as specified in this section.
C.
SOLID WASTE MANAGEMENT
Preliminary treatability studies have indicated that the sludge generated by the treatment process
designated by the ROD may not be a characteristic hazardous waste. While cenain hazardous waste
regulations could arguably be identified as relevant and appropriate requirements, the applicable state
solid waste management regulations (ARM 16.14.500 et. sea.) have been determined to be
appropriate regulations for the management of sludges that are not characteristic hazardous waste. It
is possible that the sludges produced may be characteristic hazardous waste, either becaUse an
alternate treatment system is ultimately utilized or because the process identified in the ROD, once
implemented, actually generates characteristic hazardous sludges. If this is the case, the state
hazardous waste regulations will be applicable.
Solid Waste Management Act (Applicable)
Regulations promulgated under the Solid Waste Management Act, ~75-10-201 ~ seq.. MCA. place
restrictions and requirements on the ultimate disposition of sludges to be generated by this action:
ARM 16.14.504 (applicable) restricts those various types of wastes that disposal sites may
handle.
ARM 16.14.505 (applicable) sets forth standards that all solid waste disposal sites must meet.
ARM 16.14.506 (Applicable) sets forth the applicable criteria for design of a landfill
repository .
ARM 16.14.520 and 521 (applicable) set forth the general and specific operation and
maintenance requirements for solid waste management systems.
ARM 16.14.523 (applicabfe) specifies that solid waste must be transponed in such a manner
as to prevent its discharge, dumping, spilling, or leaking from a transpon vehicle.
ARM 16.14.530 and 531 (applicable) set forth the requirements for closure of a landfill
repository and the requirements for post-closure care.
The ROD indicates that possible disposal of sludges in the Berkeley Pit will be considered by the
agencies when sludge disposal becomes necessary and the composition of the sludge is known. .In
considering options for disposal, the agencies will determine whether certain of the otherwise
applicable hazardous or solid waste requirements may be waived on the basis that such disposal will
attain a standard of performance that is equivalent to that required under the otherwise applicable
standard or requirement through use of another method or approach, as provided in 40 CFR ~.
300.430(t)( 1 )(ii)(C)( 4).
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D.
MONTANA DAM SAFETY ACT (Applicable)
Regulations pursuant to the Dam Safety Act,17 99 85-15-101 ~, MCA, are discussed below.
"Dams", as used in the act and these regulations includes any artiticial barrier used to impound or
divert water with an impounding capacity of 50 acre feet or greater.
ARM 36.14.202 (applicable) states that all dams and reservoirs which divert or store water must be
constructed in a secure, thorough, and substantial and safe manner.
ARM 36.14.501 (applicable) states that all high hazard dams must comply with the criteria given.
ARM 36.14.502 (applicable) states that all high hazard dams must be able to safely pass the flood
calculated from the inflow design flood.
IX. ,
OTH[ " ..IONT ANA LAWS
The following "other laws" are included here to provide a reminder of other legally applicable
requirements for actions being conducted at the site, They do not purport to be an exhaustive list of
such legal requirements, but are included because they set out related concerns that must be addressed
and, in some cases, may require some advance planning. They are not included as ARARs because
they are not "environmental or facility siting'laws." As applicable laws other than ARARs, they are
not subject to ARAR waiver provisions. Section 121(e) of CERCLA exempts removal or remedial
actions conducted entirely on an NPL site from federal, state or local permit requirements, and this
exemption is considered broad enough to cover even permits required under "other laws."
A.
Groundwater Act
Section 85-2-516, MCA, states that within 60 days after any well is completed a well log report must
be filed by the driller with the DNRC and the appropriate county clerk and recorder.
B.
Occupational Health Act, 99 50-70-101 ~ ~., MCA.
ARM 9 16.42.101 addresses occupational noise. In accordance with this section, no worker shall be
exposed to noise levels in excess of the levels specified in this regulation. This regulation is
applicable only to limited categories of workers and for most workers the similar federal standard in
29 CFR 9 1910.95 applies.
ARM 9 16.42.102 addresses occupational air contaminants. The purpose of this rule is to establish
maximum threshold limit values for air contaminants under which it is believed that nearly all
workers may be repeatedly exposed day after day without adverse health effects. In accordance with
this rule, no worker shall be exposed to air contaminant levels in excess of the threshold limit values
listed in the regulation. This regulation is applicable only to limited categories of workers and for
most workers the similar federal standard in 29 CFR 9 1910.1000 applies.
17 , Identification of these requirements as ARARs does nOI impair, alter or affect the regularory jurisdiction or authority of
the Montana Ccpartment of Slate Lands or Department of Natural Rcsourcca and COlIICrVation over the Active Mine
Area. including the Yankec Doodle Tailings Dam,
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C.
Montana Safety Act
Sections 50-71-201, 202 and 203, MCA. state that every employer must provide and maintain a safe
place of employment, provide and require use of safety devices and safeguards. and ensure that
operations and processes are reasonably adequate to render the place of employment safe. The
employer must also do every other thing reasonably necessary to protect the life and safety of its
employees. Employees are prohibited from refusing to use or interfering with the use of safety
devices.
D.
Employee and Community Hazardous Chemical Information Act
Sections 50-78-201, 202, and 204, MCA, state that each employer must post notice of employee
rights, maintain at the work place a list of chemical names of each chemical in the work place, and
indicate the work area where the chemical is stored or used. Employees must be informed of the
chemicals at the work place and trained in the proper handling of the chemicals.
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BUTTE MINE FLOODING OPERABLE UNIT RECORD OF DECISION
I CLASSIFICATION liMITATIONS FOR YATER DISCHARGED TO SilVER BOY CREEK BElOY THE COLORADO TAiliNGS FROM THE MINE FLOODING OPERABLE UNIT
Total Recoverable Concentrations (~g/l)
Discharge limitations Arsenic Cadnlun Copper lead Zinc Iron
Jaml8ry 4.5"
Monthly Average 1.6" 124" 9.5" 431" 1000"
Daily Maxlnun 6.75" 5.0" 188" 15" 64r 1500"
February 4.5" 1.6"
Monthly Average 98" 5.6"" 416" 1000"
Dally M..xlnun 6.75" 5.0" 14r 15" 624" 1500"
March
Monthly Average 6.5" 1.6" 132" 5.6" 448.5" 1000"
Daily Maxlnun 9.75" 5.0" 19r 15" 673" 1500"
Apr Il 6.5" 1.6" . 129" 5.6" 444"
Monthly Average 1000"
Daily Maxlnun 9.75" 5.0" 194" 15" 666" 1500"
May 6.1" 1.6" 115" 5.6" 443.5"
Monthly Average 1000"
Dally Maxlnun 9.15" 5.0" 173" 15" 665" 1500"
JU1e
Monthly Average 5.5" 1.6" 112" 5.6" 482" 1000"
Daily Maxlnun 8.25" 5.0" 168" 15" 723" 1500"
July 6.75" 1.6" 118" 13" 492" 1000'
Monthly Average
Daily Maxlnun 10.13" 5.0" 176" 15" 738" 1500.
August 6" 1.6" 95" 5.6" 476"
Monthly Average 1000'
Daily Maxlnun 9.00" 5.0" 143" 15" 714" 1500.
September 4.5" 2.9" 150' 11.8" 750' 1000'
Monthly Average
Dally Maxlnun 6.75" 5.0" 225" 15" 1125" 1500"
October
Monthly Average 4" 1.6" 98.5" 5.6" 445" 1000'
Daily Maxlnun 6.00" 5.0" 148" 15" 668" 1500.
November 6"
Monthl y Average 1.6" 132" 7.25" 465" 1000"
Daily Maxlnun 9.00" 5.0" 19r 15" 698" 1500"
December 5.5" 1.6"
Monthly Average 130" 7.5" 442" 1000"
Daily Maxlnun 8.25" 5.0" 195" 15" 663" 1500.
" Primary Drinking Yater Standard (Safe Orlnking Yater Act).
" Chronic Yater OUellty Criteria
" Acute Yater Quality Criteria
" one-half Monthly Mean (Table 2)
" 150 percent of the Monthly Average Discharge limitation
. Effluent limitation (40 C.F.R. 440.102)
NOTE: Presently, there is no specific discharge criteria for sulfate. However, a maximum contaminant level (MCl)
within the next 18 months. This health-based MCl will become an enforceable discharge standard at that time.
for sulfate Is expected to be proposed
"
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-
TECHNICAL IMPRACTICABILITY EV ALUA TION
APPENDIX 2
BUTIE MINE FLOODING OPERABLE UNIT
RECORD OF DECISION
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Technical Impracticability Evaluation
Bedrock Aquifer
Butte Mine Flooding Operable Unit
Page
I. 0 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-1
1.1 Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-1
1.2 Site Description and History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-2
2.0 Evaluation of Technical Impracticability. . . . . . . . . . . . . . . . . . . . . . . . . . 11-4
2.1 Waiver of Ground Water ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . 11-4
2.2 Definition of Technical Impracticability Zone. . . . . . . . . . . . . . . . . . . 11-4
2.3 Site Description and Conceptual Model. . . . . . . . . . . . . . . . . . . . . . 11-5
2.3.1 Geology and Hydrogeology. . . . . . . . . . . . . . . . . . . . . . . . 11-5
2.3.1.1 Geology of the Bedrock Aquifer. . . . . . . . . . . . . . . 11-5
2.3.1.2 Hydrogeology of the Bedrock Aquifer. . . . . . . . . . . . 11-5
2.3.1.3 Mining's Impact on the Bedrock Aquifer. . . . . . . . . . 11-6
2.3.2 Source, Volume. and Quality of Ground Water. . . . . . . . , . . . 11-7
2.3.2.1 Ground Water and Contamination Sources. . . . . . . . . 11-7
2.3.2.2 Ground Water Volume. . . . . . . . . . . . . . . . . . . . . 11-8
2.3.2.3 Ground Water Quality, . . . . . . . . . . . . . . . . . , . . 11-9
2.3.3 Contaminant Transpon Pathways. . . , . . , . . . . . . . . . . : . . 11-10
2.3.3.1 Current Hydraulic Control. . . . . . . . . . . . . . . . . . 11-10
2.3.3.2 Future Hydraulic Control. , . . . . . . . . . . . . . . . . . 11-10
2.4 Bedrock Aquifer Remediation Potential. , . . . . . . . . . . . . . . . . . . . 11-11
2.4.1 Source Control Measures. . , . , , . . . . . , . . . . . . . . . . . . 11-11
2.4.2 Remediation Potential Evaluation, ", . . . . . . . . . . . , . . . . . 11-11
2.4.2.1 Pump-and- Treat.. .. . .. .. .. .. .. .. . .. . .. . 11-11
2.4.2.2 Inundation. . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-12
2.4.2.3 Grouting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-13
2.4.2.4 Injection of Acid Neutralizing Fluids. . . . . . . . . .. 11-13
2.4.3 Cost Consideration. . . . . . . . . . . . . . . . . . . . . , . . . . . . 11-13
2.4.3.1 Pump-and-Treat ........................ 11-13
2.4.3.2 Inundation. . . . . . . . . . . . . . . . . . . . . , . . . , . . 11-14
2.4.3.3 Grouting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-14
2.4.3.4 Injection of Acid Neutralizing Fluids. . . . . . . . . . . 11-15
2.5 Alternative Remediation Strategy. . . . . . . . . . . . . . . . . . . . . . . . . 11-16
3.0 Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-19
4.0 References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-20
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1.0 Introduction
1.1 Executive Summary
In this report the U.S. Environmental Protection Agency (EPA) and th~ Montana Department
of Health and Environmental Sciences (MDHES) present the technical support for the
application of a Technical Impracticability (TI) Waiver for the bedrock aquifer present in the
East and West Camp areas of the Butte Mine Flooding Operable Unit (BMFOU). The
ground water Applicable or Relevant and Appropriate Requirements (ARARs) for the
bedrock aquifer include the National Primary Drinking Water Standards (40 C.F.R Part 141)
and the Montal. . ...round Water Quality Standards (ARM 16.20.1003). The ground water
present in the bedrock aquifer shows concentrations of arsenic, lead. cadmium, and copper at
levels exceeding MCLs and state ground water quality standards. Although many other
metals are found in the bedrock aquifer of the TI zone at elevated levels, compared to
background, only these fou~ exceed a primary drinking water standard. The exceedances and
elevated concentrations are a result of the presence of oxygen, water. and the massive source
of sulfidic minerals (i.e.. the native ore) present in the bedrock. mobilization of which has
been enhanced by past mining activities (ARCO, 1994a). .
The cause of the contamination within the TI zone is acid mine drainage. Acid Mine
Drainage (AMD) requires three things: water. oxygen, and a source of sulfur. At this site,
the source of sulfur is the native mineralized ore, such as pyrite (iron disulfide FeS2) in the
bedrock.
The oxidation of sulfidic and mineralized ore in the presence of water, releasing the metals
to the water and lowering the pH of the water is a natural process. Examples of naturally
occurring acid rock drainage, or ARD. can be found in the United States. However, this
same natural process is magnified by the activities of man. such as mining; thus the term
acid mine drainage. Further. the acidic water gradually dissolves more sulfides in the
bedrock, which in turn contribute more dissolved metals and sulfate to the ground water; a
son of "snowball" effect.
To stop or control AMD requires limiting or eliminating one of the three factors: water,
oxygen, or source material.
The bedrock aquifer within this site, the Butte Mine Flooding Operable Unit, requires a TI
waiver' because:
.
From a practical standpoint, it is not feasible to use source removal to remediate the
This Tl waiver relate; only to this specifIC operable unit and is not an indication of intent or policy with
respect to any other operable unit or site. This TI waiver does not affect the requirements of any other
federal. state. or local r~ulation: nor is the waiver I1n allowance to permit further degradation of the
bedrock aquifer. The ,"'Ontamination of the bedrock aquifer at the Butte Mine Floocliq Operable Unit
is a unique situation and may not be analogous to any other site.
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ground water to attain the prescribed ARARs. The sheer size of the source,
calculated to be 27 billion cubic yards, would leave an open pit about 62 times larger
than the current Berkeley Pit, would eliminate the historic city of Butte, and would
have untold environmental consequences;
.
Engineering controls to limit or eliminate water flow into and within the bedrock
aquifer by conventional or innovative methods on a site of this size and nature has
never been attempted, final ability to attain ARARs is debatable, and cost calculations
place the attempt at 7 to 10 billion dollars. The site is complicated by the
anastomotic2 nature of the mine workings. There are no less than three thousand
(3000) miles of interconnecting underground mine workings within the 6.75 mile TI
zone;
.
Lowering the ground water level in the bedrock aquifer via pumping would
exacerbate (degrade) the existing water quality by elevating acidity (lower pH) and
increasing concentrations of metals. Further. >:wering the ground water level would
perpetuate the problem as pumping only exposes more source material to oxidation
and acid generation; and
.
The selected remedy proposed for the BMFOU, maintaining the Berkeley Pit as a
hydraulic sink, will effectively prevent migration of contaminated bedrock ground
water within the TI zone from impacting the Silver Bow Creek/Blacktail Creek
drainages and the associated alluvial aquifer. Similarly, ground water controls to be
implemented at the Travona Shaft will prevent off-site migration of contaminated
bedrock ground water from the West Camp to Silver Bow Creek. However, the
selected remedy for the site will not meet ARAR requirements for ground water.
All of the points and issues presented in this introduction section will be discussed further in
the Technical Impracticability Evaluation.
1.2 Site Description and History
The area to be considered for the TI waiver is located in southwestern Montana in and near
the City of Butte (Figure 1). The TI zone (shown in Figure 2) is within the Butte mining
district in the upper Silver Bow Creek (SBC) drainage and covers an area of approximately
6.75 square miles. Thp.re are two cistinct hydrologic systems within the TI zone, the East
and West Camp systems. The West Camp system is located in the west-central portion of
the city of Butte and includes the Travona, Ophir and Emma shafts and associated
underground mine workings. The East Camp system is located in the east-northeast portion
of the Butte mining district and consists of the Berkeley Pit and related underground mine
workings. The two systems are separated hydraulically by bulkheads installed in mine shaft
drainage levels during the late 1950s. However, the integrity of the bulkheads is not known.
2
Anastomotic means "not witbout a connection". With the extensi.e mine workings and fractures in the
TI zone, the bedrock with respect to water is accurately described as anastomotic.
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and they may be subject to deterioration and possibly failure (CDM FPC, 1990).
Extensive underground and open pit mining activities have been prevalent throughout the TI
zone since gold was first discovered in Butte in 1864. Underground mining began in the
1880s and by 1964, several thousand miles of underground workings had been driven into
the bedrock. Estimates of th~ extent of mine workings range from 3000 miles for major
shafts, levels, and drifts, to 10,000 miles for total workings within the 6.75 square miles of
the TI zone (James, 1980). This extensive network of mine workings has created an
anastomotic condition; an analogy might be made to a heavily riddled swiss cheese. Table I
lists the underground mines located within the Butte Mining District. When underground
mining stopped in 1982, the workings had descended to below 1500 feet above mean seal
level (ft msl)[United States Geological Survey (USGS) datum]. The surface el( vation within
the TI zone ranges from about 5400 ft mls to about 6200 ft msl.
Large scale open pit (the Berkeley Pit) mining began in 1955. When mining was
discontinued in 1982, the bottom of the pit was at an elevation of 4,265 ft msl. The total
depth of the pit from the bottom to the highest point on the rim is 1,780 feet. The pit
encompasses approximately 675 acres (1.06 square miles) and has a volume of approximately
1.18 x 1010 cubic feet from the base to the rim at an elevation of 5,543 ft msl (ARCa,
1994a). The Pit would contain just under 89 billion gallons of contaminated water if allowed
to fill unregulated to this rim. .
To facilitate mining activities, the naturally occurring ground water level was lowered
approximately 4,200 feet from pre-mining levels via pumping. With the cessation of active
mining in the Berkeley Pit in 1982, the pumping system ceased operating and the
underground mines and the Berkeley Pi,t began to flood. The presence of water in the mine
workings during and after mining, in combination with the oxidation of the naturally
occurring sulfide minerals has resulted in generation of acidic solutions and the releasing of
metals and sulfate into the bedrock aquifer. If the two hydrologic systems (mine workings
and pit) were allowed to flood, recovering to natural pre-mining conditions without
regulatory intervention, there would be a release of the contaminated waters (AMD) from the
TI zone and into Silver Bow Creek and the Butte alluvial aquifer. However, the.selected
remedy will permanently manage water levels in the two systems, with the focus being the
Berkeley Pit maintained as a sink for the AMD.
TI-3
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2.0 Evaluation of Technical Impracticability
In accordance with CERCLA Section 12l( d)( 4)(C) and the National Contingency Plan. 40
CFR ~300A30(f)(1)(ii)(C)(3), EPA may select a remedial action that does not attain an
ARAR if compliance with that ARAR is technically impracticable from an engineering
. perspective. This section presents an evaluation of the components for a 11 waiver in
accordance with "Guidance for Evaluating the Technical Impracticability of Ground Water
Restoration" (EPA. 1993).
2.1 Waiver of Ground Water ARARs
The ground watet Applicable or Relevant and Appropriate Requirements (ARARs) for the
bedrock aquifer include the National Primary Drinking Water Standards (40 C.F.R. Pan
141) and the Montana Ground Water Quality Standards (ARM 16.20.1003). Within the 11
zone. these ARARs are waived for the following constituents: arsenic. cadmium. lead.
copper. and sulfate if a primary MCL is established for sulfate. These are the only site-
related ground-water contaminants that exceed ARARs. Table 2 lists the metal constituents
for which the ARAR waiver is invoked. along .with the applicable water quality standard.
Table 2 also gives the mean and highest value of water quality data for other elevated
constituents within the shafts (mine workings) and bedrock monitoring wells (fracture zone)
of the 11 area.
In cases where it is not practicable to return usable ground water to its beneficial uses within
a time frame that is reasonable given the panicular circt:mstances of a site. EPA expects to
a) prevent migration of contaminated water from the 11 zone. b) prevent exposure to
contaminated ground water within the 11 zone. and c) evaluate funher risk reduction (40
C.F.R 9 300.430 (a) (1) (iii) (F»). Because it is not technically practicable from an
engineering perspective to attain these groundwater quality standards in the designated area
within the bedrock aquifer. a waiver is invoked f')r these ground water ARARs.
2.2 Definition of Tecbnical Impracticability Zone
The horizontal extent of the 11 zone is defined primarily by the extent of underground mine
workings and/or extent of documented influence of mine workings on the bedrock aquifer.
The venical extent of the 11 zone is defined by the elevation of the lowest underground mine
workings which has been determined to be approximately 1500 ft msl (AIME. 1968).
Additionally. the 11 zone represents the outer boundary of the area(s) within the cone of
influence of the historically dewatered East and West Camp hydrologic systems (see Section
1.1). .
The area to be included in the bedrock aquifer 11 zone is shown in Figure 2. This area
represents the potential contaminated bedrock aquifer and encompasses the area of
underground mine workings. However. major landmarks (roads) were utilized to assist in
the subsequent institutional controls that will follow a 11 waiver. This area covers both the
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East and West Camp areas of the Butte Mining District. and is approximately 6.75 square
miles in area.
2.3 Site Description and Conceptual Model
2.3.1 Geology and Hydrogeology
To develop a site conceptual model of the bedrock aquifer, three topics require consideration
to evaluate this TI waiver: the geology. hydrogeology, and mining's impact on the bedrock
aquifer.
2.3.1.1 Geology of the Bedrock Aquifer
The Butte area is underlain by igneous rocks of the Boulder Batholith. which consists
primarily of quam monzonite that has been intruded by rhyolite and porphyry dikes (AIME.
1968). This bedrock contains disseminated ore vein deposits of copper and other metals,
primarily in sulfide form. The area was and continues to be of interest to the mining
industry .
The bedrock can be subdivided into a weathered zone and a competent bedrock zone.
Weathered bedrock is native ore that has oxidized in place over geologic time and is
"incapable" of producing an acid rock drainage. Where present, the weathered bedrock is
100 to 200 feet thick and consists of clay interspersed with I to 10 inch fragments of
monzonite. Frequently, the weathered bedrock functions as a confining layer. limiting water
and oxygen movement between the alluvium and the deeper competent bedrock. The
competent bedrock consists of unoxidized quam monzonite and is encountered in the TI zone
at depths ranging from 250 to more than 750 feet below the ground surface as documented
by logs of diamond drill holes (DDHs). mine shafts. and monitoring wells installed as part of
the Remedial Investigation (RI) (ARCa. 1994a).
There is limited alluvial material within the TI zone. What alluvial material there is in the
TI zone is confmed to the eastern and southeastern region of the Berkeley Pit. This is the
historic flood channel of Silver Bow Creek, pre-Berkeley Pit. North and west of the
Berkeley Pit, only very thin deposits of alluvial material can be found; frequently it is non-
existent.
2.3.1.2 Hydrogeology of the Bedrock Aquifer
The flow of water within the TI zone is dependent on the extent of mine workings associated
with any ponion of the area. Flow within the area west of the Berkeley Pit, especially those
areas associated with the Kelley Mine workings which are connected to the Berkeley Pit, is
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best characterized by a pipe network model (Ralston, 1994). Pipe network models are
typically used to evaluate water distribution systems for cities and plants. These models use
the length and size of pipes and friction factors to relate flow rates to water pressure and
friction losses. Application of a network model to the mine workings best simulated
experimental data (Ralston, 1994). Areas with less workings and/or caving of workings,
plus the remainder of the TI zone, have flow best characterized by a fractured media model.
Ground water within the TI zone is primarily stored .within fractures. However, the
thousands of miles of open and caved underground workings increase the amount of aquifer
storage by about 13 percent.
Based on geophysical logging data, localized fracture zones within the competent bedrock
extend at leas! as deep as 350 feet below the weathered/competent bedrock interface
(Canonie, 1992). These fractures contain ground water, most of which is encountered in the
upper 1000 feef of the bedrock. The yield of water from bedrock wells ranges from less
than 1 to more than 50 gpm (CDM FPC, 1990). The equivalent fracture porosity of the
bedrock aquifer is estimated to be 1 percent (ARCa, 1994a). Previous investigations at the
site calculated a fracture porosity for the bedrock in a shallow and highly fractured area of 5
percent (Metesch, 1990). This value represents an upper limit for the site. The TI zone. as
a general description, is best characterized as a large fractured crystalline system. Literature
citations for fractured crystalline rock (in the range of 1 percent porosity) were used as a
reasonable value for the site.
Hydraulic propenies of the bedrock aquifer were determined from rising-head and constant
discharge tests (see Section 6.4 of RI (ARCa, 1994a) for complete discussion of bedrock
aquifer characterization). The rising-head test data (seven wells tested) showed that
hydraulic conductivity values range from 7.1 x 10-6 to 3.46 X 10-4 centimeters per second
(cm/sec) with an average of 1.34 x 10-4 cm/sec. Aquifer transmissivity, as estimated from
constant discharge test data, ranges from 9.9 gallons per day per foot (gpd/ft) to 99.0 gpd/ft.
As discussed in Section 2.3.1.1, the alluvium in the TI zone is essentially limited to an area
east and southeast of the Berkeley Pit. A complete characterization of the alluvial aquifer
can be found in Section 7.4 of the RI (ARCa, 1994a). The primary direction of ground
water flow in the alluvial aquifer is southwest of the Leach Pads Area (nonheast of the Pit)
and then west towards the Berkeley Pit (see Figure 3). A ground water divide exists in the
alluvial aquifer south of the Berkeley Pit. Nonh of the divide, ground water flows towards
the Berkeley Plt. A numerical ground water flow model developed for the RI (Section 11)
indicates that this pattern of ground water flow will continue even as the water in the
Berkeley Pit approaches 5410 ft msl (see Section 2.3.3.2 for significance of this elevation).
2.3.1.3 Mining's Impact on the Bedrock Aquifer
To facilitate underground and open pit mining the bedrock aquifer was dewatered. via
pumping. In addition to temporal dewatering, mining activities resulted in the excavation of
no less than 3,000 miles (James, 1968) of underground workings in the bedrock. This has
resulted in an extensive network of drainage galleries and conduits and has significantly
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elevated the storage capacity of the bedrock aquifer throughout the 11 zone (over 900 million
cubic feet or 6.8 billion gallons (Stephenson. 1994».
Figures 4 and 5 show the underground mine workings in plan view and cross section,
respectively. As shown on Figure 4 the underground mine network is more extensive in the
East Camp than in the West Camp. As shown on Figure 5. several of the mine shafts and
drifts directly intersect the Berkeley Pit. Thus. the hydraulic connection between the pit and
the bedrock aquifer consists of both the mine workings network and to a lesser degree by the
bedrock fracture system. .
Prior to bedrock aquifer dewatering. the regional ground water tlow in the bedrock was
approximately fr'1m north to south with discharge to alluvium along Silver Bow Creek
(SBC). Mine dewatering created a large cone of depression in the original potentiometric
surface. When mining and dewatering operations ceased in 1982. the ground water began
rising toward its premining equilibrium condition.
The influence of the underground workings on the hydraulic conditions within the bedrock
aquifer can be seen by comparing the extent of underground workings (Figure 4) with the
current configuration of the bedrock aquifer potentiometric surface as shown in Figure 6.
Comparison of these figures shows that a hydraulic cone of depression is centered about the
Berkeley Pit which is acting as a hydraulic sink. The shape of the cone of depression is
elongated over the area containing underground workings, reflecting hydraulic influence
(drainage) of the workings.
2.3.2 Source, Volume, and Quality of Ground Water
2.3.2.1 Ground Water and Contamination Sources
The source of water in the 11 area is shown in Figure 7. The Inflow Control Investigation
of the RI found that the average rate of flooding to the Berkeley Pit is about 5 million
!?allons per day (mgd) (ARCa. 1994a). Inflow to the Berkeley Pit from all surface water
tlows averages 1.68 mgd, the majority of which comes from the Horseshoe Bend area.
Alluvium contributes 0.58 mgd. The bedrock aquifer accounts for 2.49 mgd of the inflow
(49%). The origin of this bedrock inflow water is predominately precipitation/runoff and is
the natural recovery of a dewatered system. A 0.30 mgd component of inflow to the'
Berkeley Pit is a combination of direct precipitation, adjacent runoff, and evaporation..
The source of contamination to the ground water in the bedrock aquifer is sulfidic and
mineralized rocks (i.e., natural ore). This source is the massive ore body within the 11 zone
and the source produces contaminants when oxygen and water are available. The volume of
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the source is estimated to be approximately 736 billion cubic feet' or about 27 billion cubic
yards. However, due to current and progressing flooding of the underground workings with
water (natural inundation or flooding). the source of contaminants is gradually being removed
as a source. As oxygen in the water has been consumed by AMD reactions. the water is
"oxygen poor" and AMD reactions are greatly slowed. i.e.. the source is removed from
AMD production.
2.3.2.2 Ground Water Volume
Ground water in or hydraulically connected to the bedrock aquifer is present in three storage
systems which a "e interconnected throughout the area of the 11 zone and cover an area of
6.75 square mile~.
. The tirst storage system is the Berkeley Pit which. as of July 1994 (ARCa, 1994a),
contains about 24 billion gallons of impacted water. The Berkeley Pit is approximately
5.280 feet wide and 1,780 feet deep at its deepest point. The area of the pit is approximately
675 acres or 1.06 square miles. Based on the pit dimensions. the volume of water contained
within the pit at the CWL of 5.410 ft msl is estimated to be 64 billion gallons (ARCa,
1 994a).
. The second storage system consists of underground openings from past mining. Mining
within the 11 zone has resulted in approximately 3.000 miles of workings (James, 1968)
which are documented or assumed to be connected with the Berkeley Pit. The volume of
ground water which may be present in old mine workings is assessed to be approximately 6.8
billion gallons (Stephenson. 1994).
. The third storage system is the ground water in fractures throughout the area of 11 zone.
The bedrock within the 11 zone is highly fractured and jointed as a result of ore-body
fonnation. weathering, and mining-induced fracturing and caving. The total volume of
ground water contained in the fractured ponion of the bedrock aquifer can be estimated by
taking the total bedrock aquifer volume within the 11 zone. subtracting the estimated volume
of underground workings and the Berkeley Pit. and multiplying the result by an average
fracture porosity. Considering that the 11 zone encompasses 6.75 square miles (Figure 2),
with a fracture porosity of the bedrock of 1 percent (ARCa, 1994a) and a lower boundary of
11 zone of 1,500 ft msl, the volume of water stored in fractures is approximately 54.3 billion
gallons.
A comparison of volumes of ground water present in the three storage systems in the bedrock
aquifer is shown in Figure 8. The calculations of the bedrock aquifer volume contained
within the 11 zone bedrock aquifer are presented in Appendix A. The total volume of
ground water stored in the bedrock aquifer in natural or man-made features within the area
The volume of source has been estimated by: [Volume in TI zone] - [Volume of underground workin~)
- [Volume of Berkeley Pit] - [Volume of fractures in bedrock]. Volume of TI zone was oMtim..~ as
surface area (6.75 sq. mile:s) times depth (4000 feet). See Attachment 1 for complete caJculatioos.
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for which the TI waiver is granted is approximately 125 billion gallons.
2.3.2.3 Ground Water Quality
. The ground water present within the bedrock aquifer displays a different chemical makeup
depending on the storage system in which the water is present. Table 2 summarizes the
range of concentrations for the four constituents (arsenic, cadmium, copper, and lead) for
which the ARAR waiver is being sought. Table 2 also gives the mean and highest value of
water quality data of other elevated constituents within the shafts (mine workings) and
bedrock monitoring wells (fracture zone). Figure 9 presents location specific water quality
data for the bedrock monitoring wells, mine shafts, and the Berkeley Pit.
-
As shown in Table 2, water quality of the Berkeley Pit shows high levels of all the
constituents. The water quality within the pit is a result of inflow from the bedrock aquifer,
the alluvial aquifer, surface run-off, and discharge of mill process water (tailings slurry
water occasionally discharged to the Berkeley Pit as the result of tailings pipeline failure).
Surface inflow (i.e., Horseshoe Bend water) has a chemical makeup very similar to Berkeley
Pit Water. As presented previously, this inflow component accounts for one-third of the
current inflow (historically, over 45 %) to the Berkeley Pit. The quality of water in the
Berkeley Pit does not show an improving trend based on five sampling events from 1984 to
1991 (ARCe, 1994a).
The quality of the ground water present in the underground workings (shafts) within the TI
zone also show elevated concentrations of constituents (~ Table 2). Ground water quality
present in the underground workings has been determined from samples taken from 12 shafts
(ARCe, 1994a). The quality of ground water stored in mine workings shows a trend of
improving wat~r quality. For eJ(:ample, the concentration of copper in the pumped waters
from several mines (in the early 196Os) varied between 155 milligrams per liter (mg/L) and
592 mg/L; average of 363 mg/L. The RI showed copper concentrations ranging from a
minimum of 0.24 mg/L (Anselmo Mine shaft), to 0.965 mg/L (Steward Mine shaft), to 1.28
mg/L (Granite Mtn. Mine shaft). The improvement is due to the fact that flooding of the
workings is restricting the amount of oxygen contacting the mineralized portion of the
bedrock thus preventing the continued generation of acid mine drainage.
The ground water quality of the fractured bedrock as determined from bedrock monitoring
wells shows low concentrations of the four constituents with few exceedances. Ground water
quality trends in the fractured bedrock have been determined from samples taken from
bedrock monitoring wells during RI (ARCe, 1994a). Note, these bedrock monitoring wells
are located away from mine workings and frequently are on the outer boundary of the TI
zone. Although these wells indicate a cleaner water than that which would be found closer
to the Berkeley Pit, a well placed in this area and having sufficient production capacity,
could be expected to pull contaminants towards the well. The systems (Berkeley Pit, mine
workings, and fractures) are connected to each other within the TI zone.
TI-9
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2.3.3 CODbmioaot Transport Pathways
For contaminants to be transported from the 11 zone into the Butte alluvial aquifer and Silver
Bow Creek drainage, two conditions must be met. First - a connection (pathway) between
the 11 zone and the Butte alluvial aquifer and Silver Bow Creek drainage must exist. This
condition exists for the bedrock aquifer and alluvial aquifer. Second - a hydraulic gradient
must exist to facilitate ground water flow out of the bedrock aquifer and into the alluvial
aquifer. For the bedrock aquifer within the 11 waiver area this condition is nOt met at
present and will not be met in the future because of proposed ground water level controls,
which will preclude any movement of contaminated bedrock ground water to areas outside of
the 11 waiver zone. See Section 2.5. Alternative Remediation Strategy. for a summary of
the selected remedy.
2.3.3.1 Current Hydraulic Control
Under current conditions. the bedrock aquifer ground water in East and West Camp does not
migrate beyond the boundaries of the 11 zone because the Berkeley Pit is acting as a
hydraulic sink. A map showing positioning of the water levels in the bedrock aquifer in the
East Camp demonstrating flow into the Berkeley Pit is shown in Figure 6. Figure 5 presents
a cross-section showing the current ground water flow conditions into the pit.
2.3.3.2 Future Hydraulic Control
Easr Camp Sysrem
In the development and negotiations of the Administrative Order on Consent [Docket No.
CERCLA VIll-90-09 (EPA. 1990)] (AOC) for the BMFOU RI/FS the potentially responsible
panies (PRPs) agreed to maintain the water level in the Berkeley Pit/East Camp system
below a preliminary Critical Water Level (CWL) of 5,410 ft ms!. This elevation
corre;)ponds to the lowest documented occurrence of ground water in the alluvial aquifer of
the Summit Valley (i.e.. the alluvial valley south and southwest of the Berkeley Pit).
Consequently, maintaining this level will prevent any future migration of water' from the
Berkeley Pit into the Silver Bow Creek. the Metro Storm Drain and Blacktail Creek. EPA
and MDHES have determined that the CWL will be protective of the alluvial aquifer and
surface flows. However. to ensure that an inward gradient is maintained within the bedrock
aquifer. monitoring of future water levels will be conducted. As illustrated in Figure 5,
maintaining the ground water below the CWL will ensure that a hydraulic gradient toward
the Berkeley Pit in the bedrock aquifer exists over the East Camp section of the 11 zone.
Wesr Camp System
Water levels in the bedrock aquifer in the West Camp are significantly higher than those in
the East Camp (approximately 5A20 ft msl vs 5.060 ft msl based on July 1994 data.
respectively). This difference is the result of hydraulic separation of these tWo sections by a
-------
system of bulkheads in the mine workings. The approximate locations of the bulkheads are
shown in Figure 4. In the future, the water levels will be controlled. utilizing the Travona
Shaft as the control/pumping location. at or below a level of 5.435.6 ft msl (EPA, 1990).
2.4 Bedrock Aquifer Remediation Potential
This section presents an evaluation of the remediation potential of the bedrock aquifer. The
remediation potential of the bedrock aquifer is addressed in terms of the nature and extent of
ground water with concentrations of contaminants exceeding ARARs. and the applicable
conventional and innovative remedial technologies. Four technologies are evaluated: pump-
and-treat. inundation. grouting, and injection of acid neutralizing fluids.
The results of the evaluation indicate that it is technically impracticable to remediate the
bedrock aquifer in the TI zone. However, mandated ground water controls will be
implemented that will prevent off-site migration and impact to the Silver Bow
CreekJBlacktail Creek drainages and the associated alluvial aquifer (see Section 2.5).
2.4.1 Source Control Measures
As described in Section 2.3.2 the occurrence of metals in the bedrock water is a result of
geochemical reactions with the metal sulfides present within the naturally mineralized veins
of the bedrock. Therefore. the source of metals and sulfate loading to the bedrock aquifer
within the TI zone is the highly mineralized bedrock which is exposed to oxygen and water.
This source volume has been estimated to be 736 billion cubic feet and cannot be removed or
contained. Removal would leave an open pit about 62 times larger than the current Berkeley
Pit. would eliminate the historic city of Butte. and would have untold environmental
consequences.
2.4.2 Remediation Potential Evaluation
This section presents an evaluation of th~ remediation potential for the bedrock aquifer,
based on current knowledge of technologies for ground water remediation at mine sites.
Four methods were evalu~ted as pote~jtial remediation techniques. They are: pump-and-treat, .
inundation, grouting, and injection of acid neutralizing fluids. Ability to meet ARARs,
specifically groundwater ARARs. is also evaluated.
2.4.2.1 Pump-and- Treat
Pump-and-treat systems for remediation of AMD at a mine site. although capable of
extracting contaminated ground water from the bedrock aquifer. would not enable cleanup of
the ground water in the bedrock aquifer. Pump-and-treat systems would reverse the
-------
currently observed improving trend (see Section 2.3.2.3) in the quality of the ground water
in the bedrock. Lowering of the water level will reintroduce oxygen to the bedrock.
. reexposing the sulfide ore to oxidation. generating acid and thereby raising the concentrations
of metals in the bedrock aquifer within the 11 zone. The consequences of this fact are
greater cost in treatment plant operation (i.e.. increased reagent cost to treat the more grossly
contaminated water). extended time to completely oxidize all sultidic and mineralized-ore.
greater volumes of sludge from the treatment plant with its associated handling cost and
environmental impact. and loss of ore-body for future. albeit a low potential for this site.
extraction of metals.
Finally, a pump-and-treat system would not meet ARARs for groundwater remaining in the
11 zone. As d'Tussed previously, pump-and-treat actually degrades the quality of the
groundwater.
2.4.2.2 Inundation
Inundation. or flooding, is the only generally a('cepted method applicable to this situation of
abating acid generation of the material containing pyrite (Kleinmann. 1991). Research by
Watzlaf (1992) indicated that maintaining pyritic coal refuse under water vinually stops
pyrite oxidation. In fact, mine waste with 10 percent pyrite placed under water did not fonn
acidity, aluminum, iron, and sulfate contamination.
According to Watzlaf (1992), the metals mining industry has had success using under-water
disposal of pyritic wastes, as discussed by Rit<;:ey (1991), Balins et aI. (1991), Rescan
Environmental Services Limited (1990) and Bell (1987). Watzlaf (1992) quotes from Bell
(1987) that "at the current time. the only practical and proven long-tenn approach to
controlling the fonnation of acid in sulphide tailings is to limit the availability of oxygen as a
reactant by maintaining the waste in a saturated or submerged condition". The authors
acknowledged the use of capping as a remediation technique. However, they concluded that
the long tenn maintenance of capping technology make it less attractive as a closure or
remediation technique when compared to water closure.
Because of the demonstrated success of subaqueous disposal of pyritic mine waste,
inundation is considered the best available technology economically achievable for new mine
development in Quebec, Canada (Filion et al., 1994) and for dealing with mine wastes from
uranium mines in eastern Gennany (Feasby et al. 1994). Sulfidic tailings and waste rock at
a zinc-copper mine in Sweden were also decommissioned by flooding (Broman and
Goransson. 1994). Flooding was considered to be the safest and most effective option for
the mine.
Although current flooding is reducing contaminant concentrations in deep bedrock
groundwater (see Section 2.3.2.3). the selected remedy may not meet ARARs for
groundwater within a reasonable timeframe.
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2.4.2.3 Grouting
To be effective. grouting of the bedrock would have to seal. at a minimum. the entire
underground workings contained within the TI zone. This IS due to the highly
interconnecting nature of the site. There are no less than three thousand (3000) miles of
underground mine workings within the 6.75 square mile TI zone. The volume of grout
needed to seal the underground mine workings is estimated to be a minimum of 6.8 billion
gallons. For comparison, this volume of erout is over seven times the volume of concrete
used to construct the Hoover Dam in Nevada.
Grouting does have the potential of meeting ARARs for the bedrock aquifer. Grouting has
been used successfully at other mine sites outside of the U.S.. but on a smaller scale.
2.4.2.4 Injection of Acid Neutralizing Fluids
Injection of acid neutralizing fluids involves injecting an alkaline solution through boreholes
from the surface into the target area producing AMD. Previous studies suggest that addition
of alkalinity to underground mine pools may have the potential to neutralize stored acidity,
precipitate metals from solution. and reduce further pyrite oxidation. Also, since the
precipitates from and remain in situ, the problem of sludge disposal would be less severe.
The Bureau of Mines (Aljoe and Hawkins. 1993) has experimented with injection of alkaline
fluids into the subsurface to neutralize acidic discharges from abandoned coal mines.
Application was down boreholes into flooded mine pools. However, this method has had
linle success at abandoned flooded or flooding sites. and its general application to a large
scale site is questionable. Problems associated with this method include: inefficient mixing
of the acid neutralizing agent and the ground water, surface coatings of iron hydroxides on
the acid neutralizing agent which would inhibit neutralizing reactions, inability to completely
access the underground workings, and difficulty in controlling flow of injection fluids in the
fracture and mine w~rking zones. This laner aspect affects cost by doubling the number of
wells required to achieve adequate distribution of neutralizing fluid.
This method has. in theory, the potential to meet ARARs. However, this method has had
limited success at smaller sites; its applicability at such a large site as this project makes the.
chances for meeting ARARs questionable.
2.4.3 Cost Consideration
2.4.3.1 Pump-and- Treat
In response to public comments on the proposed plan, the cost of pumping the Berkeley Pit
"dry" (over an eleven year period) was calculated and ranged from $346 million to $462
-------
million~ .
2.4.3.2 Inundation
, Cost calculations for inundating the bedrock system under several flow conditions can be
found in the FS (ARCO. 1994bJ. The no action alternative (uncontrolled flooding) and flow
alternatives with and without active mining at the site were calculated. Cost ranged from
S27 million to $213 million. Accelerated flooding cost were not calculated but should fall
within the lower end of this range. The selected remedy may be considered an inundation
program but the selected remedy controls the rate of inundation (i.e., "controls flooding").
Cost used for the .purpose of this 11 evaluation represents the selected alternative cost which
are $41.8 million-or $52.8 million depending on location of sludge disposal, Le.. into the
Berkeley Pit or into a constructed repository located elsewhere in the active mine area.
2.4.3.3 Grouting
The assumptions made to estimate the cost of complete grouting of the underground workings
in an anempt to abate the source of contamination to the bedrock aquifer are:
I) To deliver grout to the underground workings, 5 grout borings per acre would' be drilled
[0 an average depth of 2.500 feet below the ground surface. Over the area of the 11 zone
(6.75 square miles) the total linear footage that would need to be drilled would be over 54
million feet and represents 21.600 drill holes (six inch diameter). Assuming an average cost
of drilling to be $100 per foot for the first 1000 feet of drilling and $50 per foot for the
remainder, the total cost of drilling the grout borings will be approximately $3.78 billion.
2) The total volume of grout needed to completely fill the underground workings void space
is. at a minimum. approximately 920 million cubic feet ([21,600 holes X 6 inches per hole X
2.500 feet per hole] + volume of mir:te workings). The cost of the grou~ to fill this void is
estimated to be $2.2 to $3.0 billion.
..
Cost calculations were bused on FS (ARCO, 1994b) values for treatment plant capital costs and
operation and maintenance costs. Pumping the Berkeley Pit "dry" in 11 years with sludge di<;posal into
the Pit had a associated co!>'t of 5346 million to 5388 million. Sludge di<;posal on IIn onsite fllcility hlld
an associated ran~e 01' 5412 million to 5462 million.
Cost estimates are based on price quotes by local drilling contractor who instaUed bedrock monitoring
wells as part of the Rl and who has extensive experience in drilling deep bedrock we& at ~e site.
o
Cost of grout i<; based on a 52.40 per cubic foot for cement-bused grout and 5J.2.S for clay based grout.
The latter i<; a price quote from a contractor supplying grout at 56.50 per cubic foot for a Montana
AMD remediation project. The supplier stated that for a project requiring such a larKe amount of
grout, the cost per cubic yard would be reduced by nfty percent (SO").
-------
3) A water treatment plant to treat the displaced mine drainage would cost 520.3 million,
based on the parameters used for the Feasibility Study (FS) (ARca. 1994b).
4) Water treatment would operate for 8 years at a rate of 6.8 MGD. The a&M cost of
treatment and sludge disposal would be estimated at $113.3 million (ARCa. 1 994b).
5) The ground water displaced by the grout would be pumped from 10 existing mine shafts.
The cost of refurbishing the 10 shafts for ground water extraction is estimated to be $162.5
million.
6) The annuaJ O&M cost for pumping the 10 shafts is assumed to be 15 percent of the
capital cost. For a period of 8 years. this a&M would amount to $195.0 million.
7) Contingencies for grouting are assumed to be 30 percent of the total cost. The
contingencies amount to $2 billion to $2.3 billion.
In summary, the cost of grouting the underground workings is estimated to be $9 billion (:t
$.5 billion).
2.4.3.4 Injection of Acid Neutralizing Fluids
In order to estimate the cost of injecting acid neutralization fluids to remediate the bedrock
aquifer in an attempt to attain ARARs. the following assumptions were made:
I) To deliver acid neutralizing fluids to the underground workings, 10 injection borings per
acre would be drilled to an average depth of 2,500 feet below the ground surface. Over the
area of the TI zone (6.75 square miles) the totaJ linear footage that would need to be drilled
would be over 108 million feet. Assuming an average cost of drilling to be $100 per foot for
the first 1000 feet of drilling and $50 per foot for the remainder, the total cost of drilling the
grout borings will be approximately $7.56 billion.
2) Assuming lime and barium oxide would be needed to neutralize the acidic ground water
and to precipitate metals. the total amount of lime and barium oxide to treat the bedrock
aquifer ground water within the TI zone is estimated to be 17.8 million tons, at a cost of
$1.1 billion. .
3) A water treatment plant to treat the displaced mine drainage during injection would cost
$20.3 million based on the parameters used in the FS (ARCa, 1994b).
4) Water treatment would operate for 8 years at a rate of 6.8 MGD. The O&M cost of
treatment and sludge disposal would be $113.3 million (ARCO, 1994b).
5) The ground water displaced by injection would be pumped from 10 existing mine shafts.
The cost of refurbishing the 10 shafts for ground water extraction is estimated to be $162.5
million.
-------
6) The annual O&M cost for pumping the 10 shafts is assumed to be 15 percent of the
capital cost. For a period of 8 years. this O&M would amount to S 195.0 million.
7) Contingencies for injection are assumed to be 30 percent of the total cost. The
contingencies amount to $2.6 billion.
In summary. the cost of injecting acid neutralization fluids is estimated to be $11. 8 billion.
2.5 Alternative Remediation Strategy
In cast:s where it is not practicable to return usable ground water to its beneticial uses within
a time frame that.: is. reasonable given the panicular circumstances of a site, EPA expects to
a) prevent migration of contaminated water from the 11 lone. b) prevent exposure to
contaminated ground water within the 11 lone. and c) evaluate funher risk reduction (40
CFR ~300.430(a)(l)(iii)(F)). Because it is not technically practicable from an engineering
perspective to attain these groundwater quality standards in the designated area within the
bedrock aquifer. a waiver is invoked in the Record of Decision for ~h~ ground water ARARs.
The selected remedy consists of inundation of the mine workings along with other measures.
as outlined below. However, the selected remedy controls the rate of inundation (controlled
flooding). The remedy selected for this OU will protect human health and the environment,
and will meet the NCP expectations for non-ARAR-compliant remedies as outlined in (a)
through (c) above.
The selected remedy also provides the greatest balance of tradeoffs among the nine remedy
selection criteria. as discussed in the FS (and the ROD?).' The major components of the
selected remedy are provided below:
1)
Inflow Control: The remedy requires immediate control and treatment of surface
water as well as immediate control and treatment of subsurface flow in the east
alluvial aquifer. This action will slow the present rate of Berkeley Pit flooding by
over 40 % . The selected remedy also requires diversion of clean flows, presently used
by current mining operation. around the Pit once mining is discontinued.
2)
Water Levels: The remedy does not allow water levels to rise in the Berkeley
Pit/East Camp system and the TravonaiWest Camp system above the established
levels of 5410 and 5435 ft msl, respectively. EPA and the State believe these are
levels at which human health and the environment will be protected.
3)
Water Treatment Technology and Sludge Generation/Disposal: Aeration with
two-stage hydroxide precipitation and reverse osmosis (if necessary) has been chosen
as the treatment technology for this action. Any sludge disposal repository will meet
. Montana solid waste regulations. The' declaration ponion of the ROD directs disposal
of sludge in a repository in the mine area or in the Berkeley Pit. However, the
selected treatment technology must be reevaluated when the water in the Berkeley
-------
Pit/East Camp system reaches 5260 ft msl. The agencies remain flexible in the use of
other technologies proposed jointly by the responsible panies and developers of
technology, if it meets stream discharge' standards. For a complete discussion of the
water treatment technology and sludge generation/disposal issue. see the declaration
and decision ponions of ROD. .
4)
Construction of the Water Treatment Facility: Design will begin no less than eight
years prior to the projected date when the Berkeley Pit/East Camp system could reach
the critical water level. The facility will be completed four years prior to reaching
that level.
5)
Perfonr r('e Standards: The design. construction. operation and maintenance of the
, water treatment and sludge disposal facility will be approved and monitored by EPA
and the state. Discharged water will meet State water quality standards. Sludge
disposal activities will meet state and federal solid waste disposal regulations.
6)
Comprehensive Water ~1onitoring Program: This will be used to track water
elevation and quality in the 11 zone. The data will be used to ensure that a water
treatment facility is in place and operating before reaching the critical water levels.
The agencies will produce yearly written repons with the collected data and updated
predictions of when the critical water levels will be reached. Every three years the
agencies will review the entire monitoring program and make adjustments.
7)
Dam Stability: The selected remedy provides monitoring and design criteria for the
Yankee Doodle Tailings Pond to ensur~ that the dam does not fail.
8)
Groundwater Use Restrictions: Institutional controls will be employed to ensure
that there is no inappropriate use of contaminated bedrock groundwater.
9)
Travona/West Camp System Water: EPA took action in 1988 to control the water
level of this system by pumping and treating Travona Shaft water. This remedy is
still appropriate. and is integrated into the Mine Flooding selected remedy.
10)
Flexibility: There is flexibility in the way surface water inflow is controlled, the'
method used to treat contaminated water. the bedrock water withdrawal point, and the
use of collected and/or treated water.
II)
Five Year Review: Since hazardous substances will remain on site at levels above
those. that would allow unlimited use and unrestricted exposure, the remedy will be
reviewed no less often than every five years after initiation of the remedial action.
EP A and the State retain authority, under applicable federal and state law, to establish
lower water levels, or take other actions as necessary to deal with unanticipated
threats to human health and the environment.
The monitoring program is comprised of 13 bedrock monitoring wells (9 existing and 4
new), eight mine shafts, 15 existing wells completed in bedrock, and the Berkeley Pit, for a
total of 37 bedrock monitoring locations. Also, there is over ten years of water level data
-------
for many of these locations plus additional water-level data is being added monthly to the
data base (see Figure 10 for monitoring point locations). The monitoring program has an
extensive data base on water chemistry with additional water quality data to be collected.
The selected remedy requires a three year review of the program. retaining flexibility to
adjust the program as needed. The current monitoring network (with the addition of new
monitOring wells in the West Camp and the flexibility to require additional wells if needed)
will assure the agencies and the public that ground water tlow towards the Berkeley Pit/East
Camp will be maintained.
TI-18
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3.0 Conclusions
Attainment of ARARs in the bedrock aquifer within the 11 zone is technically impracticable
from an engineering perspective. The principal reasons for this are: I) the extremely large
horizontal and vertical extent of the contamination problem: 2) the potentially applicable
. remediation technologies are not proven in conditions similar to this site: and 3) even if one
of the potentially applicable technologies were used. the cost of remediation would be
inordinately high. Additional clarification and conclusions are provided below. Table 3
summarizes and provides a comparison of the four remediation techniques evaluated in
Section 2.4 above.
.
It is infeasible to remove the contamination sources. Removal of the source, which
consists of approximately 34 billion cubic yards of partially mined-out bedrock, would
leave an open pit approximately 68 times larger than the current Berkeley Pit and
would eliminate the historic city of Butte:
.
Implementation of pump-and-treat methods will cause progressive deterioration of the
ground water quality and reverse the currently observable trends of improving
bedrock ground water quality by exposing more source material to oxygen;
.
The ability to effectively deliver grout or acid neutralizing fluids to the subsurface is
very uncertain from an engineering standpoint due to the extremely large extent of
underground workings and the improbability of reaching all of the mine workings;
.
Both grouting of the underground workings and injection of acid neutralizing fluids
are prohibitively expensive methods given the conditions at the site (estimated at $9 to
$11.8 billion. respectively):
.
The volume of contaminated ground water contained within the bedrock aquifer of the
11 area (Figure 2) is approximately 125 billion gallons. Environmental and economic
effects of treatment of such a volume of ground wa~er are not possible to predict;
.
Inundation of the bedrock aquifer with control of migration is the only reliable and
available means to control and improve the quality of the bedrock ground water
within the 11 lone. However, the selected remedy, considered to be an inundation
program. will not meet ground water ARARs.
.
Since hazardous substances will remain on site at levels above those that would allow
unlimited use and unrestricted exposure, the remedy will be reviewed no less often
than every five years after initiation of the remedial action. EPA and the State retain
authority, under applicable federal and state law, to establish lower water levels, or
take other actions as necessary to deal with unanticipated threats to human health and
the environment.
-------
4.0 References
AIME, 1968. are Deposits of the United States. 1933-1967, The Graton-Sales Volume, John
D. Ridge, editor, American Institute of Mining, Metallurgical, and Petroleum Engineering, New
York.
Aljoe. W.W. and Hawkins, J.W.. 1993. Neutralization of Acidic Discharges from Abandoned
Underground Coal Mines by Alkaline Injection. U.S. Bureau of Mine, RI/9468.
Balins. J.K., Welch. D.E., Knapp, R.A. and Maltby. J.W., 1991. "Decommissioning of the
Quirke uranium tailings basin to eliminate acid production" in Proceedings of the Second
International Conference on the Abatement of Acidic Drainage, Montreal, Quebec, September
16-18, 1991. p. '}79-397.
ARCO, 1994a. Butte Mine Flooding Operable Unit Remedial Investigation/Feasibility Study
Draft Remedial Investigation Report. Prepared by Canonie Environmental Services.
ARCO, 1994b. Butte Mine Flooding Operable Unit Remedial Investigation/Feasibility Study
Draft Feasibility Study Report. Prepared by Canonie Environmental Services.
Bell. A.B. 1987. "Prevention of acid generation in base metal tailings and waste rock" in
Proceedings of the Acid Mine Drainage Seminar and Workshop, Halifax, Nova Scotia, March
23-26, 1987, p. 391-410.
Broman. P.G. and Goransson. T.. 1994, "Decommissioning of tailings and waste rock areas at
Stedenjokk, Sweden in Proceedings of the International Land Reclamation and Mine Drainage
Conference and Third International Conference on the Abatement of Acidic Drainage,
Pittsburgh. PA, April 24-29, 1994, Vol. 2, p. 32-40.
Canonie Environmental Services Corp.. 1992. Miscellaneous Tasks, Bedrock Monitoring
Program Data Summary Report. Remedial Investigation/Feasibility Study, Mine Flooding
Operable Unit. Butte Montana, draft report prepared for ARCO.
CDM Federal Programs Corp., 1990. Final Work Plan for Remedial Investigation/Feasibility
Study, Butte Mine Flooding Operable Unit, Butte Addition to the Silver Bow CreeklButte Area
NPL Site, Butte Montana, Doc. Control No. 7760-005-WP-BGCC, prepared for the U.S.
Environmental Protection Agency.
Dugan. R.P., 1975, Bacterial ecology of strip mine areas and its relationship to production of
acidic mine drainage in Ohio Journal of Science, v. 75, no. 6, p. 266-279.
EPA. 1992. General Methods for Remedial Operations Performance Evaluations. U.S.
Environmental Protection Agency, EPA/600/R-92/002.
EPA. 1990. Administrative Order and Consent, Remedial Investigation/Feasibility Study for
Butte, Montana Area Mine Flooding Operable Unit (Silver Bow Creek/Butte Area NPL Site),
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Docket No. CERCLA VIII-90-09.
EPA, 1993. Guidance for Evaluating the Technical Impracticability of Ground Water
Restoration. Office of Solid Waste and Emergency Response, U.S. Environmental Protection
Agency, Directive 9234.2-25.
Feasby, D.G., Chambers, D.B., Scharer, J.M., Pettit, eM., Dakers, R.G. and Goldsworthy.
M.H., 1994, "International perspective on the role of acid generation in selecting
decommissioning techniques for uranium mining sites in eastern Germany" in Proceedings of
the International Land Reclamation and Mine Drainage Conference and Third International
Conference on the Abatement of Acidic Drainage, Pittsburgh, PA, April 24-29, 1994, Vol. 2.
p. 67-76.
Freeze, R.A. ana Cherry, J.A., 1979. Groundwater, Prentice Hall, Inc. Englewood Cliffs, New
Jersey.
Filion, M.P., Firlotte, F.W, Julien, M.R. and Lacombe, P.F., 1994, "Regulatory controlled
design - Louvicoun project - a case study" in Proceedings of the International Land Reclamation
and Mine Drainage Conference and Third International Conference on the Abatement of Acidic
Drainage, Pittsburgh, PA, April 24-29, 1994, Vol. 2, p. 22-31.
James, Don, 1980. Butte Memory Book, The Caxton Printers LTD.
Kleinmann, R.L.P, 1991. Acid Mine Drainage: An Overview in Energy in the 90's,
Proceedings of a specialty conference sponsored by the Energy Division of the American Society
of Civil Engineers, March 10-13, 1991, Pittsburgh, Pennsylvania, p. 281-286.
Metesch, J.J., 1990, "Aquifer Testing and Evaluation at the Travona Mine and the Margaret
Ann Mine, Butte, Montana", Master's Thesis, Montana College of Mineral Sciences and
Technology, Butte, Montana.
Ralston, D.R., Sprenke, K.F., Liou, J.C.P., and Petrich, C., 1994, "Evaluation of hydrologic
impacts from operation of a pumping-injection program in the underground workings at Butte.
Montana", prepared for the Kelley Resource Recovery Corporation.
Rescan Environmental Services Limit~, 1990, Geochemical assessment of subaqueous tailings
disposal in Buttle lake, British Columbia. Project funded by Energy, Mines and Petroleum
Resources and the British Columbia Ministry of Energy, Mines and Petroleum resources.
Ritcey, G.M., 1991, "Deep water disposal of pyritic tailings" in Proceedings of the Second
International Conference of the Abatement of Acidic Drainage, Montreal, Quebec, September
16-18, 1991, p. 421-442.
Singer, P.C. and Stumm, W., 1970, Acidic mine drainage: the rate determining step in Science,
v. 167, p. 1121-1123.
Stephenson, Sam, 1994. Personal Communication.
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Watzlaf, G.R., 1992, "Pyrite oxidation in saturated and unsaturated coal waste" in Proceedings
of National Meeting of the American Society for Surface Mining and Reclamation, Duluth, MN,
June 14-18, 1992, p. 191-205..
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Adventure
Ah:xander
Alex Scott
Alice
Alisbury
Allie Brown
Amapore
Amy Silversmith
Annie and Ida
Anselmo
Argonaut
Atlantic
Aurora
Ausania
A very
Badger
Badger State
Balaklava
Belk
Belcher
Bell
Belle of Butte
Bellona
Belmont
Berkeley
Black Chief
Black Rock
Blue Bird
Blue Jay
Blue Wing
Bob Ingersoll
Buck Placer
Buffalo
Burke
Burlington
Champion
Chattanooga
Chicago
Chinook
Clark's Colusa
Colorado
Colusa Parrot
Comanche
Cora
Curry
Cut Hand
Czarromah
Darling Fraction
Diamond
Dixon
Table 1
Butte Mines within the Butte Mining District
East Colusa
East Grayrock
Edith May
Ella Clark
Ella Ophir
Elm Orlu
Emma
Estrella
Excelsior
Flag
Fraction
Free-for-all
Gabriella
Gagnon
Gambetta
Gem
Gemania
Glangarry
Goldsmith
Grabella
Granite Mountain
Gray Eagle.
Gray Rock East
Gray Rock West
Great Republic
Greenleaf
Green Mountain
Hattie Harvey
Hawkeye
Hibernian
High Ore
Jamestown
Jersey Blue
Jessie Wingate
Josephine
Kansas Chief
Kanuck
Kelley
La Plata
Later Acquisition
Leonard
Lexington
Little Minah
Liquidator
Lone Tree
Maggie Bell
Magna Chana
Magnolia
~tanhattan
Margaret Ann
Maria
Marie Louise
Martha
Mayflower
Michael Devitt
Midnite
Mill Site
Milwaukee
Minnie Healy
Minnie Irvin
Minnie Jane
Missoula
Modoc
Molly Murphy
Moonlight
Moose
Morning Star
Moulton
Mountain Centtal
Mountain Chief
Mountain Flag
Mountain Rose
Mountain View
Nellie
Nettie
Neversweat
Night Hawk
Nipper
Nonh Berlin
Nonh Star
Ophir
Original
Orphan Boy
Orphan Girl
pogO
Pacific Slope
Parnell
Parrot
Pauline
Paymaster
Pennsylvania'
Piccolo
Pittsmont
Plover
Poser
Rainbow
Ramsdell's Parrot
Rarus
Read
Ready Cash
Rescue
Rialto
Roben Emmet
Rocker
Rock Island
Rockwell
Rooney
Ryan
St. Clair
St. Lawrence
Samantha
Saukie East
Saukie West
Silver Bow
Silver Buillon
Silver Chief
Silver Litle
Silver Smith
Sister
Smoke House
Snowball
Snow Drift
Sooner
Speculator
Star West
Steward
Sun Dog
Sunrise
Surprise
Tramway
Transit
Travonia
Tully
Tuolumme
Valdemere
Vulcan
Wake-Up Jim
Walkerville
Wappelo
West Colusa
West Grayrock
West Mayflower
West Steward
Wild Pat
Yankee Boy
Zella
-------
TABLE 2
AVERAGE AND IDGHEST CONCENTRATION VALUES OF CONSTI11.JENTS IN BERKELEY PIT, BEDROCK WELL, AND SHAFf WATER
AND ESTABLISHED STANDARDS
BtnTE MINE FWODING OPERABLE UNIT
Constituent Berkeley Pit Bedrock Well Water1 (pglL) Shaft Water' (pg/L) MCLsc (pglL)
Water! (pg/L)
I,
Mean Higbest Value Mean Higbest Value
Aluminum 270,000 244 726 675 3,010 None
Arsenic' 710 52 254 211 1,380 50'
Cadmium I, 790 2.4 3.7 100 547 5'
Calcium 440,000 127,610 172,000 276,321 573,000 None
Chloride 26,200 4,400 2,600 NA NA 250,OOOS
Copper 167,000 26.4 129 1,581 20,800 1.300s
Iron 897,000 9,231 17,600 50,094 307,000 JOOs
Lead 87 2.4 7.3 9.0 49.9 15'
Magnesium 395,000 33,400 47,400 83,046 190,000 None
Manganese 161,000 2,306 4,170 31,503 129,000 5,OOOS
Potassium 22,700 14,523 22,300 12,232 29,600 None
Sodium 71,400 62,200 169,000 43,975 128,000 None
Sulfate 16,800,000 577,800 980,000 840,583 2,870,000 None
Zinc 476,000 844 2,660 40,375 215,000 55
pH 3.0-3.3 str 5.8-7.6 SU 5.84-7.59 SU 5.72-7.33 SU 5.72-7.33 SU 6.5-8.55 SU
Source: ARCO 1994a
I Average concentration values are weighted averages of 1991 data based on Pit volume.'
2 Average concentration values for bedrock monitoring wells A, B, C, D-2, E, and F.
, Average concentration values for the Chester, Hebgen, Parrot, Anselmo, Belmont, Emma, Granite Mountain, Kelley, Lexington, Margaret Ann, Orphan
Boy, and Steward mine shafts.
C Maximum Contaminant Levels (i.e., primary and secondaryS drinking water standards). ,
, Acute and chronic aquatic Water Quality Criteria; all values are based on a hardness of 100 mglL CaCO, except arsenic and aluminum which an: not
hardness dependent.
" Arsenic values are for arsenic". Note: State of Montana Water Quality Bureau standard for arsenic (wQB-7) is 3.18Ilg/L.
7 Range of pH values in Standard Units.
NC = Not Calculated.
-------
TABLE J
COMPARISON CW REMEDIATION TECHNIQUES FOR MEETING CiROUNDWATER ARARs
BurrE MINE n.oODING OPERABLE UNIT
REMEDIATION TECHNIQUES COST CONSIDERATIONS POTENTIAL TO MEET ENGINEERING t:OMMENTS
GROUNDWATER ARARs UNt:ERTAINTIES
TOTAL COST RELATIVE
CO~T TO SR
.-
Pump-and- Treat 400 million2 8x No6 No Conventional; Perpetuates prohlem.
Inundation' SO million) I No No Conventional; Selected Remedy is it
.controlled flooding. .
Grout 9 billion' 18,OOOx Yes Yes Innovative; Cosl and access issues
for drilling are limiting factors.
Injection of Acid Neutralizing I J.8 billion' 24,OOOx Yes7 Yes Innovative; Most experimental and
Fluids unproven.
lOne regime of inundati~n is the Selected Remedy (SR) presented in Section 2.5 Alternative Remediation Strategy.
2 Based on middle range of cost ($346-$462 million) and Berkeley Pit pumped .dry. in II years; see Section 2.4.3. I.
) Based on Selected Remedy cost range of $42-$50 million; see Sectiun 2.3.4.2.
, See Section 2.4.2.3.
, See Section 2.4.2.4.
6 This method actually degrades existing groundwater quality.
-------
CD
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VICINITY MAP
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5000 fEET
Mo- DAT[
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..~ WIH[ SKAf'T lOCAftON AHD
. II{U"£Y O£SlCHAllON
MONTANA
LOCATION MAP
/
/
NOT T:> SCALE
BUTTE MINE fLOODING OPERABLE UNIT
SITE LOCATION AND tEATURES UAP
PR(PARED fOR
ARCO
ANACONDA, MONTANA
()AT[. 8-10-94
SCAlE: AS SHOWN
FIGURE 1
DRAwING NU"B[~
3101-81
-------
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Figure 2 . i
.. i
Area of Potcutial. I
Cont:lmin:ltffl Bedrock Aquifer
for the BMFOU
I
- !
Legend
.'quifet BoundoJy
Streel or Rood
Hydrolosic f8u",..
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PREPARED FOR
ARCO
ANACONDA. MONTANA
O-JO-'"
.,-
F1CVRE 5
_..
-------
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'(ANKEE DOODLE
TAILINGS POND
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ISSU[ I R(VISiON
CONTINENTAl
FAULT
CONTINENTAl PIT
lEGEND:
~
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~
P~F:P.OT
~ARy. .
~
KEU.£Y
(5082.3)
EEOROCf: MONITOR,NG WELL
LOCATION AND LE~IGN~ TlON
DIAMOND DRILL Hf)LE LOCATION
AND DESIGNAliON
IAUNICIPAl MONITORING WELL
~f)CATION AND DESIGNATION
MINE SHAfT LOCATION AND
OESIGNATION
BEDROCK WATER LEVEL ELEVATION.
FEET ABOVE MEAN SEA LEVEL
-5080- BEDROCK WATER LEVEL ELEVATION.
FEET ABOVE MEAN SEA LEVEL
DIRECTION OF GROUND WATER FLOW
.....
l1QIES.;
1. BEDROCK AOUlfER MONITORING WELL E NOT
USED FOR CONTOuR MAP INTERPRETATION
BECAUSE OF ANOMALOUS WATER LEVEL
MEASUREMENTS.
2. All WATER LEVELS MEASURED DURING
JULY 1993.
3. FOR CONTINENTAl FAULT. 0 INDICATES
DOWNTHROWN SIDE AND U INDICATES
UPTHROWN SIDE.
4. WATER LEVEL ELEVATIONS IN THE TRAVONA
SHAFT AN{) THE CtiESTER STEELE AND
HEBGEN PARK WElLS ARE AffECTED BY
PUMPING IN THE TRAVONA SHAFT.
SCAlE
~-
1800 0
,
1 800 fEET
WAITR LEVEL CONTOUR w.P .
FOR THE BEDROCK AOUIFER
PREPARED rOR
ARCO
ANACONDA, MONTANA
DATE, 9-1-94
SCALE AS SHOWN
FIGURE 6
ORA-WINC NUMseR
3101-84
~~,'"L~~. ..-...r.rv-A-
-------
<{
I
10.21)
(0.16)
.....
o
.....
r')
<.;Ie::
Zw
~(D
<{:::;
e::;:)
az
YANKEE DOODLE
TAILINGS POND
(NEG)
f. 'JJVIUM
HORSESHOE
BEND
(0.17)
NET EVAPORATION
NET
(EVAPORATION
0.86)
(3.10)
(NEG)
(0 -:-0 2.68)
PRECIPITATION
PLANT
( 1.45)
(1.54)
NET
EVAPORATION
(21.82)
(15.80)
(0.12)
(14.43)
(??)
LEACH PADS
AREA
(??)
(0.30)
(18.80)
NET PRECIPITATION,
RUNOFF AND
EVAPORATION
(0.58)
(??)
(0.14)
(4.44)
MR
CONCENTRATOR
(0.37)
LEGEND:
FLOW VOLUME,. MILLION
GALLONS PER DAY
MOISTURE IN
CONCENTRATES
(NEG)
(0.4 7)
CONSUMED
(0.37)
(NEG)
(??)
FLOW IS NEGLIGIBLE
FLOW IS UNKNOWN
NOTES:
1. FLOW FROM McQUEEN BOOSTER STATION
INTO BERKELEY PIT EQUALS 0.14 MGD
OF SLURRY OR 0.12 MGD OF WATER ONLY.
BMFOU WATER BALANCE
FLOW DIAGRAM
REFERENCE'
DIWIING OBTAINED FROW BU'TTE WINE FlOODING OPERABLE
UNIT REWEOW. I>N£ST1GATION/I'!.-s18lU1'l STUDY DfWT
REPORT. ARCO IN<
-------
en
<
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IS
60
50
I 40
CO
O
O
in
O
m
30
20
10
Berkeley Pit
Underground Workings
Fractured Rock
VOLUME OF STORAGE SYSTEMS
PREPARED FOR
ARCO
ANACONDA, MONTANA
No
DATE
ISSUED FOR TtcHwot iMPRncnowurr
REPORT
ISSUE / REVISION
XHN 8V CK'D BY «P'0 Bft
DATE: 9-1-94
SCAIF N.T.S.
FIGURE 8
DRAWIN'C NUMHER
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VALIDATED GROUND WATER
SAMPLE RESULTS
BEDROCK MONITORING PROGRAM
PREPARED rOR
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ANACONDA. MONTANA
::\Iili
1..,t~1
I:.,t:..'
lc..j,MJ
l~j':IIO"
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-------
ATTACHMENT 1
VOLUME CALCULATIONS
'"
-
, j
-------
Titan Environmental
By T AS Date 9/8/94 Subject
Chkd By Date
Purpose:
Method:
Volume Comparison
('/
Page-L-of-L
Proj No 3101-005
Volume Comparison of Water within the East Camp Area
The purpose of this calculation is to compare the volumes of water contained in
the Berkeley pit, the underground workings, and the fractured rock in the east
camp area.
Table P.I (attached) was used to calculate the volwne of water in the Berkeley
pit. The table is a summary of the calculated Berkeley pit water level
projections. The water level used for the volume calculation was the critical
water level 9f 5,410 ft ms!. Since the table does not provide a volume for the
elevation of 5,410 ft msl, linear interpolation was used.
The underground workings volume was calculated based on information
provided by Sam Stephenson of ARCa. Mr. Stephenson had previously
prepared information for a public presentation when the pumps were turned off
in Kelley shaft. The presentation included overheads Vtith the following
information:
From Mt. Con sump to 2,195 ft msl, void volume = 40,748,400 £r
From 2,195 ft msl to 4,320 ft. msl, void volume = 432,369,504 ft3
These volumes accounted for void volume in fill. For example, 30 percent
void volume was assumed for slime fill and 20 percent void volume was
assumed for mine (gob) fill.
The voie volume f:om the bottom of the pit to the surface was not calculated;
however, it would be a conservative estimate that the same ratio of void space
was present as in the 2,195 ft msl to 4,320 ft msl interval. The total of these
three void volumes is equal to the volume of underground workings. Since the
underground mine workings are beneath the current bedrock aquifer elevation,
the volume of the workings is equal to the volume of water contained in the
mine workings.
The volume of ground water within the fractured rock was calculated by
assuming a site area of 6.75 sq. miles (EPA, 1994). Multiplying this area by
the total height of water from the lowest mine workings elevation to the critical
water level elevation provided the total water volume contained \..ithin the site.
The lowest mine workings are at 1,500 ft msl and the critical water level is
-------
~-
Titan Environmental
By T AS Date 9/8/94 Subject
Chkd By Date
Volume Comcanson
Page~ot.r-
Proj No 3101-005
the volume of water in the Berkeley pit and the volume of water in the
underground workings were subtracted from the total volume. This volume
was then multiplied by I % since it was assumed that 1 % of the remaining
-------
~------
- i i a:~';Environmental
By '1M
Chkd b}JF(
", '.
! \ I i. ..
_1,\,[ ~ \ 1, ;',(',\:
\jO\'A",\t
Date ~/2..v I'd
Date J7~'./9Y
Sheet No ~ of .-1-
Proj No ? I 0 I 00 C;
1/5" X 1/5"
V~\LlAA I
( r.~tA"'I')li/\
SubjeCt
,)r
I.I,];J},V
';,'JJ ~ 7 ";iC rr' I\
-------
a=======.a.=-=E . 1
"=" == = =:":...': nVlrOnmenta
By -1~ Date ~ Subject~ !AI\,..J ti':Yo\~C\,";SC:.'
Chkd by ./PL Date ~/? /~
Sheet No ~ of ~
Proj No ~\O\ O()S
1/5" x 1/5"
, V~IJ.rM. (, Uf\&l.utOlAJ1l.
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-------
(,/
'/ r'
TABLE P.I
JI:t rlCjr'1
Calculation or Berkeley Pit Water-Level Projection for Scenario No. I
Butte ~1ine Flooding Operable Unit Rl/FS
1nl10ws to U1e Totalln!1ows to the Predictluns for Berkelev Pit
Berkelev Pit (in mEd) Berkeley Pit lin mg) Cummulative In!1ow Volume I Water L~'..:
Y C.1r Surface I Alluvium I Bedrock I P/RJE Dailv I YC.1rlv 1m!:) I (ft3) I (fi msil
i -J ui-1993 ... ... ... .. ... ... ... ... ... ... ... ... .. ... ... ... ... ... ... ... ... ... .. ... ~1.347 ~.8534E+09 5.049.6
31-Dcc-1993 1.68 0.58 ~.49 0.30 5.05 929.2 ~.176 ~.9783E+09 -~.1.jk 5.064 ,
31-Dcc-1994 1.68 0.58 1.49 0.30 5.05 1,844.5 24,110 3.:149E+09')~ 5.088
31-Dc:c-1995 1.68 0.58 1.49 0.30 5.05 1,844.5 15.965 3.4715E+09 5,110
31-Dcc-1996 1.68 0.58 2.49 0.30 5.05 1.844.5 17.809 3.718IE+09 5./31
31-Dcc-1997 1.68 0.58 2.49 0.30 5.05 1,844.5 29,654 3.9647E+09 5.150
31-Dcc-1998 1.68 - 0.58 2.49 0.30 5.05 1.844.5 31,498 4.2113E+09 5,169
31-Dcc-1999 1.68 0.58 2.49 0.30 5.05 1.844.5 33.343 4.4579E+09 5.187
31-Dcc-2000 1.68 0.58 1.49 0.30 5.05 1.844.5 35,187 ~. 7045E +09 5.20:
31-Dcc-2ool 1.68 0.58 2.49 0.30 5.05 1.844.5 37,031 4.9511E+09 5.::0
31-Dee-:OO:! 1.68 0.58 2.49 0.30 5.05 1,844.5 38.876 5.1978E+09 5,236
31-Dee-1oo3 1.68 0.58 1.49 0.30 5.05 1,844.5 40.721 5.~E+09 5.251
31-Dc:c-2004 1.68 0.58 2.49 0.30 5.05 1.844.5 4::565 5.6910E+09 5.:66 '
:
31-Dee-Zoo5 1.68 0.58 :.49 0.30 5.05 1,844.5 .£.i.410 5.9376E+09 5.:80
0.58 0.30 5.77 1./07.5 '
3 i -Dcc-:0O6 1.40 :.49 ~.517 6.2194E~09 5.:95
3 i -Dee-:0o7 2.40 0.58 2.49 0.30 5.77 1,/07.5 48,615 6.501IE+09 5.310
3i-Dec-2008 2.40 0.58 =.~9 0.30 5.77 2,107.5 SO,iJ:! 6. i829E +09 5.325
:; i -Dc:c-:0o9 ~..:.o 0.58 :.~9 0.30 5.77 :.107.5 5~.8~ i.0~iE...09 5,339
31-Dcc-:OlO 1.40 0.58 :.49 0.30 5.77 ~,107.5 54,947 7.3~SE...09 5,353 i
31-Dee-~011 ~..:.O 0.58 Z.:9 0.30 5.77 ~.107.5 57.055 7.6282E+09 5.366 ,
31-D.:c-:01: :.~ 0.58 :.49 0.30 5.77 ~.107.5 59,162 7.9100E+09 5,380 !
31-D.:c-:013 2.40 0.58 :.49 0.30 5.77 ~.107.5 61.170 8.1918E+09 5.39: i
3i-Dec-:014 1.40 0.58 2.49 0.30 5.77 1./07.5 63.377 8.4736E+09 5.405
... s'o/I"
31-Dec-:015 2.~O 0.58 2.49 :.30 s.n 2.107.5 65.485 8.7553E+09 5..Hi '
!
c{i:-
~
1.'\)1".'
.: S':::::l:-:o JssU:'::e:S t~e: CU:-:-:::: m::1e sur:Jc: ::1r.ows c:::r.::::ue: for :he: l:i: uf thi: mi:1e (:;~.::t :CC5) :::.J the:! inc~c:1s::£ !n include
I
\:;,;:. t:-.~ :"hJr~c::~hoc a~:-:c 1rc.3 f~cws: T:~c J.i!:.:vit.:rn J~C c~roc:.t di~c~.:r;~s, .1:10 lrac: :iC:~ prc:c:pit.l~ioni"'Jnoii/c"'1por:HJUn n::n3i.roa consUnt.
~ m;;.; = ~liiljon gallons IXr cay.
3. m;; = ~lilJjon SJllons; mg = cubic fee: (:'..3) x 7.48IE-6.
~ ?'?~::: == :-;c: ;:~~:?iLltjonir.;::oi:je:V3por.lt'0r:.
5. DJuy tOLlI inllow to pit = suriace inilow + alluvium discharge + bedrock discharge: + PIRIE.
o. y c:.3rl~' total inl10w to pit = daily total in!1ow x 365.15 days. except for period irom July I to December 31. 1993 which is 184 days.
'7 C~mmu!3tive inilow volume for pit for July I, 1993 based on current pit water Ie:Ye:\ of 5,049.61 fcc:t :lbovc mc:1n SQ level (ft msl)
f L SGS datum) and is calculated based on the foUowing equation from Canonie (1993.1):
Y = -5.6640EI1 + (3.8~i1ES x X) - (8.7388E4 X X X X) + (6.6391 x X x X x X)
'W'herc: Y = Pit volume. in ft3. and
X = Pit ele:vation. in ft msl.
S WJ:~: :c\'c:! ;:rojcc:ion for the: YC.1rs 199~ th.ough 20 j 5 He: based on the: yc:.arly cummula!ive in.1"....' volume:s anJ .Ire: calculated
~:>~ -.::: :~,c: :'ci;c.....ng c:.qu:lt;on :':om CJnonie (1993a;:
X = ~.::i.S - I!.OOOiE.7 x Y) - [:.O~6:E-: :\ (s<;uare!'O"!,,fY» - (1.97:5E.j8 x ':' :\ y)
'W~~,,:~: X = Pit e!e"at'"r:. in ft ~sI. and
Y = Pit voh;mc:. in f'.:!.
~"t I ....';(,O~?T C.~C"S:a'.Pt£DI_,(:..s .9-:n.-."
-------
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-= E E E=--:"'~Environmental
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Date ~z.& /'i4
Date '7/ C 19-(
Subject
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-------
Titan Environmental
By TAS Date 9/8/94 Subject
Chkd By- Date
Volume Comparison
Page-1-of~
ProjNo 3101-005
Conclusion:
Underground
Berkeley Pit Workings Fractured Rock
Volume 64.3 6.8 54.3
(billion gallons)
Figure 1 (anachd) represents a visual comparison of the water volume contained in each area
of interest. The total volume of water in the site from the critical water level elevation (5,410
ft msl) to the lowest mine workings (1,500 ft msl) and assuming a site area of 6.75 sq. miles
is 125 biilion gallons. Based on these large volumes of water, a pump and treat treatment
technology would not be the most feasible or economical remedial alternative to use for
remediation purposes.
References:
ARCO, 1994, "Butte Mine Flooding Operable Unit Remedial Investigation / Feasibility Study,
Draft Remedial Investigation Report." DreDared for ARCO, Anaconda, Montana, prepared by
Canonie Environmental Services Corp., January 1994.
James. Don, 1980, "Buttes Memory Book", published by the Ca.xton Printers, LTD.
The .~~rican T1"1c:t;t11t~ ~. ~ !:~:~;;, ~ ~~!:'.!!'_::-;:::.!. ,md Petroleum Engineers, Inc., 1970, "Ore
Deposits of the United States, 1933 - 1967." The Graton-Sales Volume. John D. Ridge
editor.
Stephenson, Sam, 1994, Personal communication to Sam Stephenson of ARCO from Anne
Le\\is-Russ of Titan, concerning void volumes of the underground workings in the East site
area, August 1994.
-------
/
70
60
50
VI
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g 40
OJ co
El9
:J-
- 0
o
> ~
.~ :10
in
20
10
o
VOlUME (; XI r.~!l/8J9.I1
Figure 1
Volume Comparison
Berkeley Pit
Underground Workings
,.
Fractured Rock
~
----
-------
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-------
Titan Environmental
By Date Subject
Chkd By-..P"(. Date 911-~9't'
Page_of-
Proj No
-------
TIT ANEnvironmental
Page
of
Telephone Call Record
TO:
~ame: hck :.Iajerison
Company: ARCa - Anaconda
Phone :\'"umber: ~06-563-5211
FROM:
Name: Anne Lewis-Russ
Company: TEC
Phone ~umber:
Project Number:
310 1-005
Project Name: Technical Irnpracticaiity
Date:
August 26. 1994
Time:
1 :45 pm
lack called me back after I called to ask if he had
obtained any information aboUt bedrock void
volume in the Butte area. Jack had Sam
SteDheflli)n with him. who worked for Anaconda
for a number of years. Sam had worked with Ed
~.:hneider (now with ESA) on preparing
information for public presentation when the
pumps were turned off in Kelley shaft. Sam had
2.n overhead from the presentation with the
foilowing information:
F:om the ~It. Con sump to e!evation 2195 (this
::.::i ether e !e...:lt:cns rere.ence .-\n:.conca camm)
...:": ...'..... .. -- '0.' '<:1 ,,...r. :,.3 (:_:-.""""';0'" r-rom
"..... "..-...- "- - .,~\,;.-\.I'; I. .....'...,..._...1.1. ..
a:: earlier study when part of the underground
''\"orkings \Vere flooded.
From elp.v. 2195 (elevation of Kelley pumps) to
~3JO (bottom of Berkeley Pit), void volume was
c:.lcubted at '+32.369,504 ft~. This volume was
cetermined from digitizing information in old
stope books and took into account void volume in
f:l1. For example. 30 percent void volume was
:.ssun;ec for slime fill and 20 percent void volume
',\:15 assumed for mine (gob) fill.
::::;rscn.3:5 (''''uguSI :5. 19\W1
The void volume from the bottom of the pit to
surface was not calculated; however, it would be a
conservative estimate that the same ratio of void
space was present as in the 2195 to 4320 ft
imerval.
The calculations did not include a factor for
natural void space such as fractures. The void
space is pretty well connected, but is about an
order of magnitude less than the space occupied
by the Berkeley Pit. .
This infoIT!1:ltion has been public knowledge, and
. DSL :md EPA should have it. Sam can be usd
-------
/
BUTTE'S
,.
MEMORY BOOK
by
DON JAMES
Pictures by
C. OWEN SMITHERS, SR.
/9@
-------
. £
----
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,
i '
j
I
..;.-
: 1
I '1\\' 1111
I' bCe.IIIII' It, 'I,
' .. delll,llIl' 1111111111111"
I hlcr ye.lIs '1(,11',111, 01"1'
II . I r 1,",1', ,I', II, 01'1', "I. ""
.t j" L III , , "'" dill,:, ','; . ' " '
1,1 '1111111" ..
-------
THE CITY
c::: \'it'.\,) belong to ciffere:1t gene,a:io:1s, t.lC~ ~ar:icul.1rl:--" CG:iSC:()IJ~
of its .:'-'\':1 "is:as, and each in later years re:;1embering how it \\'dS, Ci:ies
ha\'e :,ee:1 built. changed, and destroyed by r.un. They hJ.\'e be-;:-:) cC"
stro::ec by ;.'::':1..:,e, They have been destroyed simply by time.
50 Butte bs changed. Yesterday's Bu~e is not today's, nor will toc,'<5
be tOr.1orrow's, Because this book is essentially a trip back throug~ nos:J.l-
gia, we are inc!uding very few contemporar:' pictures of Butte. Possibly. in
a \vay, \\:e are depicting a city of another time.
\"evenheless, every generation, including today's youngest, will rec-
ognize places and buildings and streets and houses that still defy weather,
time, and even man.
It lakes a s~rong city of character to do that!
. ..."
, J
":
i
~ BUTTE
~-.. T~e great~st Jnining ca,~.~ ~~ ea~h" built ~~
~ t~e richest hili 'n the worlC. I hat hid. which has.,
[~ produced over ~wo billien coilars wod 0; geld. silver-.: , 3 I
!; c::pper ~nd zinc. is literally honeycombed wiL, driH. ~I i '
$': ~.lnzes and stopes that ex tend beneath the cit.y:' ,i
~ I here ar'! over 3.000 miles 0; work:nQS. ar:d shar...s' '.'"
i':- re~c~ a d~;:t;, of 4.000 fe'!~. - , -:
- -
;," ' ~ T~is imr:-:eciate c::unt:y was opened as a placer disL;cf- '
in 1864. Later But:e became a c;uarh: mining camp an ~
successive1y opened silver. c:oeper and zinc deposit.i::.
Butte has a most c:osmopolitan POpul4tiol\ derive-
fr::lm tne four corners of the world. She was a bol "
unashamed. rootin:' tootin: hell.roarin' camp in day.
... gone by and still drinks her liquor straight. . ','::~
-------
Ore Deposits
of the
-
. United States, 1933-1967.
THE GRATON-SALES VOLUME
John D. Ridge, editor
F!3.ST EDITION
Sponsored by The Rocky Mountain Fund
Volume II
Published by
The Americen Instit1Jte of Mining, Metallurgiccl, end retroleum Engineers, Inc.
~""EW YOR.." 196a
R:;:r:nt:d 1970
-------
STAT[ Y[IN S'Sf[Y
"..1 . re...
'&&81 '."..
..... 1"8
......... 18"
..
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.-
, "rt
" '.
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'. ",' ,\. ;',' 'n"t,~.~ ~,,), 'Jf.,. '''I~,I'", '" ',."
, '..., ~""-,,,..'-j;"4./,,'-"(H,~rc. .~J~.":.t~.}J..~.:,:....:, ' :.".,~
I " .
ICALI .
,
\
\
... -
, .,. A.A',..
..:.. '11 t
Fill. 9. 1.oIlC;tlltIiIlOI Stctloll a/tilt Stntt ,.till. sllow;IIC "PI'tr lim;t (// ('(II'/,er S(O/';lIg alld ZOI/t (lfwtal mil/tn/llzatiull jllS( btyol/ll coppa frolf(,
c:::Jo.. '.00'
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-------
-
~IONITORING PROGRAM
APPENDIX 3
BUTIE MINE FLOODING OPERABLE UNIT
-------
BUITE ~INE FLOODING OPERABLE C~IT
MONITORING PROGRAM REQUIREMENTS
WATER LEVEL/FLOW MONITORING:
i.
"V~lIs A~lC-6. At-.K-a. .-..~IL-.;.j. :,.\1(-2-+. A. C. G. H. D-l. 0-2. Parrott Park. LP-l.
LP-7. LP-12. LP-13. LP-14. and LP-16 wiil b~ ~4U1PP~ with automatic d~pth r~cord~rs
(i. e.. continuous monitoring).
.,
Wells AMC-5. AMC-IO. AMC-Il. AMC-12. A~C-13. AMC-15. AMC-21. B. E. F.
DDH-l. DDH-2, DDH-4. DDH-5. DDH-8. and the remaining LP wells will b~
monitored monthly for water l~vels.
3.
Water levels in the Berkeley Pit will be surveyed monthly for water level.
-+.
The following mine shafts will be monitored monthly for water levels: Anselmo.
Belmont. Emma. Granite Mountain. K~lley. ~arget Ann. Orphan Boy. Steward. and
Travona. After one year. Marget Ann and Orphan Boy will be monitored quarterly.
Additional mine shafts that may require monthly monitoring are the Badger. L~xington.
~t. Con. and Original.
5.
Residential and municipal wdls in the general area bounded by Cobban Street on the
south. 2nd Street on the north. south and west of Continental Drive. and east of Montana
Street. (also delineated in the Remedial Investigation Report. Section 8 - Private Well
Inventory (Task 6» wishing to participate in a water level monitoring program will be
monitored monthly for water levels.
6.
The following surface flows/stations will be monitored monthly for water flows: SS-07
(also designated as SF-7 (Silver Bow Creek below Colorado Tailings) in Upper Clark
Fork Long-Term Monitoring Program), SS-04 (also designated as SF-4 (Blacktail Creek
above contluence with Metro Storm Drain) in Upper Clark Fork Long-Term Monitoring
Program), and seep adjacent to Green Lake.
7.
The following surface flows/stations will be monitored continuously for surface water
discharge/tlows to the Berkeley Pit: Stations 3B and 5D as delineated in Remedial
Investigation Report. The method used to monitor Station 3B may be altered from that
used in the BMFOU RI. It is the objective of monitoring Station 3B to quantify
frequency, duration. and volume of tailings slurry overtlow from the McQueen Booster
Station.
8.
QA/QC shall follow Butte Mine Flooding Operable Unit Sampling and Analysis Plans
(SAPs) unless otherwise specitied.
WATER QUALITY MONITORING:
Wells AMC-5. AMC-6. AMC-8, AMC-12. AMC-13. AMC-15. AMC-21. AMC-23.
AMC-2-+. A. B. C. D-l, D-2. E, F, G. H, LP-8. LP-9, LP-lO. LP-ll, LP-12. LP-14.
1.
MP-l
-------
LP-15, LP-16, and LP-17 will be sampled semiannually for water quality. Wells AMC-
10 and AMC-ll will be sampled semiannually for water quality if current conditions
change. After two years (Le.. four sampling events) Wells AMC-12, AMC-13, AMC-
15, AMC-23, and AMC-24 will be sampled annually but subject to EPA/MDHES
revIew.
.,
The iollowing mine shans will be sampled semiannually for water quality: Anselmo.
Belmont. Granite \'fountain. Kelley, \'farget Ann. and Orphan Boy. The Travona will
be sampled (maximum of one monthly sample) during pumping activity. After two years
(i.e.. four sampling events) sampling frequen~y will be annually (except for the Travonal
but subject to EPAIMDHES review.
3.
The following surface tlows/stations will be sampled monthly for water quality (metal
parameters shall be analyzed for total and dissolved concentrations): SS-07 (also
..: ~signated as SF-7 (Silver Bow Creek below Colorado Tailings) in Upper Clark Fork
LMg-Term Monitoring Program), SS-04 (also designated as SF-4 (Blacktail Creek above
contluence with Metro Storm Drain) in Upper Clark F~rk Long-Term Monitoring
Program), and seep adjacent to Green Lake
4.
The following surface tlow/station that discharges to the Berkeley Pit will be sampled
monthly for water quality (metal parameters shall be analyzed for total and dissolved
concentrations): Station 5D as delineated in Remedial Investigation Repon. After one
year (Le., twelve sampling events) sampling frequency will be semiannually.
5.
Parameters for water quality lab analysis include: As. Ca, Cd, Cu, F, Fe, Ni. Mn, Pb.
S04' Zn, pH, SC. TDS. Temp, Hardness, Alkalinity. and Nitrate.
6.
QA/QC shall follow Butte Mine ,Flooding Operable Unit Sampling and Analysis Plans
(SAPs) unless otherwise specified.
YANKEE DOODLE TAILINGS DAM MONITORING REQUIREMENTS:
1.
The monitoring plan, as developed in the Harding Lawson Associates repon. "Seismic
Stability Evaluation, Yankee Doodle Tailings Dam, Butte, Montana." shall be
developed and implemented.
2.
The phreatic surface requires greater definition. The phreatic surface shall be found at
different distances u.s. of the embankment and in the embankment. The phreatic surface
level shall then be modeled for enlarged facility. Monitoring devices shall be installed
to determine if the phreatic surface is following the model. Contingencies shall be
developed to take care of the situation of the phreatic surface rising above that level
developed in the model. Note, Borehole 92-2B is missing from Plates 14 and 15, and
the depth to tailings from borehole 92-2B appears inconsistent with the depth to tailings
in the same vicinity as presented in Plates 14 and 15. Once the phreatic surface and
depth to tails is reconciled. 'the stability shall be reexamined.
3.
More data is needed in the bench material where future up stream lifts will be founded.
This data collection requirement shall include at a minimum: SPT and/or CPT values
on several alignments extending up stream on the beach from the existing u.s. face to the
-------
limits of the future u.s. lifts: densitv and moistUre protiles on the same SOrt of alignments
to depths of at least 100 feet below the existing surface; strength characteristics such as
friction angle, cohesion, and consolidation of the tailing beach material should be
determined for the various tailing material discovered in the above mentioned study area.
Also geophysical investigations (i.e.. EM, siesmigraph. etc.) of the beach. embankment.
and downstream structures shall he conducted.
4.
The strength and other physical characteristics. including void space. of the construction
;naterial shall be determined. Contingencies shall be developed to deal with the material
during construction if the material characuiristics are not as predicted. A QA/QC
program shall he ueveloped to inspect. test. and report construction material
characteristics.
FUTURE MONITORING AND ADDITIONAL :\IONITORING WELL REQUIR~. 1ENTS:
1.
Four bedrock-monitoring wells shall be installed as part of the monitoring program.
These bedrock-monitoring wells are for the Travona/West Camp System. These four
wells will be sited in the locations as depicted in the attached map.
2.
~DHES will coordinate yearly updates. in the form of a wrinen report. that incorporates
the new data gathered from the previous twelve months. and an updated report on the
prediction of when the CWL for the Berkeley Pit/East Camp System will be reached.
3.
Every three years EPA and MDHES shall review the monitoring program's
completeness. The three year review is to adjust. as determined by EPA and MDHES.
the requirements of the monitoring program. Based on this review. additional monitoring
wells may be required.
4.
Any new monitoring well shall be equipped with automatic depth recorders (i.e..
continuous monitoring) for a period of no less than three years but subject to
EPA/MDHES review.
5.
Any new monitoring well shall be sampled semiannually for water quality (metal
parameters shall be analyzed for total and dissolved concentrations); after tWo years (i.e..
four sampling events) sampling frequency will be annually but subject to EPA/MDHES
review.
-------
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Scale 0' Feet
-------
RECORD OF DECISION
-
BUTTE MINE FLOODING OPERABLE UNIT
SILVER BOW CREEK/BUTTE AREA NPL SITE
BUITE, MONTANA
September 29, 1994
United States Environmental Protection Agency
Region VIII - Montana Office
Federal Building, 301 South Park, Drawer 10096
Helena, MT 59626-0096
(Lead Agency)
Montana Department of Health and E:wironmental Sciences
Solid and Hazardous Waste Bureau
2209 Phoenix A venue
P.O. Box 200901
Helena, MT 59620-0901
(Support Agency)
-------
RECORD OF DECISION COMPO~NT LOCATOR PAGE
(Components in bold are in this volume)
VOLUME I of III
Record of Decision
Appendix 1 - ARARs
Appendix 2 - Technical Impracticability Evaluation
Appendix 3 - Monitoring Program
VOL{;~fE n of ill
~ppendix 4 - Responsh'eness Summary (Agencies Responses to Comments)
Attachment 1 - Identification of Comments Recei\'ed
VOLUME III of III
Appendix 4 - Responsiveness Summary
Attachment 2 - Transcript of Public Hearing
-------
-
RESPO~SIVE."'ESS SUMMARY
APPENDIX 4
BUITE MINE FLOODING OPERABLE UNIT
-------
TABLE OF CO~'TE~TS
SECTION
1.0 ISTRODUCTION """""""""""""""""""""'"
1.1 SITE BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.2 CO~1MUNITY ISVOL VB1E?\T BACKGROUND. . . . . . . . . . . . . . . . . .
1.2.1 PUBLIC ~1EETI~G PCBLICITY . . . . . . . . . . . . . . . . . . . . . . . .
1.2.2 AD~lI!'\ISTRA TIVE RECORD. . . . . . . . . . . . . . . . . . . . . . . . .
1.2.3 DOCUMENT REPOSITORIES. . . . . . . . . . . . . . . . . . . . . . . . .
1.2.4 CITIZEN GROUPS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.2.5 PROGRESS REPORTS A!'\D FACT SHEETS. . . . . . . . . . . . . . . .
1.2.6 MAILING LIST. . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . .
1.3 CHRONOLOGY OF CO~1MUNITY RELATIONS ACTIVITIES. . . . . . . . .
1.4 EXPLANATION OF RESPONSIVEKESS SUMMARY. . . . . . . . . . . . . . .
2.0 SV~IMARy.:OF WRIITEN A?"D ORAL COMMENTS RECEIVED ON THE PROPOSED
PLAN FOR THE MFOU RI/FS . . . . . . . . . ; . . . . . . . . . . . . . . . . . . . . . . . . .
NON-TECHNICAL CO~1MENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
CRITICAL WATER LEVEL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
USE OF OTHER TECHNOLOGIES FOR TREATMENT. . . . . . . . . . . . . .
METALS RECOVERY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . .
MORE MONITORING WELLS-E~HANCED MONITORING PROGRAM.
TAKE ACTION NOW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMMENTS RELATED DIRECTLY TO THE PROPOSED PLAN. . . . . .
A. DISAGREE WITH EPA PROPOSED PLAN. . . . . . . . . . . . . . . .
B. AGREE WITH EP A PROPOSED PLAN. . . . . . . . . . . . . . . . . .
COST............................................ .
CONTROL INFLOW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
CO~1MENTS DIRECTLY RELATED TO EPA'S ~INE CRITERIA. . . . . .
A. REDUCTION OF TOXICITY, MOBILITY, AND VOLUME. . . . .
B. CONCERNS ABOUT SUPERFUND PROCESS IN GENERAL. . . .
C. SHORT-TERM EFFECTIVENESS CONCERNS. . . . . . . . . . . . .
D. LONG-TERM EFFECTIVENESS CONCERNS. . . . . . . . . . . . . .
E. OTHER ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . .
. F. PERMANENT CLEANUP. . . . . . . . . . . . . . . . . . . . . . . . . . .
G. PROTECT AGAINST RELEASE A~1) THREAT OF RELEASE. . .
H. CONCERNS ABOUT THE PROPOSED PLAN. . . . . . . . . . . . . .
I. PUBLIC PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . .
J. SOCIAL AND ECONOMIC ISSUES. . . . . . . . . . . . . . . . . . . . .
3.10 PETITION..........................................
3.11 MISCELLANEOUS ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. A. SCIENTIFIC STUDY OF PIT . . . . . . . . . . . . . . . . . . . . . . . . .
B. UPDATING DATA AFTER RECORD OF DECISION. . . . . . . . .
3.12 INSTITUTIONAL CONTROLS/APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . .
A. INSTITUTIONAL CONTROL ISSUES. . . . . . . . . . . . . . . . . . .
B. ARARs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
C. WATER FOWL. . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . .
D. INTERACTION OF PLAN WITH NATURAL RESOURCE DAMAGE
ACTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.0 PART I:
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
RS-ii
PAGE
1-1
1-1
1-2
1-3
1-3
1-3
1-3
1-3
1-3
1-4
1-5
2-1
3-1
3-1
3'{}
3-8
3-10
3-13
3-16
3-16
3-18
3-19
3-26
3-29
3-29
3-31
3-33
3-34
3-34
3-35
3-36
3-36
3-38
3-39
3-40
3-41
3-41
3-41
3-42
3-42
3-43
3-44
-------
TABLE OF CO~"E~"S
(continued)
SECTION
E. IMPACTS TO SILVER BOW CREEK. . . . . . . . . . . . . . . . . . . .
F. FUTURE LA~D USE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
G. GROUND COVER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
H. DUST. . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . . . . . . . . . .
1. WINTER FOG. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
J. MDHES REPORT TO ENVIRONMENTAL QUALITY COUNCIL.
3.13 I~NOVATIVE TECHNOLOGIES. . . . . . . . . . . '. . . . . . . . . . . . . . . .
3.14 SLUDGES..........................................
3.15 WATER TREATMENT FACILITY. . . . . . . . . . . . . . . . . . . . . . . . . .
3.16 WATER ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A. BEDROCK AQUIFER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
B. WATER QUALITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
C. BERKELEY PIT FILLING RATE. . . . . . . . . . . . . . . . . . . . . .
D. DOMESTIC WELL WATER QUALITY. . . . . . . . . ',' . . . . . . .
E. DRAIN THE PIT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
F. FLOOD THE PIT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
G. WATER ESCAPING PIT . . . . . . . . . . . . . . . . . . . . . . . . . . . .
H. USE OF TREATED HORSESHOE BEND WATER. . . . . . . . . . .
1. WEST CAMP W A TERrrRA VONA .....................
J. OUTER CAMP/LONG-TERM VIABILITY. . . . . . . . . . . . . . . .
3.17 , EFFECTS OF EARTHQUAKE ON BERKELEY PIT. . . . . . . . . . . . . . .
3.18 ARCO'S RESPONSIBILITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.19 MINING-RELATED COMMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . .
A. POTENTIAL CONTINENTAL PIT PROBLEMS. . . . . . . . . . . . .
B. PRESENT AND FUTURE MINING. . . . . . . . . . . . . . . . . . . . .
4.0 PART ll:
4.1
4.2
4.3
4.4
4.5
TECHNICAL COMMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
USE OTHER TECHNOLOGIES FOR TREATMENT. . . . . . . . . . . . . . . .
MONITORING PROGRAM. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COST............................................. .
CONTROL INFLOW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
WORK PLAN ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A. WORK PLAN TOO NARROW. . . . . . . . . . . . . . . . . . . . . . . . .
B. NEED FOR FLEXIBILITY. . . . . . . . . . . . . . . . . . . . . . . . . . .
C. HOW WILL WE KNOW THE PLAN WORKS. . . . . . . . . . . . . .
4.6 PIT SEDIMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.7 INNOV A TIVE TECHNOLOGIES. . . . . .. . . . . . . . . . . . . . . . ',' . . .
4.8 SLUDGES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.9 WATER TREATMENT FACILITY. . . . . . . . . . . . . . . . . . . . . . . . . .
4.10 WATER ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A. BEDROCK AQUIFER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
B. WATER QUALITY. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .
C. WATER USERS AND RIGHTS. . . . . . . . . . . . . . . . . . . . . . . .
RS-iii
PAGE
3-45
3-45
3-45
3-46
3-46
3-46
3-47
3-54
3-57
3-58
3-58
3-59
3-60
3-61
3-61
3-62
3-62
3-63
3-64
3-65
3-66
3-67
3-68
3-68
3-69
4-1
4-1
4-4
4-6
4-7
4-9
4-9
4-10
4-11
4-12
4-13
4-16
4-19
4-20
4-20
4-23
-------
SECTION
5.0
TABLE OF CO~lE~lS
(continued)
4.11
D. BERKELEY PIT FILLING RATE. . . . . . . . . . . . . . . . . . . . . .
E. WEST CA~P W A TERrrRA VONA .....................
\lINI1':G RELATED CO\f\1ENTS . . . . . . . . . . . . . . . . . . . . . . . . . . .
A. LOSS OF THE ORE BODY. . . . . . . . . . . . . . . . . . . . . . . . . .
B. POTENTIAL CONTINENTAL PIT PROBLE~S .............
C. PRESENT AND FUTVRE MINING. . . . . . . . . . . . . . . . . . . . .
HUMAN"HEALTH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.12
RESPONSES TO COALmON CO\1MENTS DATED 6/30/94 . . . . . . . . . . . . . .
ATTACH~1ENT 1
ATTACHMENT 2
ATTACHMENT 3
Identification of Comments Received
Transcript of Public Hearing
Written CommentS
RS-iv
PAGE
4-26
4-28
4-29
4-29
4-31
4-33
4-34
-------
A~1C
AMD
AOC
ARARs
ARCO
ASARCO
BEPA
BSB
CERCLA
CFC
efs
CTEC
CWL
DSL
D~RC
DOE
EE/CA
Eh
EPA
EQC
ESD
ET
FS
FSR
ft
ft msl
gpm
HLA
IC
m2/sec
MBMG
MBTA
MCA
MCE
MCL
MDHES
MFOU
mgd
mg/I
MR
MRI
MSHA
NCP
NEPA
NPL
NRD
O&M
OTA
OSHA
OSWER
LIST OF ABBREHATIONS, ACRO~}'MS, A~l> I~lTIALIS:\IS
Anaconda Minerals Company
Acid Mine Drainage
Administrative Order on Consent
Applicable or Relevant and Appropriate RequirementS
Atlantic Richfield Company
American Smelting and Refining Company
Bald Eagle Protection Act of 1940
Butte-Silver Bow
Comprehensive Environmental Response, Compensation and. Liability Act of 1980
Clark Fork - Pend Oreille Coalition
cubic feet per second
Citizens Technical Environmental Committee
Critical Water Level
Montana Department of State Lands
Montana Department of Natural Resources and Conservation
U.S. Department of Energy
Engineering Evaluation/Cost Analysis
oxidation-reduction potential
U.S. Enviroiunental Protection Agency
Environmental Quality Council
Explanation of Significant Differences
Evapotranspiration
Feasibility Study
Feasibility Study Report
feet/foot
feet mean sea level
gallons per minute
Harding Lawson Associates
Institutional Control
meters squared per second
Montana Bureau of Mines and Geology
Migratory Bird Treaty Act of 1918
Montana Codes Annotated
maximum credible eanhquake
Maximum Contaminant Level
Montana Department of Health and Environmental. Sciences
Mine Flooding Operable Unit
million gallons per day
milligrams per liter
Montana Resources
Montana Resources, Inc.
Montana Safety and Health Act
National Contingency Plan
National Environmental Policy Act
National Priorities List
Natural Resource Damage
Operation and Maintenance
Office of Technological Assessment Congressional Study Group
Occupational Safety and Health Act
Office of Solid Waste and Emergency Response (EPA)
-------
Ph
Pit
ppb
PRP
psi
PSOU
RCRA
RDfRA
RFP
RIfFS
RO
ROD
RPM
SARA
SITE
SXfEW
SU
IDS
WQC
LIST OF ABBR£\lATIO~S, ACRO;..)",IS, A.\1> l;..lTIALIS~IS
(continued)
negative log of the hydrogen ion concentration
Berkeley Pit
parts per billion
Potentially Responsible Party
pounds per square inch
Priority Soils Operable Unit
Resource Conservation and Recovery Act
Remedial Design/Remedial Alternative
Reasonable Further Programs
Remedial Investigation/Feasibility Study
Reverse Osmosis
Record of Decision
Remedial Project Manager
Superfund Amendments and Reauthorization Act of 1986
Superfund Innovative Technology Evaluation
Solvent ExtractionfElectrowinning
Standard Units
Total Dissolved Solids
Water Quality Criteria
RS-vi
-------
1.0 I:\JRODUCTlO~
1.1
SITE BACKGROU~1>
Butte hi$torically has been an important mining, milling, and smelting district. Gold was first discovered
near Butte in 1864. Placer and quartz mining for gold was the primary mining activity in Butte for
several years after gold was first discovered. Copper and silver, which were also discovered along with
gold in the 1860s, became the primary focus of miners in 1874. By 1884, there were over 300 operating
copper and slIver mines, 4,000 posted claims, nine silver mines and eight smelters. During the course
of mining activities, over 500 mines and shafts were developed resulting in an estimated 3,000 miles of
underground workings and 150 major waste rock dumps cOQtaining an estimated 9. 85-miJIion cubic yards
of waste covering 350 acres. Eleven silver mills and three major smelting operations also resulted in soil
contamination throughout the Butte Hill mining area.
In July 1955, the Anaconda Copper Mining Company began open pit mining in the Berkeley Pit. In
1963, the Weeri Concentrator (now known as the MR Concentrator) became operational. Ore from the
Berkeley Pit ........,rocessed at this facility, and con\;entrates were transported to Anaconda, Montana for
smelting. The Atlantic Richfield Company (ARCO) purchased the Anaconda Copper Mining Company
in 1977 and owned the pit and associated property until it was sold to Dennis Washington/Montana
Resources, Inc. (MRI) in 1985. In 1989, a partnership known as Montana Resources (MR) was formed
between ~fRI and AR Montana Corporation, a subsidiary of American Smelting and Refining Company
(ASARCO). MR was formed to own and operate the property.
Mining in the Berkeley Pit was discontinued in 1983. Since July 1986, open pit mining has been
conducted in the East Continental Pit, located east of the Berkeley Pit. Ore from this pit is transported
to the MR Concentrator for milling.
To allow underground and then open pit mining in the Butte area, groundwater was lowered by pumping.
The pumping system was located in the Kelley Mine shaft, just west of Berkeley Pit. In 1982, pumping
was discontinued. As a result, the artificially lowered groundwater level in the area has been rising
toward its pre-mining level in the underground mines and Berkeley Pit. The pit filling rate is decreasing
with time and as the water level rises. For example, the 1988 filling rate was estimated to be 7.6 million
gallons per day (mgd); and the pit is currently estimated to be filling at a rate of 5 mgd. In December
1993, the elevation of the water in the pit was 5,062.67 feet (ft). It is currently projected that the critical
water level (CWL) of 5,410 feet for the Pit System will be reached around the year 2015 if no remedial
actions are taken.
In 1983, the U.S. Environmental Protection Agency (EPA) designated Silver Bow Creek and contiguous
ponions of the Upper Clark Fork River as a Superfund site by placing it on the National Priorities List
(NPL). The site was amended in 1986 to include source areas in and around Butte, and the site became
known as the Silver Bow CreeklBune Area Site.
Preliminary Mine Flooding Operable Unit (MFOU) Remedial Investigation/Feasibility Study (RIfFS)
forward planning studies began during the summer of 1987. In support of the MFOU, EP A conducted
an evaluation of mine flooding in the Berkeley Pit and West Camp and an evaluation of the pit water
chemistry. These evaluations indicated that it would be necessary to control the rate of pit filling to
prevent any further impact to Silver Bow Creek. The evaluations further demonstrated the need to treat
the pit water prior to discharge to Silver Bow Creek.
A removal action was implemented in the West Camp area to control potential impacts of rising mine
waters. The purpose of the removal action was to prevent flooding of basements and discharge of
-------
contaminated groundwater to Silver Bow Creek. An Engineering Evaluation/Cost Analysis (EE/CA) of
potential response alternatives was conducted by EPA in support of the West Camp removal action.
On March 31, 1989, EPA entered into an Administrative Order on Consent (AOC) with ARCO and
Dennis Washington (the consenting PRPs) pursuant to Section 106(a) of CERCLA as amended by SARA
in connection with the West Camp removal action. The West Camp order required the consenting PRPs
to convey water from the Travona Shaft to the Butte Metro Plant for treatment and discharge to Silver
Bow Creek. In the event that the Metro Plant could not accept this water, the consenting PRPs would
be required to construct a treatment plant for treatment of Travona Shaft effluent prior to discharge to
Silver Bow Creek. This AOC established a preliminary CWL for the West Camp and required the
consenting PRPs to maintain water level elevation below 5,43,5 feet (USGS datum).
A unilateral Order was issued to the non-consenting PRPs to install the pipeline which carried Travona
shaft water to the Butte-Silver Metro Sewer Plant line. The non-consenting PRPs complied with this
Order.
EPA completed the RIfFS Work Plan for the Mine Flooding OU in April 1990. This document outlined
the work to be conducted during the RI/FS, the schedule for the work, and the parties responsible for
each portion of the work. EPA and the State then entered into an AOC with the consenting PRPs to
implement the major portion of this work plan. This AOC directed the PRPs to conduct the work
according to the Work Plan with EPA and MDHES oversight. The AOC also established a preliminary
CWL of 5,410 feet (USGS datum) for the East Camp/Berkeley Pit System and required the PRPs to
maintain the water elevation below this level. A unilateral Order was also issued to the non-consenting
PRPs to implement a small portion of the RIIFS work plan. The RIIFS was conducted from July 1990
through January 1994. Site investigations, results, and remedial alternative development and evaluation
are presented in the Draft RI and FS Reports.
The RIIFS was conducted from 1990 to 1994, and included an inflow control investigation, a
characterization of the bedrock aquifer, an investigation of the leach pads area alluvial aquifer system,
sampling of the Berkeley Pit, treatability testing, evaluation of the water balance in the MFOU, a risk
assessment, and development and evaluation of remedial alternatives. Site investigations, results, and
remedial alternative development and evaluation are presented in the Preliminary Draft RI Report and the
Preliminary Draft FS Report.
EPA, with the concurrence of MDHES, released a Proposed Plan for the site in January 1994. A public
comment period was held from January 27 to April 29, 1994. An informational meeting was held on
January 27, 1994 and a technical meeting was held on February 1, 1994 to explain the Proposed Plan
and the potential alternatives. On March 8, 1994, EPA held a public hearing to allow the public to
submit formal oral comments. This Responsiveness Summary presents EPA's and MDHES's responses
to the comments received.
1.2
CO~I~~lTY INVOLVEMENT BACKGROUND
EP A has conducted community involvement activities for the MFOU RI/FS in accordance with state and
federal laws and EP A Superfund guidance documents. Additionally, EP A's philosophy is that the citizens
of Montana, and especially residents living on or near Superfund sites, will be most affected by the
decisions of the agency and therefore should have the opponunity to be actively involved in the decision
making process.
A Community Relations Plan was first developed for the Silver Bow Creek/Butte Area site in 1983 and
was revised several times. After extensive interviews of local citizens and community leaders, this
document was last revised in September 1991.
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1.2.1 PUBLIC ~IEETL"G Pl'BLlCITY
:-':ews releases were sent to the media mailing list periodically before public meetings and to announ.::e
public comment periods. The media mailing list includes all print and electronic media in Butte. In
addition, these meetings were advertised in local papers and lor on a local radio station. Print
advertisements were display style, conspicuously large (at I~t two columns by five inches) in a widely
read section of the local paper, the Montana Standard.
1.2.2 AD~fI:\lSTRA TIVE RECORD
The Administrative Record is the set of documents identified for the site upon which the selection of the
remedy is based. The Administrative Record is required by CERCLA.
The Administrative Record for the site is available at the ~iontana Tech Library in Butte and the EPA
Montana Office in Helena. In addition, important site-related documents are available at the Butte EPA
Office located in the basement of the County courthouse in Butte, ~iontana.
1.2.3 DOClJMENT REPOSITORIES
Site documents and other information have heen. and will continue to be, made available to the public.
EP A has established repositories for site documents at the ~iontana Tech Library, the Butte EP A Office,
and the EPA Montana Office in Helena, Montana. EPA adds documents to the repository as quickly as
possible after publication.
J.2.4 CmZEN GROUPS
In 1992, the Citizens Technical Environmental Committee (CTEC) received an EPA $50,000 technical
assistance grant for the Silver Bow Creek/Butte Area site. CTEC has regular monthly meetings that often
include activities connected to the MFOU RI/FS. EPA and ~1DHES site staff attend these meetings and
are also available by phone or in person as questions arise. The EP A Remedial Project Manager (RPM)
for this action is locateo in Butte and is regularly available to the public.
EPA and MDHES have also worked closely with the Clark Fork-Pend OreiHe Coalition of.Missoula,
Montana. In late 1992, the Coalition hired a staff member who works on upper Clark Fork River issues
in an office in Butte. EPA and MDHES stay in regular contact with this staff member about MFOU
RIIFS issues. This staff member also became a member of the CTEC board of directors in Spring 1993
and was recently elected Vice President of CTEC.
1.2.5 PROGRESS REPORTS A..''D FACT SHEETS
EP A publishes progress reports and fact sheets containing information on recently released documents,
upcoming meetings, site activities, completion of projects, sampling results, etc. These reports are sent
to people whose names are on the site mailing lists. Extra copies are disttibuted to pamphlet racks at a
number of public locations and are maintained in the Butte EP A office.
1.2.6 MAILING LIST
EPA actively maintains the site mailing list on a computer database and updates the list periodically.
EP A actively solicits additions to the mailing list in the progress reports and at public meetings.
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1.3
1990
1991
1992
1993
1994
CHRO~OLOGY OF CO~f~f1j~ITY RELATIO:\S ACTI\lTIES
Prepared and distributed a ~1ay 1990 fact sheet regarding the RlfFS Work Plan.
Two separate display advertisements were placed in the Montana Standard announcing the AOe,
LTnilateral Order and Work Plan for the ~1FOU Rl/FS and public meetings scheduled to discuss
these issues.
EPA conducted an informational meeting (~1ay 8, 1990) and a formal hearing (May 30, 1990)
regarding the Work Plan and RlfFS.
Two separate display advertisements were placed in the Montana Standard announcing an MFOU
RIfFS update meeting subsequently held on April 25, 1991.
Two display advertisements were placed in the .\1omana Standard announcing an MFOU RIfFS
update meeting subsequently held on May 6, 1991.
Two display advertisements were place in the Momana Standard announcing an MFOU RIfFS
update meeting subsequently held on October 30, 1991.
Two separate display advertisements were placed in the Montana Standard announcing a MFOU
RIfFS update meeting subsequently held on July 30, 1992.
Two separate display advertisements were placed in the Montana Standard announcing a MFOU
RIfFS update meeting subsequently held on April 23, 1993.
January
Two display advertisements were placed in the Montana Standard announcing the ava~lability of
the Proposed Plan and the public comment period, and outlining upcoming meetings regarding
the MFOU RIfFS.
The Proposed Plan was distributed via first class mail to a mailing list consisting of more than
1,000 names.
An informational briefing for the media and other officials was held on January 27, 1994.
An informational public meeting was also held on January 27, 1994.
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February
A technical public meeting was held on February I, 1994 to discuss the MFOU RIfFS.
Met with Clark Fork Pend Oreille Coalition twice in February 1994 to discuss MFOU RIfFS.
On February 9, 1994, EPA gave an informational presentation to the Butte-Silver Bow (BSB)
Council of Commissioners,
. EPA attended at CTEC meeting on February 10, 19~4, at which the MFOU RIfFS was discussed.
On February 22, 1994, EPA RPM discussed the Proposed Plan, the RIfFS, and the preferred
alternative on a radio call-in show "Party Line".
~farch
On March 8, 1994, EP A' conducted an informational meeting on the MFOU RIfFS and the
Proposed Plan at Montana Tech where a class of 50 was required to attend.
On March 13, 1994, EPA RPM discussed the Proposed Plan, the RIfFS, and the preferred
alternative on a television public affairs show "Focus".
April
A formal public hearing was held on April 26, 1994.
In addition to the formal meetings throughout the entire four-year process, EPA made presentations,
answered questions, and discussed the Proposed Plan and RIfFS with several groups, including CTEC,
Clark F:::-!-: Pend OreiIJ~ Coalition, BSB Council of Commissioners, the PRPs, the Silver I:0W Kiwanis,
and the Big Butte Kiwanis.
1.4
EXPLA1"IJATION OF RESPO~SIVEJ\"ESS S1J~fMARY
Comments were received during the public com~.ent i-,eriod from various parties, which are identified
in Attachment 1. Two types of comments were received by EPA: (1) oral comments which were
presented at the formal public hearing on April 26, 1994 (Attachment 2) and (2) written comments
(Attachment 3). The comments presented at the public hearing were recorded and transcribed by a court
reporter. In addition, some commenters at the public hearing submitted written materials for the record
which are included in Attachment 2.
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2.0 Sl~f'fARY OF WRI1TE~ A.\"D OR.\L CO'I'IE:\.S RECEIYED O~ TIlE PROPOSED
PLA~ FOR TIlE 'IFOU RI/FS
The responses to comments on the Proposed Plan are prepared jointly by EPA and MDHES. The
word "we" in the responses to comments refers to EPA and MDHES. The comments are organized
into the following parts:
Part I: ~on-Technical Comments (Section 3.0). '),'hich include summ2ries of remarks made
by citizens, local government, environmental organizations, ~1DHES, as well as some PRP
comments. Each comment is followed by EPA's and MDHES's response. Policy comments
are generally included in this section.
Part n: Technical Comments (Section 4.0), which provide a comprehensive set of technical
and legal comments and EPA's and MDHES's detailed responses. These comments include
summaries of the remarks made by the PRP, environmental organizations, ani' citizens. The
comments include comprehensive discussions concerning the preferred altern.ili ve.
Section 5.0, which include responses to the Clark Fork - Pend Oreille Coalitions' (CFC)
comments dated June 30, 1994.
As much as possible, comments in Sections 3.0 and 4.0 have been summarized and grouped to
provide an overview of the comments and to give a sense of which general topics generated the most
interest or concerns. Each comment is followed by a note in parentheses, which identities the party
or parties making the comment. Attachment 1 contains a list of each source used in this
Responsiveness Summary.
It should be noted that, while only formal public comments are presented and responded to in this
Responsiveness Summary, EP A and MDHES have also considered other information in the remedy
selection process. EPA and MDHES have considered information from meetings held among EPA,
MDHES, ARCO (and other PRPs), BSB, and other parties during the MFOU RIIFS process.
All comments received, including those provided to EPA outside the comment period, have been
reviewed and considered by EP A and MDHES in the decision-making process and are addressed in
this Responsiveness Summary.
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PART 1- ~O:'IJ-TECH.'\1CAL COM~fE~'TS
3.0 PART I: :\O:'IJ-TECH.'\1CAL COM~IE:'IlTS
3.1
CRITICAL WATER LEVEL
CommentJ-J:
An assumption underlying all discussions and plans regarding the Pit has been
the concept of the CWL.
.
How did this concept come to be the officially sanctioned key to the
solution of the Pit System problem?
.
How was the CWL determined?
.
By what definition is it "protective" as a final remedy?
.
If groundwater modeling specialists are skeptical about any predictions
more than five or ten years into the future, why isn't a greater safery
factor built into the calculation of the final remedy? (G J)
Response:
In the negotiations with the PRPs for the MFOU RIfFS, a preliminary CWL
of 5,410-ft elevation was established. This agreement specified stipulated
penalties of $25,000 per day if this level was ever exceeded. The preliminary
CWL was established at this elevation because this was the water level in
Silver Bow Creek at the west end of the Colorado Tailings where the alluvial
system constricts and upwells into the Rocker canyon.
EPA and the State viewed this level as the maximum allowable water level for
the Pit System (not just the Pit), and it would be lowered, if necessary, based
on the findings of the RI. The RI was designed to investigate the alluvial and
bedrock water levels and gradient throughout the area. After completion of
the RI, the data were assimilated and the 5,410-ft level was determined to be
protective and deemed the official CWL. The RI conclusively showed that the
alluvial water levels in the Upper Basin are higher than the CWL and that the
Pit/East Camp System cannot discharge to the higher alluvial system if the Pit
System is kept below the 5,410-ft level. This level is, therefore, protective.
The 5,410-ft level is at least 50 ft lower than the alluvial water levels at the
alluvial groundwater divide south of the Pit. Additionally, the highest level
in the East Camp is 40 ft higher than the present Pit level. If this gradient
between the Anselmo and the Pit remains or the even becomes 20 ft less, the
Pit level will be at least 70 ft below the alluvial groundwater d.ivide adjacent
to the Pit.
The skepticism expressed by groundwater modeling experts pertains to the
predicted hydrologic impact that the rising bedrock system may have on the
alluvial system flow patterns. We acknowledge the limitations of the existing
model applications in trying to make such predictions; however, EP A and the
State still believe that the inward gradient will contain the contaminated Pit
and bedrock aquifer waters. We believe that the impact of rising bedrock
waters on shifting additional alluvial waters presently flowing toward the Pit
-------
Comment 1-2: -
. Response:
Comment 1-3:
Response:
PART I - ~O~-TECl£\lCAL CO~f~fE~IS
down the ~fetro StC'lrm Drain, or rises in the alluvial water level in the ~fetro
Drain area, will be minor.
In I ight of the uncertainty in trying to model this impact, we are planning to
provide further assurances in two ways. First, the monitoring system is set up
with a very high density of alluvial wells in the upper Metro Storm Drain area
where we would observe any increased flow or contaminant loading if it
occurred. We would be able to react to any such changes immediately.
Second, EPA plans to design the Cpper Metro Storm Drain remedial action
for :.he Priority Soils Operable Cnit, which must address alluvial groundwater
problems to accommodate flow and contaminant loading increases that might
occur due to this "diversion" of the alluvial flow away from the Pit and down
the Metro Storm Drain.
Comment expressed the need for assurances that the critical water level (CWL)
is never approached. (BSB 2)
The Record of Decision (ROD) and subsequent enforcement action will
provide these assurances. EP A and the State have integrated a specific time
schedule into the ROD. Construction of a treatment plant capable of holding
the entire East Camp System below the CWL must be completed four years
prior to the projected water level reaching the highest point within the East
Camp. Currently the highest water level is at the Anselmo Mine, which is
about 40 ft above the current Pit water level. It is presently projected that the
CWL will not be reached until the year 2025 (assuming 2.4 million gallons
per day (mgd) inflow control and the Anselmo water level 20 ft above the Pit
level). Construction of the final treatment facility therefore would have to be
completed by 2021. These dates will be revised every three years based on
the growing water level database.
The CWL is wrong or unacceptable and should be lowered to a more
protective level. (BSB 4-B, BSB 7, 11. 13, 143, BSB 12-B, BSB 12-A, T 5,
14)
EPA and the State believe that the CWL is protective, based on the following:
1)
Alluvial water level adjacent to the Pit is 50 ft higher than the CWL.
2)
The CWL will be measured at the highest point in the East Camp
System, presently the Anselmo mine, which is 40 ft above the Pit
level. This provides an additional safety margin.
3)
The comprehensive monitoring program would act as an early warning
system.
4)
ConstruCtion must be completed four years prior to reaching the CWL
at the highest point in East Camp.
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Comment 1-4:
Response:
Comment ].5:
Response:
Comment ].6:
Response:
Comment ]-7:
Response:
Comment ]-8:
Response:
Commem 1-9: .
PART 1- ~O~-TECH.'\lCAL COM~IE~'TS
1t was suggested in comments submitted by BSB to provide additional
protection by requiring that a trearment planr be built three years prior to
reaching the CM... (ESB 4-K)
We believe that four years will be necessary to "shakedown" the facility and
will allow time to react to unanticipated contingencies (i.e., sludge handling or
dewatering problems, solids settling problems, metals remvoal effciency
difficulties, unanticipated impacts on groundwater systems, etc.) during the
final critical time period for implementation of the remedy. This four-year
time frame will also allow for an in-depth assessment of the characteristics of
the sludge to be generated by this facility and for input into sludge disposal
design decisions in advance of mandating operation of the treatment facility.
Commenter supportS the eM:. and stares that something should be done at the
Pit long before it is absolutely necessary. (1' 4)
See response to Comment 1-4, Section 3.1.
eM:. cannot be changed. (ESB 4-N)
The CWL can be changed if in the future the monitoring data shows that there
is threat to public health or the environment by allowing the water level in the
System rise to the 5,410-ft elevation.
Construction schedule should begin when the water level in the Berkeley Pit
reaches 5.260 ft. (ESB 8)
EPA and the State believe that this general idea of allowing plenty of time for
design, construction, and shake dow.1 of a treatment facility before the CWL
is reached is appropriate, although we do not believe that a specific elevation
should dictate the construction schedule. The ROD dictates a schedule (see
response to Comment 1-1, Section 3.1), that requires design and construction
to be completed in four years prior to the CWL being reached. This schedule
is to be updated every three years based on the highest water level at the
established East Camp monitoring points (presently the Anselmo Mine).
CWL should be set at 25-billion gallons and stick to it. (18)
EPA and the State believe that a numerical volume limit of 25 billion gallons
serves no purpose and has no technical justification.
The water level in the pit should be maimained at the bottom because:
.
Very large volumes of low-cost. clean. drinkable water can be made
available for the community of Butte-Silver Bow for both its present
and future needs:
-------
Response:
Comme1ll 1-10:
Response:
PART I - ~O:"oJ-TEC~lCAL CO:\t~tE~TS
.
lArge amounts of inexpensive electricity can be utilized by the
community or sold at a profit to Montana Power Company;
.
Storm water runojJ. as well as the sewage of the commun iry , can be
processed into a clean water supply that meets the Safe Drinking
Water Act requirements;
.
Metals that now pose a health risk in our aquifer can be processed at
a profit;
.
lArge amounts of garbage can be processed. thereby reducing dema.nd
on the current new landfill by as much as 50 percent,'
.
It will spawn a system to provide a vast array of high-tech, high-
paying jobs that will be sorely needed after EPA, MDHES, and ARCO
leave the communiry;
.
The process can be utilized in other areas of the world to benefit
mankind while practically eliminating the cover-up and Institutional
Controls that are some of the possible "remedies" of present and
future Superfund sites; and,
.
It eliminates need for degradation of Big Hole River water, as well as
Silver Lake water, that could instead be utilized for future needs of the
citizens of the State of Montana. (I 50)
Although some of the benefits espoused in this comment would occur Oarge
volumes of clean water, jobs, potential reduction of Big Hole and Silver Lake
water use), draining the Pit would also produce increased flows and metals
loadings to be treated and is a much more expensive option than allowing the
water to slowly approach the CWL. Given these increased flows, metals
loadings, and treatment costs, EP A and the State do not believe that draining
the Pit is the correct solution to the Pit System problem.
Did the EPA, MDHES, and the PRPs know beforehand rhat allowing the
Berkeley Pit to fill up to the 5,410 ft elevation with toxic water would result in
the bedrock aquifer being y,rinen off? If so, why wasn't it explained much
sooner to the people of Bune-Silver Bow and CTEC? (I 50)
Yes, EPA, MDHES, and the PRPs knew beforehand that the waiver of State
groundwater standards would be necessary for the bedrock aquifer. The fact
that cleanup of the bedrock aquifer was technically infeasible was stated in the
RIIFS Work Plan in 1990 and should be of no surprise to anyone following
the project, and we assumed no funher explanation was necessary. The
5,410-ft level is of no relevance to this issue. It is infeasible to repair the
bedrock aquifer regardless of the elevation the CWL. The water in the sbaft
system has shown improvement as the underground workings have become
progressively inundated, and EP A and the State believe that this improvement
-------
Comment 1-11:
Response:
Comment 1-12:
Response:
Co112l1lint 1-13:
Response:
Comment 1-14:
PART 1- ~O~-TECH.'\lCAL COMMENTS
will continue as the water level rises and more underground workings are
inundated. Therefore, maximum water quality benefits are achieved by
allowing the water level to rise as high as possible without threatening the
alluvial aquifer.
Stop calling it the "critical water level" and start calling it instead the "safe
water level." (T 10)
In retrospect, it would have been wise to call the "critical water level" the
"safe water level" because EPA and the State believe that the S,410-ft level is
safe and an adequate buffer zone exists above this elevation to provide an
additional margin of safety. We have identified this level, however, as the
CWL and we believe that it would not be productive to change the name at
this point in time.
As the cn.z is reached, how much of a margin of safety is left? (14)
The alluvial water level adjacent to the Pit is 50 ft higher than the CWL. We
also expect the highest level in the East Camp to be the Anselmo Mine, which
is presently 40 ft above the Pit level. The CWL will be measured at the
highest point in the East Camp which will not be the Pit. This provides an
additional margin of safety.
The observed water levels in some monitoring wells are very close to the CWL
of 5,410 feet mean sea level (jt msl). For example, the AMC-5 well has
measured an observed water level of 5,436.7 ft msl. 11uJr is only 26.7 ft
above the CWL. That is a small margin of safety. (14)
AMC-5 is well within the Pit cone of depression where the alluvial system
drains toward the Pit. The water level in the System has to get above the
alluvial groundwater divide (which is near Continental Drive) before discharge
to the alluvial system from the Pit can occur. This groundwater divide is at
least 50 ft above the CWL and provides a margin of safety of at least 50 ft. It
is technically inappropriate to make this conclusion about alluvial water levels
within this cone of depression. The water levels within the cone of depression
. are expected to be lower than the water level at the groundwater divide
because the alluvial water within the cone of depression is draining toward the
Pit.
There is no room for a carastrophic event or deepening of the warer level in
thp alluvial aquier. The rationale for acceptance of the CWL of 5,410 ft msl
was that model prediCted little or no impaCt when the warer in Berkeley Pit
reached the CWL. Given the small margin of safety that leaves along with
current aquifer levels and the lack of dara to establish the maximum lowest
alluvial aquifer warer level, 1 believe the CWL of 5,410 ft msl is too high.
(14)
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PART I - :\O:'li-TECID1CAL CO~f:\IE:\"S
Response:
EP A and the State bel ieve that there is an adequate safety margin as expressed
in the proceeding responses to comments. We also believe that there is not a
lack of data concerning the lowest alluvial levels. The water levels and
groundwater gradients in the alluvial system were thoroughly defined utilizing
dozens of wells showing water throughout the area.
3.2
VSE OF OTHER TECI£\"OWGIES FOR TREA T~fE:\'T
Comment 2-1:
.Why is this Record of Decision not'defective if the authors did not sun'ey the
same Idnds of available technologies and offer the 0pDortunit',' 10 demonstrate
what reall',' can be achieved? We see that the study was a paper thinking,
reading, speculating, and skewing the process to reach a preordained
solution. . (I 12)
Response:
The Preferred Alternative was not preordained. The FS process cannot take
all potential technologies through bench-scale or pilot-scale demonstration in
the time frame allocated for making this decision. This FS is not envisioned
to be research and development which offers an opportunity to demonstrate
technology. However, EPA and the State are completely open to the
implementation of other technologies brought forward collectively by the
developers of such technologies and the PRPs, if they meet the project's
performance criteria (discharge standards and flow rates). In response to
public comment such as this one, the ROD dictates that a reevaluation of
technologies must occur when the water level in the Pit reaches 5,260-ft level
(presently projected to occur in 2009 or when mining is suspended, whichever
is earlier). We are hopeful that additional technologies will be demonstrated
by that time.
There are also other avenues for the testing of various technologies
specifically for the Berkeley Pit. The U.S. Department of Energy (DOE)
Resource Recovery Project, presently being run in Bune through MSE is such
an avenue. The results of this project will be helpful to EPA, the State, and
the PRPs in the reevaluation process and in the decisions associated with the
implementation of new and innovative technology. EP A Region 8 and the
State are also commined to pursue addtional Federal funding for development
~::~ ~ ~=~ :-..:;::::::c:-. vf inno\ ...; ~'e treaunent/metals recovery technologies.
Comment 2-2:
"Nobody asserts that reverse osmosis technolog)' is an appropriare technology
for the level of contamination of the Berkeley Pit water as the first stage of an
overall treatment solution; however, it might well have a role to play in the
final step of a process that solves the problem. " (I 12)
Response:
EPA and the Su:.: :..;ree with this statement. Reverse osmosis (RO) was
never envisioned to be a primary treatment process for the Pit waters, but
rather a polishing step for sulfate removal and achieving very low metals
discharge standards.
-------
Comment 2-3:
Response:
Comment 2-4:
Response:
Comment 2-5:
Response:
Comment 2-6:
Response:
PART I - NON-TECHNICAL COMMENTS
The technology suggested is very old. The commeNer quoted a paper written
by William Oark dated 1902 and a paper by the Anaconda Company dated
1941. (1' 7)
The technology chosen in the FS is an old technology (hydroxide precipitation
and aeration), but the application is quite sophisticated when utilized to reach
very low metals concentrations such as those dictated by State water quality
standards for Silver Bow Creek. It is the most common technology used for
the wastewater containing metals and acid mine drainage. It is employed in
many similar instances at mines throughout the country, including the Yak
Tunnel, Leadville Tunnel, and the Iron Mountain Mine.
Surely there are less antiqualed processes available in 1994 than those in the
curreN plan. Can new technologies like OIelanon ChromQlography be used
now to begin the cleanup. (138)
There are newer technologies available; however, EPA and the State believe
that the proposed technology is the most cost-effective, proven technology
available which will meet the project's performance standards. EPA and the
State are open to the implementation of alternate technology if brought
forward collectively by the PRPs (who will ultimately pay for the costs of the
project and be responsible for meeting discharge standards) and the developers
of the innovative technology. EP A and the State believe that it is important to
evaluate technologies in the future as they become more proven. The ROD,
in response to comments such as this one, requires a reevaluation of
technologies when the water level in the Pit reaches the 5,260-ft level
(presently projected to be reached in the year 2009).
The wrong technology has been chosen and the wrong solution has been
chosen both by the EPA and ARCO. (1' 7)
EP A and the State disagree with this statement. See the previous response.
.It seems to me that the technology that is available now is much better as it
not only leaves no sludge bur utilizes everything and also reduces cost. I
don't understand how the people of Butte can see this way and ARCO and
EPA cannot.. (140)
EP A and the State disagree with the statement that alternate teclmologies
reduce costs. Many of these alternate technologies also generate significant
amounts of byproducts that, if they cannot be marketed, must be disposed of
as a sludge. We are hopeful that some of these technologies wiJ) be shown to
be cost-effective in the future. As was previously stated. EPA and the State
are open to the implementation of alternative technology if proposed
collectively by the PRPs. The ROD dictates that reevaluation of treaanent
technology must occur when the water reaches the 5.260-ft level or if mining
. is suspended, whichever occurs earlier.
-------
Comment 2-7:
Response:
Commenl 2-8:
Response:
Commenl 2-9:
Response:
PART 1- ~O~-TECl£\lCAL CO~f~fENTS
I therefore ask that the proposed plan be rejected at this time because it has
not considered adequately this new technology (Chelation Chromatography).
This technology is capable of treating water to nondetectable levels of copper,
manganese, zinc, and arsenic. It is quite likely thai the proposed plan has not
appropriately or adequately considered other technologies which would work
in conjunction with any modern process that would treat this water. (I 6)
EPA and the State will not reject the Proposed Plan on this basis. We believe
that the FS did adequately consider numerous technologies, which for various
reasons outlined in the FS were rejected.
"The City of Bune should buy the water from Silver Lake, then pay for it by
mining the copper and lead out of the wastes. The Concentrator could use the
water out of the dam behiTlli the Pit, after cleaning it. This is the water
leaking into the Pit now. Then put up a few Hydroelectric Pumps to make
electricity to sell to the Montana Power. " (l 46)
The City of Butte is not a PRP for this project and has no responsibility for
the cleanup of the Pit. EPA and the State encourage commercial ventures that
would aid in this project. These commercial ventures should be financially
viable on their own and not depend on Superfund funding or authority to be
financially viable.
"An innovative alternative approach would be to allow ARCO to delay
construction for some agreed upon time (e.g., 10 years) and invest the savings
of this delay in a research and development fund that would pay for research
into alternative technologies to treat the pit water. " (l3)
The EPAIState plan requires construction to treat inflows into the Pit in the
near future. We believe that the most cost-effective way to handle this flow is
to integrate it into the mining process, and this will likely require some
~nnstruction. Construction of a treatment plant is not required to be
completed until four years before the CWL is approached or after mining is
suspended. This should not occur for nearly 30 years if inflows are controlled
in the interim. During this time period, there is considerable time for
research and development. There are a considerable number of technology
demonstration projects planned by the DOE Resource Recovery Project. The
ROD also requires a reevaluation of technology when the Pit reaches the
5,260-ft level.
3.3
METALS RECOVERY
Comment 3-1;'
Response:
"People think thai metals recovery should be considered as an offset to the
cost of good cleanup. " (I 9)
EPA and the State would also prefer the metals to be recovered, but only if it
can be done in a cost-effective manner. We believe that the value of the
metals recovered would not cover the capital costs and operation and
-------
Comment 3-2:
Response:
Comment 3-3:
Response:
Comment 3-4:
Response:
Comment 3-5:
Response:
PART I - NON-TECHNICAL COMMENTS
maintenance costS of a conventional metals recovery facility and would not
reduce treatment costS significantly.
"The purpose of hydroxide precipitation is to tie up the heavy metals and
metalloids (arsenic) in insoluble foms to prevent the spread of contamination
in surface and groundwaJer. Once the sludge is produced. the metals are
essentially unrecoverable slwu/d future metals recovery technology become
feasible. Thus. the hydroxide precipitation option precludes the future
recovery of a mass of metals that represents a significant economic resource. "
(BSB 2)
This statement is correct, but EP A and the State believe that the hydroxide
precipitation and aeration option is the most technically effective, cost-
effective, and proven treatment method currently available. The fact that the
metals will not be easily recovered in the future is not a criterion used in our
evaluation of treatment alternatives.
"The selecred technology is at odds with metals recovery. Again. what we see
herds the heavy metals being turned into a sludge which does not solve the
problem. it just relocates the problem to a new location. The hydroxide
precipitation technology has been described very eloquently as an old
technology norwithstanding any claims for newness that have been made. "
rr 12)
This technology is an old technology which will be applied" in an innovative
treatment train. EP A and the State disagree with the assenion that this
process "just relocates the problem." This treatment method effectively ties
up metals (to the point that they are hard to recover) preventing them from
leaching into the groundwater. Any repository will be built to State of
Montana solid waste disposal site standards to ensure that the problem is not
"relocated. "
"Our philosophy is to recycle the metals. " (BSB 4)
EPA and the State would also prefer recycling of metals, but only if it can be
done in a cost-effective manner as compared to conventional wastewater
treatment methods.
"Why was only one treatment technology for metals recovery (copper
cementation) evaluated during the final screening? Other newer technologies
(e.g., those ofMetannetiJ: and Tetra Tech) have been teSted in aCtUal cleanups
with some success. Metals recovery from Pit water has a great potenriDI to
turn a current liability into a long-tem economic asset. 7his section should
have been one of the most extensive in the FS. InStead, metals recovery
technology received a perfuncrory examination. " (BSB 3)
These technologies were evaluated in the screening portion of the FS and were
eliminated for specific reasons stated in that document. Metals recovery.
-------
PART I - ~ON-TECmlCAL COMMENTS
although a benefit, by itself is not a primary criteria evaluated for decision
making. The primary criteria used in the screening repon were treatment
effectiveness, costs, and implementability. The ROD does require that there
be a reevaluation of treatment technology when the Pit reaches the 5,260-ft
level. EPA and the State are also hopeful that the developers of such
technology and the PRPs collectively propose metals recovery technologies or
other innovative treatment technologies that can be implemented for this
project before a final treatment plant has to be constructed.
3.4
~10RE J\fOl\TIORING WELLS-E~1IANCED MO~lTORING PROGRAM
Commenr 4-1:
The number of monitoring wells does not seem adequate. (II, J 3, BSB 4-H,
I 53, J 54)
Response:
With the addition of two bedrock monitoring wells and one alluvial well for
the East Camp and four monitoring wells for the West Camp, EPA and the
State feel that there is adequate coverage of the MFOU. However, if future
information should indicate a need for additional monitoring wells in the
~1FOU, hien EP A and the State will have the ability and authority to install
these monitoring wells. The current monitoring wells (with the new additions)
and future flexibility to require additional wells assure the Agencies and the
public that groundwater monitoring wiJl be adequate.
Comment 4-2:
"A well is useless ifit is improperly placed. Based on the complexfauIting
andfraauring of the area, more wells are necessary to get a complete
understanding of the hydrology. " (I 1)
Response:
EPA and the State believe that additi')nal wells are required in both the East
and West Camp and have required the installation of these wells (see comment
4-1, Section 3.4). After installation of these wells are completed, we believe
that the post-ROD monitoring program provides adequate coverage with 9
Rl/FS bedrock monitoring wells (7 existing and 2 new), 8 mine shafts. 15
"existinglhistoric" wells completed in bedrock, and the Berkeley Pit (37 total
- 33 bedrock monitoring locations as of this date. with 4 additional
monitoring wells in the bedrock of the West Camprrravona System required
as part of the ROD), plus over ten years of data for many of these locations
and additional monthly water-level data being added to the database. As water
flows downhill and given the 3000 miles of interconnected mine workings in
the MFOU that cut through and into the "complex faulting and fracturing of
the area," EPA and the State do not believe this "complex faulting and
fracturing of the area" is a confounding issue to the over,all hydrology of the
operable unit. EP A and MDHES are convinced that groundwater flow within
the East Camp is towards the Berkeley Pit.
Commenr 4-3.'
"Monitoring wells shouId have been parr of the remedial investigation, not
specified as parr of the remedy.. (1'9)
-------
Response:
Comment 4-4:
Response:
Comment 4-5:
Response:
PART] - NON-TECHNICAL COMMENTS
Numerous monitoring wells (7 bedrock monitoring wells, 16 alluvial
monitoring wells, 6 piezometers and 43 private wells) were part of the
remedial investigation. Six "new" bedrock monitoring wells and one alluvial
well are being installed or will be required as part of the ROD. These
additional wells were not needed in the RI to make the remedial decision, but
were needed to monitor the future rising water levels. It is possible that
additional monitoring wells will be required in the future; however, current
data does not support more wells. The ROD will incorporate language that
allows the Agencies to require the ipstallation of additional wells if the data .
support such a finding.
The remedy would address contamination after the fact, it is not preventive.
(1' 9)
We believe that the remedy is preventative. It requires significant inflow
control and requires that contamination never be allowed to enter the alluvial
aquifer. The MFOU is an issue of preventing acid mine drainage (AMD)
from entering the Summit Valley aquifer and contaminating that aquifer. We
cannot prevent the generation of contaminants in this care. By allowing the
Pit System to rise as high as possible without discharge, the rate of acid mine
drainage generation can be reduced.
The County acknowledges that the Monitoring Program outlined in Appendix 1
of the RI is reasonable. However. to provide the highest level of assurance to
the County and its citizens, the County would recommend that additional
monitoring be included in the plan, as follows:
.
1Wo new monitoring wells should be drilled in the region southeast of
the Berkeley Pit; the objective of these wells would be to extend the
bedrock aquifer contours through the linear path of the Berkeley Pit
and Well C. These wells would provide funher verification that mine
flooding problems are not migrating south and east.
.
A monitoring point should be located adjacent to the East Continental
Pit to monitor that Pit's influence on the bedrock aquifer. (BSB 2,
T 8. G 2, 1 54)
EP A and the State agree with the general intent of the comment. As noted
previously, two additional bedrock monitoring wells are being .installed in the
area discussed by the County. These wells should be completed before the
end of 1994. One of these wells is located between the Berkeley Pit and Well
ClEast Continental Pit area. Further, this well should be in the area of the
lowest point for weathered bedrock. The second well will be located south of
Well ClEast Continental Pit area and east of Walnut Street/Continental Drive.
-------
Comment 4-6:
Response:
Comment 4-7:
Response:
Comme1J1 4-8:
Response:
Comment 4-9:
Response:
PART 1- J'liON-TECH:\1CAL COMME!\'T~
"The Counry would request tluJt these monitoring points should be installed
during th£ summer field season of 1994. Funher, the Counry would pledge to
work closely with the EPA and PRPs to locate these monitoring points to
acquire the most useful data. " (BSB 2) .
The wells should be completed before the end of 1994. The County was .
allowed the opportunity to work with EPA and the State and did contribute on
the siting of these wells.
In the ROD, EPA must commit itself and th£ PRPs to developing a
compreh£nsive program to educate local citizens on the flooding of the
Berkeley Pit and any potential contamination problems. Infonnation must be
widely disseminated on a regular basis and in terms thai are clearly
understood by the average citizen. BUlle-Silver Bow stands ready and willing
to assist in developing a such an education program. (BSB 2, BSB 4-K)
The monitoring program will call for yearly updates to be given to the public
through MDHES and the Montana Bureau of Mines and Geology (MBMG).
This update will include information on water levels, water quality, Berkeley
Pit flooding rate, and future date projections of reaching the CWL. Butte-
Silver Bow is welcome to work with the State through MDHES and MBMG
on the yearly updates.
"One ofth£ positive aspects of the RIfFS is th£ requireme1J1 of additional
wells. " (BSB 7)
EPA and the State acknowledge the comment. We also think the flexibility of
requiring additional monitoring wells in the future, as new data may indicate,
is also a very imponant aspect.
Further research needs to take place to establish a more adequare margin of
safery. All Final Alternatives contain groundwater monitoring provisions that
begin immediately. Continued monitoring of alluvial water levels over many
more )'ears will increase the confidence of the predictions of the maximum
deepest alluvial aquifer level. As the confidence of the predictions of the
alluvial aquifer water level increases, periodic readjustme1J1s of the eM.
sMwdbemade. a4,15~
EP A and the State believe current information, as found in the RI, does
establish an "adequate" margin of safety. Tbe ROD establishes
comprehensive guidelines pinpointing when future actions are to take place
prior to the water levels reaching the CWL for the East CamplBerkeley Pit
System and West Camprrravona System. Further, there is no less than a SO-
ft water level elevation difference between the East CamplBerkeley Pit System
CWL and the alluvial aquifer in the region. Also, the monitOring program (as
recognized in the comment) will gather data to confirm the accuracy of the
CWL(s). Finally, if new data collected during the monitoring program
demonstrates that the CWLs are not protective, the Agencies bave the
-------
Comment 4-10:
Response:
Comment 4-11:
Response:
Comment 4-12:
Response:
3.5
PART 1- t\ON-TECHNICAL COMME!\'TS
authority to react and take whatever action is necessary, including lowering
the CWLs.
.Our judgement is that there will never be enough wells to satisfy everyone's
curiosity. Since the wells cost $80,000 each, good common sense should also
tell us all that at some point no new wells need to be drilled for curiosity
sake. - (BSB 8)
EP A and the State agree with the comment. However, we wiJI require
installation of wells if any new data indicates a need for additional wells, EP A
and the State will have the flexibility and authority to direct their installation.
-The Proposed Prefe"ed Alternative has suggested $100,000 be spent on
monitoring and public education. Our judgement is that this a. 'Wunt should
be more than enough to cover monitoring and public education. We do not
believe this money should be spent to hire 'Activists' who have tlreir own
agenda to pursue. - (BSB 8)
The dollar figure given in the Proposed Plan for Post-RIfFS monitoring is an
estimation. The figure did not include monies for educational effons. Also,
the first years (about two) of the monitoring program will cost more than
subsequent years. Finally, EPA and the State encourage the PRPs to work
with the State (i.e., MBMG through MDHES) to conduct the monitoring
program; however, the Agencies cannot force the PRPs to use the State.
-One suggestion that 1 would like to put forward is about funding of tire
comprehensive monitoring program. 1 think that advantage should be taken of
sources otlrer than EPA and ARCO. There are funding programs available
through tire National Science Foundation, and otlrers internationally, wlrere
large grants are given for environmental projeCts. - The commenter also
suggests EPA coordinate a grants application scheme with local institutions
and others. (1 53)
The MFOU is an enforcement action against designated PRPs, notably ARCO
and MR. PRPs are financially responsible for the minimum requirements of .
the monitoring program as outlined in the RI. Additional monies for basic
research projects cannot be forced on the PRPs. EP A and MDHES encourage
the academic community to pursue additional external monies to conduct
original research on acid mine drainage and related topics using the Berkeley
Pit as a -test bed. - EPA and the State wiJI encourage the PRPs to facilitate
these research effons.
TAKF. ACTION NOW
Comment 5-1:
",
Future generations are going to be saddled with maintaining a pumping and
treatment facility in perpetuity under any plan. The least we can do is get tire
remedy in place now, not shove thal off to them as well. rr 9, T 11, BSB 12-
C, 121, 12, 13, 132, 129, G 1)
-------
Response:
Comment 5-2:
Response:
Comment 5-3:
Response:
Comment 5-4:
PART I - ~O~-TECH1\1CAL COM~IENTS
EPA and the State believe that much of remedy will be implemented in the
near future. The PRPs will be required to control 40 percen~ of the flow that
has, since 1982, gone to the Pit. They can do this through integration of this
flow into the mining process or construction of treatment plant.
Please get a pumping plant for the Pit now and t~ aCtions to get new
technologies thilI don '1 produce so much sludge. Please get them into
operation within the next few years. (G 1, I 30. 117, 1 14. I 3)
See response to Comment 5-1, Section 3.5. Although the technology chosen
produces significant amounts of sludge, the volume generated daily is only
about one to two percent of the amount of tailings generated daily by the
current mining operation. There is considerable acreage in the active mining
area where sludge disposal can occur with no threat to human health or the
environment. The ROD requires a reevaluation of technologies when the
water level in the Pit reaches the 5,260-ft level. Some of these technologies
may generate less sludge than the hydroxide precipitation treatment method
called for in the ROD. EPA and the State are also committed to seeking
additional Federal funding for development and demonstration of innovative
technologies in this area.
The £PA must begin the process of physically addressing the problem of 27-
billion gallons of toxic water now. rather than putting it offfor 20 or 30
years. (BSB 15, /45. /44, /47, /4/, /40, /38, /36, /48, /34, /23, /27,
/26, /25. I 18, 120, / 16, / 14, / 12, / 10, /9, BSB 4-£, BSB 6, 13, T 3,
/1)
The Agencies' near term goal is to reduce inflow into the Pit. We believe
that inflow can approach the CWL (allowing in excess of SO-billion gallons to
accumulate) before any risles are posed to health and the environment.
Caution in this case means beginning today to formulate a plan of aCtion
based on the best available technology, thilI being the technology thal works
best. The commenter also suggests the following:
.
Begin immediately and takJ! tWO or three years to solicit technical
sc!utions to cleaning up the water,'
.
Within three years, using market forces, have someone screen the
proposals and choose tWO or three to put into a pilot program;
.
Testfor three years,' .
.
Fifth or sixth year, begin pumping plant with the best available
technology and work out bugs in the system,' and,
.
Seventh or eighth year, projeCt established. (BSB 15,.112, 13, /36)
-------
Response:
Comment 5-5:
Response:
Comment 5-6:
Response:
Comment 5-7:
Response:
Comment 5-8:
Response:
PART I - NON-TECHNICAL COMMENTS
EPA and the State agree with many aspects of the proposal. We believe that
we are implementing the most cost-effective proven technology; and we are
going to solicit other technical solutions as the project advances. We do not
believe that it is necessary, however, to have a treatment facility, other than
one to control surface inflows, to be on line in seven to eight years. We
believe that, as long as the water level is kept below the CWL throughout the
East Camp, no risk is posed and final construction completion of a treatment
facility to treat Pit water should be tied to the CWL.
"Please consider a treatm£nt plant now, or alternatively, some of the mineral
extrarnon possibilities mentioned by various companies in recent newspaper
articles. " (1 39)
See response to Comment 5-4, Section 3.5,
This valuable resource could be available to the communit)' for industry and
other purposes. The sooner these efforts are set into motion, the earlier clean
water could be available to this area. (1 9, G 1)
EP A and the State agree that the water in the Pit is a potentially valuable
resource; however, the goal of the Superfund remedial process is not to make
the resource (water) available to the area sooner but to protect human health
and the environment. We believe the plan outlined in the ROD does meet this.
remedial goal.
Please stop arguing about this issue and start reassuring the general
population and start fixing this problem. At least begin by slowing the rise of
water. Arnon is needed. " (1 7)
EPA and the State suppon "stopping the arguing." The first step in fixing the
problem is controlling the inflow and the plan outlined in the ROD
accomplishes this task.
"There is a conflict of interest because we want something done now and at
the s~ time we want to see some innovative technology used. Ifwe do
something now, the technology that will be used will create sludge. " (BSB 4-
N)
There is a conflict here, but EP A and the State believe that it is imponant that
inflows to the Pit are halted in the near future and that the PRPs have a clear
path to follow, enforced through federal coun, regarding the Pit problem.
This path includes a hydroxide precipitation treatment plant, a process that
creates significant amounts of sludge where the precipitated metals are hard to
recover. We believe, however, that this technology is the most proven, cost-
effective treatment presently available. EP A and the State are open to other
more innovative and newer technologies if proposed collectively by the PRPs
and the developers of such technology. We are also calling for a reevaluation
of technologies when the Pit reaches the 5,260-ft level.
-------
PART I - ~ON-TECHJ\lCAL COMMENTS
Commem 5-9:
Reduce the amount of water in the Pit now and clean it up now. (BSB 4-J,
BSB 6. T9)
Response:
EPA and the State do not believe that reducing the amount of water in the Pit
is the correct alternative from the technical or cost perspectives. Although
reducing the amount of water in the Pit would reduce the volume of
contaminated water in storage, the amount needing treatment on a daily basis
is more if the East Camp level is lowered. The groundwater gradient
increases resulting in an increase in flow toward the Pit. The loading of
metals to be removed on a daily basis is also increased if the East Camp water
level is lowered because of the increase in acid production and acid mine
drainage that would occur. Inundating the shafts decreases oxygen
circulation, acid production, and metals loading.
Commem 5-10: ~
-Residents of Butte and the Silver Bow Creek drainage have been frustraIed by
the lack of progress b)' the EPA in developing a plan that will adequatel)' treat
the contaminated water and protect the environment and citizens of the area
from the potential threat to the alluvial aquifer surrounding Bune. - (BSB 7)
Response:
We acknowledge the frustration, however, the Superfund law dictates that
EPA and the State follow certain steps, including public panicipation, before a
decision is made. The RIfFS took about three years to complete as was
projected in 1990. This is a relatively short period of time to move through
the Superfund process for a project of this magnitude and develop a plan for
addressing this problem.
Comment 5-11:
''It is time to holler (and loud) to EPA about the Pit cleanup! 1 think there are
still too many question marks left as it stands now. " (1 22)
Response:
The public comment period allows anyone to voice their cor.~:;:ms and
questions. This responsiveness summary is in response to these questions and
concerns.
3.6
COMME"7S RELATED DIRECTLY TO THE PROPOSED PLAN
DISAGREE WITH EPA PROPOSED PLAN
A.
Commem 6..1-1:
Marry commenters disagreed with EPA's Preferred Alternative for the cleanup
of the Berkeley Pit. (110,133,112, T 9, PI, 140, 138, 139,132, 119, /
28,124, /21,115,113, 111)
Response:
We conducted a detailed and thorough MFOU RIIFS to determine the most
"i-'tI' uti! i..... . ~ponse al.:tiun lOr this operable unit given the data and the
applicable technology currently :!v~ih"lp. we believe that the Preferred
Alternative, with modifications based on public comment, is the best response
action alternative for this operable unit.
RS3-16
-------
Comment 6A-2:
Response:
Commem 6A-3:
Response:
Commem 6A-4:
Response:
Commem6A-5:
Response:
Commem6A-6:
PART I - NON-TECJL1\1CAL COMME~7S
The plan to let the Pit fill for 28 years is shorr-sigh/ed. It doesn't take into
account the effect that this has on Butte. (14,112, I 15.113)
We believe that allowing the Pit to approach the CWL will not threaten
human health and the environment. This action does not take into account
socio-economic effect to Butte and we do not have the authority under
Superfund to take such effects into account.
The plan doesn't seem to care about shorr-term adversities, such as doubling
contamination. and it doesn't leave room for emerraining holistic approaches
to Pit cleanup, approaches that could provide many benefits to the community.
rr 9, P 1) .
We acknowledge that the remedy outlined in the ROD allows for the Pit water
level to rise and that this would correspond to an increase in the volume of
contaminated water; however, the daily flow and metals loading generated will
be reduced if the Pit is allowed to approach the CWL. We do not believe that
this will increase the .risks to human health or the environment since the CWL
will never be reached. As stated previously, the remedy can accommodate
new recovery and/or treatment technologies if and when they become
available. .
People say thai the plan would creale new comamination and a nuisance thai
would decrease their quality of life in substantial ways-including
environmemally, economically, socially-and thai it creales new threals to
human health, including memal health. (P 1, I 39)
. We acknowledge that the remedy allows for an increase in the volume of
contaminated water; however, this will not increase the risks to human health
or the environment because discharge to the alluvial aquifer on Silver Bow
Creek will not be aJlowed. The Preferred Alternative allows for new
technologies to be implemented should the developer of such technology and
the PRPs wish to do so. In this way, the Preferred Alternative aJlows the Pit
water to be of economic benefit to the community.
-I disagree with the preferred alternative. It is my understanding, this has
been tried al Jefferson City and it did not work because of extreme
temperature changes T>'Pical in Momana. Was a trealability study done thai
supports this alternative? lfnot is one planned?- (137)
Hydroxide precipitation works well in a wide range of climates and we
anticipate no problems using this technology in Butte. It is presently being
used successfully in Leadville, Colorado, which has a climate similar to that
in Butte. .
-I do not believe thai the EPA-ARCO plan for cleaning up the Berkeley Pit is
adeqUlJle to meet the requiremems of Supeifund law. - (1 35)
-------
Response:
PART I - ~ON-TEC~CAL CO~fMENTS
In selecting the Preferred Alternative, we have met all legal requirements for
the Superfund (CERCLA as amended by SARA) program. This includes the
regulations set forth under the National Contingency Plan (NCP).
B.
AGREE WITH EPA PROPOSED PLAN
Comment 6B-1:
Response:
Comment 6B-2:
Response:
Comment 6B-3:
Response:
CommeTU 6B-4:
Response:
Comment 6B-5:
Response:
"The local gOWf17ll1lenJ has gone on record. with a lot of reservation and
concern abour the preferred alternative. but also in support of some
modifications to tM preferred alternative that the local government might find
more acceptabl~ as the)' relate to the preferred alternatives as it addresses the
problem wilh the Berkeley Pit. It is the first time local government has gone
to the exleTU of conduCting their own public hearings to receive input to
forward to the EPA. and the first time local government has formally gone on
record and has drafted a resolution that sets forth their comments relative to
the preferred alteT7lll1ive. " (['8)
We a;:knowledge this comment.
One commeTUer feels that the proposal is a viable solution. This person is
frighIened by the decision that is being made and supports it, with some
reservations, because it is the best offer now. (BSB 12-1, BSB 4-N)
We acknowledge this comment and believe that this is the best and most
flexible alternative at the current time.
"I agree wilh Jour findings, there is no quick solution." (/49)
We acknowledge this comment.
"Regarding EPA's Proposed Plan, I lean towards Alternative 6/7 with
resen'OJions. Some aspeCts of tM pumping and cleaning the water should be
doTU! as soon as possible." (/ 31)
Although contaminated Berkeley Pit System water will not be pumped and
treated during the initial stage of this response action, surface water flowing
into the Pit at Horseshoe Bend will be captured and pumped to the Yankee
Doodle Tailings Pond.
A number of speakers saw no scientific or technical basis to challenge the
plan. Lacking such basis, they saw no reason not to allow it to go forward.
(G 1)
We acknowledge these comments.
-------
Comment 6B-6:
Response:
Comment 6B-7: .:
Response:
3.7
gm:
Comment 7-1:
Response:
Comment 7-2:
Response:
PART 1- NON-TEC~1CAL COMMENTS
One commenter is proposing that the community scope be whar is best for the
community and feels that because of the Superfund Act. this whole issue has
been forced. His concern is that EPA has come up with technical information.
~We need to put our efforts toward the best result thar is available to us. ~
(ESB 4-N)
We believe that, overall, the preferred primary treatment technology is
currently the best process for removing the bulk of the metals from Pit System
water. In order to consider innovative technologies that may be developed in
the near future, the response action includes a re-evaluation of available
technologies when the water elevation reaches S,260-ft level. Based on that
evaluation, a different technology may be implemented that would generate
less sludge than lime precipitation.
1h£ commenters generally accept Prefe"ed Alternative 6/7 as presented in the
Plan. However, they believe that in one critical respect the Plan fails to
provide for the necessary flexibiliry inherent in the long-term 1UlIUre of this
Plan. They believe that with a modification of this and other more minor
points, Alternative 6/7 will ensure thar the overall goals of the Berkeley Pit
remediation process will be met. ARCO and a variety of other parties, EPA,
MDHES, BOM. and MRJ are in agreement with the study. (PRP 1, T 4, BSB
4-K)
We acknowledge this comment and bave tried to provide flexibility concerning
treatment technology, points for withdrawing contaminated waters, and fmal
water uses.
"1h£ Proposed Plan will save ARCO a bundle. Butte miners say the stainless
steel pumps al the Kelley cost $60 million about 20 years ago. Cost of this
'eternal cleanup' would be less: $42-53 million. " (G 2)
EPA and the State question the validity of the $60,000,000 figure. Costs
developed by the Agencies to install pump(s) and piping in the Kelley Shaft is
approximately $16,000,000, in 1994 dollars. Following installation, the cost
of remedy is considerably more than the costs of the pumps in the Kelley.
Regardless, we believe the costs of pumps are irrelevant as compared to the
cost of the remedy.
Please do not choose a remedy thar appears to give the grealen weight to cost
or to threals of litigation from PRPs. (P 1, BSB 7)
The two threshold criteria used to make this decision are: (1) overall
protection of human health and the environment, and (2) overall compliance
with regulations and standards. EP A and the State believe that several of the
alternatives proposed in the FS equally meet these basic criteria. To
determine which alternative is preferred, the balancing criteria are employed.
RS3-19
-------
Commenr 7-3:
Response:
Comment 7-4:
Response:
Comment 7-5:
Response:
Comment 7-6:
Response:
PART I - NON-TECHNICAL COMMENTS
Cost is one of these criteria and plays a major role when the costs of one'
alternative is inordinately more expensive. Threats of litigation play no role
in the decision, but the Agencies must be cognizant of the fact that the
decision must be based on an objective weighing of these criteria and not be
arbitrary and capricious.
The cost factor needs careful consideration. There are tWo ways of
calculating cost: (1) What is the cheapest plan of action or (2) Mat are the
goals we are trying to achieve and, after the goals have been established,
whal is the most cost-effective way of achieving these goals. In devising a
remedy for the Pit we must not select the cheapest solution but the solution
which will maximize the protecrion of human health and the environment. We
must select a cleanup solution. (1 51)
EP A and the State agree with this statement and the FS did just as the
commenterstated in Comment 7-2. No alternatives were considered that did
not protect human health and the environment, meet state and federal
requirements, and have long-term effectiveness and permanence to the highest
degree possible.
.The community must itself put up a financial conrribution to the clean-up
perhaps 1 to 10% of the cost. This is only fair since the community bene fined
as well as suffered. . (1 49)
Butte-Silver Bow is not a PRP for this operable unit and bears no
responsibility to share in the financing of the remedy.
.Costs need to be broken down when they are so high and include contingency
costs. . (1 37)
The costs in the FS do include contingency costs, as well as maintenance costs
and a safety factor, to cover unanticipated costs that vary according to market
prices' (chemical costs).
The proposal appears to be written more in the interestS of ARCO than in the
interests of the citizens. It even allows ARCO to escape the necessiry of
having to create a trust fund now so thai we are assured thai we are not left
holding the bag. We simply cannot trust ARCO to treat thai Water in
perpetuiry. EPA must think thai the people in BUtte have no memory of all the
corporate flight thai took place during the past 15 years. (113, I 5, T 9)
All parties need to realize that there are several PRPs, including Montana
Resources (MR), ASARCO, Dennis Washington, ARCO, and several smaller
companies which are held responsible for the MFOU. The Superfund
regulations and guidance contain several methods for PRPs to provide
fiDaDcial assurances. However. based on comments such as these from the
. public and Butte-Silver Bow and the long time frame needed to implement the
remedy, EP A and the State believe that bonding (or a similar financial
-------
Comment 7-7:
Response:
Comment 7-8:
Response:
Comment 7-9:
Response:
Comment 7-10:
Response:
Comment 7-11:
Response:
PART I - NON-TECHNICAL COMMENTS
instrument) is appropriate. EPA is, therefore, presently evaluating the
potential for requiring bonding.
The preferred remedy must state clearly and completely exactly how these
costs will be covered. including the possibiliry that ARCO declares bankruptcy
at some time in the future. The preferred alternative must also include the
cost of reconstructing or renovating the water treatment system in perpetuiry,
as well as allowing for the cost of installing new technologies should they
become available. (l 5, //6)
See response to Comment 7-6, Section 3.7. The cost in the FS includes the
routine maintenance and replacement cost of the treatment system. The
fmancial assurance assessment will also include this cost in perpetuity. We
cannot, under Superfund, demand that inclusion of the cost for installing new
technology be included in this assurance.
-Because any remedy for this OU will require treatment in eternity, why are
the funds to do so not provided up front in a trust fund adminiStered by EPA
or another governmental agency instead of allowing ARCO to self insure that
they will do the perpetual care, operation and maintenance?- (G 2)
See response to Comment 7-6, Section 3.7.
-7Wo bonds should be established immediately to pay for the coSt of the
remedial effons. The first should cover the initial building cOSts and prediCted
operating and maintenance costs. The second bond should be a special fund '
for upgrading the physical plant in thejuture. - (14) .
EP A and the State are evaluating the potential for requiring bonding of long-
term capital expenditures and long-term operation and maintenance costs.
-A mechanism should be set up to decide which new treatments should be
implemented and which are not worthy. / recommend setting up the bonds
now to hedge off future uncertainties such as interest rate fluCtUJJtions,
changes in the cost of the projeCt and responsible parties folding. - (14)
See response to Comment 7-6, Section 3.7.
-Presently, all the alternatives fail to address what will happen after 30 years.
Who will pay for the treOrment after 30 years to eternity? . What is the life
expeCtancy of the treatment system in Alternative 617? / believe any
allernative that can't effectively address these questions, can't be trusted to be
cost-effective in the future. - (14)
The typical replacement period for equipment and structures for such a
treatment facility is 20 years (five percent per year) and the replacement costs
were calculated into the annual operation and maintenance costs in the FS.
The costs in the FS for the various alternatives were calculated for 30 years
-------
Commenr 7-12:
Response:
Commenr 7-13:
PART 1-l'iON-TECIL'' CAL COMMENTS
(per Superfund guidance) so that the cost of the various alternatives could be
compared. The bonding provisions for implementing the remedy will take
into account the cost of ruMing and maintaining the plant in perpetuity.
Presently, responsible parties exist to pay for remediation, yet even the most
expensive alternative (19) does Unle more than any of the other alternatives to
keep from pushing this problem onto future generations. All the proposed 19
alternatives are stop-gap measures, )'et this is not how they presenr themselves
in the report. In facr, Alternative 6/7 was picked for its higher long-term
effectiveness over the cheaper Alternative 4/5 (Feasibiliry Study, 1994). The
higher long-term effectiveness is that the Pit water level will stabilize at a
lower level than Alternative 4/5. By choosing the more expensive Alternative
6/7 for this reason, the authors and the State of Monrana are placing a high
value on having a lower stabilized Pit level. Why? What difference does it
make, the work objecrive only required the level to be below the CWL, why
waste $15-20 million to have a lower Pit level?- (14)
Both Alternatives 4/5 and 6/7 equally meet the two threshold criteria. The
balancing criteria must be weighed to decide which alternative is preferable.
As was expressed in this comment, there is a potential, if Alternative 6/7 is
employed, for the water level in the System to come to homeostatic conditions
before reaching the CWL. It is not definitively known whether this would
occur. There are positives and negatives to this occurring. We do believe
that there is value in allowing the water level in the System to rise as high as
possible without endangering the alluvial aquifer to reduce acid mine drainage.
On the other hand, there has been significant public comment wanting a lower
CWL. Regardless, we do believe that Alternative 6/7 will significantly slow
down the rate of rise in the System as compared to Alternative 4/5 and that
there is significant value in slowing the Pit flooding down. First, it allows a
greater period of time before a full scale treatment system has to be installed
and for additional technology to be developed. Second, it allows more time
for unexpected contingencies and glitches long before the CWL is approached.
Third, it potentially avoids significant expansion of the plant in the future if
the System does come to homeostatic conditions. Founb, it provides
continuous control of inflows while Alternative 4/5 does not. We believe that
continuous control of inflow contributes to the implementability and continuity
of the project.
Alternative 6/7 is more expensive (about 50 percent more) than Alternative
4/5; but in light of the benefits, we believe that these increased costs are
worth the benefits. On the other hand, the Agencies believe that similar
benefits derived from some of the other alternatives are not worth the several
hundred percent increase in cost over Alternative 4/5.
What is the basis for EP A having put a lid of $60 million on the amount of
dollars that could be spent for the perpetual remedy for this site? The
RS3-22
-------
Response:
Comment 7-14:
Response:
Comment 7-15:
PART I - SON-TECHNICAL COMMENTS
Preferred Plan says thai reducing the water in the Pit was not considered
because it would be too costly. As cost is only one of the nine criteria for
evaluating remedies. we recommend EPA go back and develop a plan that
reduces contaminated water in the pit-what is preferred by the overwhelming
majoriry of affected residents-and then evaluate its cost effecriveness along
with its abiliry to reduce mobiliry. toxiciry. and volume of contamination. its
short-term effecrs. its communiry acceptance. and its permanence. (G 2)
We set a $60-million cutoff as the line between moderate costs and high costs
in the comparisons of the alternatives in the FS. A line must be drawn
somewhere to enable the comparative analysis required in the FS. This line
was completely subjective and could have been higher or lower.
We believe that the benefits of reducing the Pit level below the existing level
are not worth the costs. Although the volume of contaminated water in
storage would be less (a potential benefit), the volume of acid mine drainage
generated on a daily basis and the loading of metals in the acid mine drainage
would increase if the Pit level is lowered. The higher the water level in the
System is maintained, the greater the inundation of the underground
workings. This reduces the oxygen supply to the System, thereby reducing
acid production and metals going into solution, thereby reducing toxicity.
Keeping the water level in the System as high as possible also reduces the size
of the cone of depression around the Pit. The reduction of the groundwater
gradiant also reduces the flow of uncontaminated bedrock water from the
periphery of the System from getting into the Pit, reducing the daily and long
term cumulative volume which needs treatment. Both alternatives are equally
permanent in that both will require treatment in perpetuity. '
CERCLA is supposed to reduce the amount of pol/urion in the area. ARCa is
saving money by not treating the contaminated water in the Pit now. 1
recommend that ARCa be required to quantify the money not being spent and
that this money be used to: (1) pay for more monitoring wells to better
understand the system and protect human health. and (2) research and develop
the new technology that will allow the profitable removal of the valuable
metals from the Pit. .. (11)
The ROD requires that a reevaluation of treatment technologies be performed
when the water level in the Pit reaches the 5,260-ft level. We have also
requested that the PRPs install three additional wells to further define the
alluvial and bedrock groundwater system east and south of the Pit and ARCO
has agreed to install these wells. We have also required an additional four
wells to be placed in the West ,Camp System. We believe that these tasks are
necessary to meet the objectives of the project and are not tied to the cost of
treatment.
What is being proposed is not a solurion, it is Q postponement that has to be
dealt with down the line, therefore it will cost more money. Jfthert is a
permanent solution now that is as cost-effective or even a little more
-------
Response:
Commem 7-16:
Response:
Commem 7-17:
Response:
Commem 7-18:
Response:
Commem 7-19:
PART I - NON-TECHNICAL COMMENTS
expensive, then is it not wOrTh getting involved with it? Why does it have to
be more cost-effective? (ESB 4-R)
The plan described in the ROD is a permanent solution. All alternatives
require treatment in perpetuity regardless of the level at which the East Camp
is mainUined. By allowing the water level higher in the East Camp,
significant monies are saved because: (1) the avoided operational and
maintenance expenses of not having to run a full scale treatment plant until the
water approaches the CWL; (2) the reduced flow to be treated at that time, the
selected metals loading which needs to be treated; and (3) the value of unspent
capital accrues 'over time.
The term cost-effective is constantly being used. What does cost-effective
mean to th£ people of this community ten years down the road? Does it mean
thar after th£ metals are taken, we are dealing with today's dollars or ten
years from now dollars? (ESB 4-Q)
An alternative is considered to be cost-effective if the alternative meets the
objective of the project (i.e., protection of human health and the environment)
and meets all State and Federal requirements for less cost than other
alternatives. The FS uses 1991 dollars as a baseline for any cost comparisons.
The baseline year is not important, as long as alternatives are compared in
tenus of the same baseline.
The EPA made a grave mistake in 1981 when tMy did not force ARCO to kJ!ep
th£ pumps running when ARCO decided to abandon the Pit. The waler should
never have been allowed to flow through th£ shafts and imo the Pit. The cost
would. have been much less than the cleanup is costing now, or will cost when
it finally does happen. (115)
EPA had no authority in 1981 to force ARCO to keep the pumps running.
The overall cost of the cleanup is much less if the water level in the System is
allowed to approach the CWL than if it had been controlled since 1982. See
response to Comment 7-16, Section 3.7.
"The EPA/ARCO plan doesn't adequately consider the fact that this country
has only been around 200 years. It doesn't consider th£ possibiliry of a future
economic depression thar might take dollars away from maimaining the Pit at
its full sign. It doesn"t consider the possibility of social upheaval or war. It
doesn't appear to have adequate fail-safes built in case of a breakdown of the
nuts-and-bolts ..,lams thar would have to be maimained for~r. " (T 9)
The plan outlined in the ROD accounts for costs in perpetuity, including
operation, maintenance, and replace~ent of components of a treatment plant.
Cost is not the major factor in Superfund decisions. Cost is secondary to
protecting human h£alth and th£ environmem. Under Superfund, hunum
h£alth must be protected from potential threats regardless of cost. The
-------
Response:
Comment 7-20:
Response:
Comme11l 7-21:
Response:
Comme11l 7-22:
Response:
PART I - NON-TECHJ\1CAL COMMENTS
cleanup plan and its end result should be simply proteering human health and
that should determine cost, not the other way around. 50 in devising a
remedy for the Berkeley Pit, we must not select the cheapest solution but the
solution which will maximi;:e the protection of human health and the
environment. rr J, T 9)
See response Comment 7-3, Section 3.7.
"Chelation Chromatography is a low-cost solution because it provides
marketable metals, it provides drinking quality or better water. Will ARCO
accept .or entertain a zero cost treatm£nI for cleanup alternarives?" rr 6)
We do not believe that this technology is presently the "Iow-cost solution."
This technology, or other technologies which recover metals, may eventually
become the low cost solution. The ROD requires a reevaluation of
technologies when the Pit level reaches 5,260-ft. Technologies are also being
demonstrated in the DOE Resource Recovery Project using Berkeley Pit
waters. Information from that program may eventually aid in the
implementation of metals recovery or other innovative technologies. We are
also encouraging the PRPs and developers of such technologies to collectively
come to us with innovative technologies that they believe are more appropriate
than hydroxide precipitation.
We also do not believe that Chelation Chromatography will create a zero cost
option at the present time. The value of copper and zinc in the Berkeley Pit
water is about $2.75-$3.00 per 1,000 gallons at current (June 1994) metal
prices, based on average concentration of 170 mgll copper and 355 mgll zinc.
The cost of the selected remedy which raises the pH and removes dissolved
salts is about $4.20 to $5.60 per 1,000 gallons depending on the total volume
of treated water. If the latter costs are incurred in addition to the cost of
metals removal by the Chelation Chromatography process, the value of the
metals in the water will not cover the cost of treabnent and will not create a
zero cost option as suggested by the commenter.
"What trust fund or funding means will be available to "eat water during the
'post mining' period and when does this period start? This is too open
ended. " (1 52)
We do not know when the post mining period will be. We see no way to
predict this period. EPA is presently evaluating the potential for requiring the
PRPs to provide bonding to cover treabnent costs the post-mining period.
"If the cleanup funds were available in advance could EPA require quicUr
action toward cleanup of the water that is now in the pit instead of waiting up
to 28 years? (G 2)
EPA and the State would not "require" the Pit to be pumped sooner unless
technical information is developed that indicates that pumping is necessary to
RS3-25
-------
PART I - ~O~-TEClL'\lCAL COMMEI'.'TS
protect human health and the environment. On the other hand, we would not
disallow parties from pumping the Pit at any time in the future if those parties
meet discharge standards. We do see a possibility for this happening. For
instance, if a high flow rate commercial metals recovery facility was
developed or if the underground workings were dewatered to stan
underground mining again.
3.8
COJ'lw'TROL I~TLOW
Commeru 8-]:
All surface water inflows-from streams, precipitation, snow pack, etc.-be
diverted from entering rhe Berkeley Pit. This would prevenr wasteful
contamination of clean water and prevenr the I'il from filling as fast as it is. (
/43, / 34, /4, / ], G])
Response:
The ROD does require diversion of the Horseshoe Bend flow in the near
future and clean inflows from the Pit System after mining has been suspended.
All clean waters presently going into Yankee Doodle Tailings Pond will be
diverted around the Pit System. Currently that water is used in the MR
process. MR needs a minimum amount of soft water in their operation. If
these clean waters are diverted around the System, an increase in the import
of Silver Lake drainage water would be necessary to make up the difference.
The underlying and primary objective of the selected remedy is to maximize
control of inflow to the Berkeley Pit in a cost-effective manner, thereby
minimizing the rate of rise in the Pit System. The selected remedy does not
require 100 percent control of all surface inputS as this would be impossible
and unreasonable. Water balance additions to the MFOU during current and
active mining are allowed as they are used within the tailings water circuit.
However, when mining stops, these additions (specifically the West, North,
East, Yankee Doodle Creek, and Silver Bow Creek Drainage) will be diverted
from the MFOU. .
Commeru 8-2:
-More description on flow of Horseshoe Bend water would be exxremely
pertinent and helpful. - (137)
Response:
Horseshoe Bend is a discharge of contaminated alluvial system water from the
old Silver Bow Creek stream channel in the northeast area of the Pit, in the
vicinity of the Precipitation Plant. The average flow of this discharge is about
2.4 mgd of which about .9 mgd is presently being integrated into the MR
tailings circuit and 1.5 mgd is discharged to the Pit. There are several
sources of this water, including natural recharge from melting snow and rain
and seepage from the leach pads and Yankee Doodle Tailings Pond. The
amount of flow from the various sources is unknown.
The Rl describes the Horseshoe Bend water as acidic water originating from
seeps at the base of the slopes at the north end and northwest comer of the
Precipitation Plant area. The pregnant solution and Horseshoe Bend water are
both acidic (pH ranging from 2.5 to 3.2 SU), have similar concentrations of
-------
Comme1ll 8-3:
Response:
Commenr8-4:
Response:
Commenr 8-5:
PART I - :'\O~-TEC~lCAL COMMENTS
barium, cadmium, calcium, copper, manganese, potassium, silver, sodium,
chloride, fluoride, and silicon, and have similar parameters of acidity,
alkalinity, hardness, temperature, and Eh. The difference between the tWo is
that the pregnant solution has concentrations of aluminum, arsenic, chromium,
iron, magnesium, nickel, zinc, acidity, sulfate, total dissolved solids (fDS),
and conductivity that are a magnitude greater than those of the Horseshoe
Bend water. The outflows from the Horseshoe Bend area averaged 2.40 mgd
(1,667 gpm or 3.72 cfs [cubic feet per second]). Tbese outflows include 1.54
mgd (1,069 gpm or 2.38 cfs) of water to the Berkeley Pit and 0.86 mgd (597
gpm or 1.33 cfs) of water to the PrecipitAtion Plant.
.The MR Concentrator should not bring in any clean warer from outside
sources like Silver Lake. Silver Lake Waler should be replaced completely
with c01llaminated water from Horseshoe Bend thar will be divened to the
tailings pond. The cumulative effect of removing the clean 'Waler from the
system and stopping the concentralor from dumping in the Pit will lower the
costs of n-eatm£nt in the future. . (l 4)
MR requires some Silver Lake water to meet their soft water needs. They
have the water rights for this water. Divening the clean water out of the
Berkeley System now will not lower the overall cost of the project because of
the cost of treating Pit water to meet MR's needs.
Complete elimination of Silver Lake water is not possible. Silver Lake water
is required for efficient and cost-effective operation of the MR. Concentrator
(a.k.a., Weed Concentrator). It is not as simple as a one to one replacement
of Silver Lake water with another water source. The chemica] characteristics
of the tWo waters must be considered. Silver Lake water is a high quality, .
soft water. Currently, there is not a consistent and adequate supply that meets
these requirements in the MFOU. To achieve such high quality soft water
with existing MFOU waters would require the construction of a treatment
plant. Silver Lake water is owned by MR and, as such, is less expensive than
water from a treatment plant. To require the construction of a water
treatment plant to replace the Silver Lake water would not be cost-effective
It should be noted that MR has verbally committed to minimi7e the use of
Silver Lake water and use alternative water sources when feasible.
.One of the positive aspects of the RIIFS is the treatme1ll of Horseshoe Bend
Water. . (BSB 7)
We also believe that this is a major positive aspect of the plan. This control
of inflow slows the rate of ris~ in the Pit considerably.
. All clean Waler entering the area should be divened around the operable unit
and discharged to Silver Bow Creek. aean Waler should not be allowed to
enter the pit or be divened to the Yankee Doodle Tailings Pond. The pond
was not designed for this purpose and the greater level of waler in the pond
would increase its instability in the event of an eanhqWJke. In addition.
-------
Response:
Cc1Tl112ent 8-6:
PART I - NO~-TEClC\'CAL COMME!\'TS
purring more water in the pond increases the likelihood that contaminated
waIer will leak from this pond and funher contaminate groundwater and Silver
Bow Creek. Water used by the existing mining operation should be treated to
Montana State Water Qualiry Standards and discharged to Silver Bow Creek.
The existing mining operation should not be allowed to contribute to the
problem at the Superfund site. " (l 3)
See response to Comment 8-1, Section 3.8. The Pond was designed to
receive this flow where it mixes with the tailings circuit water and recycles
back to the concentrator. The Pond dam meets the standards set by the
Montana Departtnent of Natural Resources and Conservation (DNRC) and
Department of State Lands (DSL). If this upper basin water was routed
around the Pond, then additional makeup water would need to be added at the
concentrator. There would be no net change of water in the System. If any
new water input to Yanjcee Doodle Tailings Pond were to alter the phreatic
surfaces within the dam, this import would then have to stop. The PRPs are
required to monitor and maintain the phreatic surfaces within the dam to
design specifications to insure its stability under the test parameters outlined in
the Harding Lawson Associates (HLA) report.
The input of "treated Horseshoe Bend" water will approximately match the
inflow into the Yankee Doodle Tailings Pond. MR is working to minimize
the input of Silver Lake water by offset to the tailings circuit.
The import of "treated Horseshoe Bend" water to Yankee Doodle Tailings
Pond should not increase the discharge to the alluvium underlying the Yankee
Doodle Tailings Pond because of the concurrent minimization of often makeup
water in the tailings circuit. However, if this import does result in increased
flow, this flow is likely to be captured by the ROD requirement to pump and
treat groundwater in the Horseshoe Bend area. There is no discharge of
alluvial groundwater in the Yankee Doodle Tailings Pond area to Silver Bow
Creek. All alluvial groundwater within this area east of the Berkeley Pit is
captured (within the cone of influence) by the Pit.
Currently, there is no discharge of water outside the permined area by MR.
If a discharge of waters from the MFOU is required, the discharge will be
required to meet applicable or relevant and appropriate requirements
(ARARs), including "I" class discharge standards.
"Beyond c01llrolling Horseshoe Bend water as pan of an inflow c01llrol
regime, please consider long-term options for dewatering upstream of the
c01llaminated ground warer, rerouting everything possible and reducing the
TU!ed for perpetual treatme1ll. If stasis in the miTU! flooding can be achieved at
an earlier date without the need for long-term treatment and artendanr sludge
geTU!rarion. or any other expensive, long-term treatment TU!eds, everyOTU! wins.
Intercept the water before it gets to the contaminated areas on the hUl.
Reduce its rate of filling to next to nothing. " (l'10)
RS3-28
-------
PART I - ~OS-TECHNICAL COMME1\7S
Response:
See responses to Comments 8-1 and 8-5, Section 3.8. We agree with this
statement, and in response to public comment, the ROD has been designed to
reduc~ inflows as much as practical. This means control of Horseshoe Bend
surface water and subsurface drainage that discharge to the Pit during mine
operations. Upgradient, uncontaminated surface water will be required to be
divened after mining has been suspended. However, complete dewatering of
contaminated water is not practical. Therefore, long term treatment of the
horseshoe bend flow will be required. Treatment cost can be reduced
however by reducing clean upgradient inflows as much as possible as required
by the ROD.
COMME~7S DIRECTLY RELATED TO EPA'S 1\'INE CRITERIA
3.9
A.
REDUCTIOS OF TOXICITY, MOBILITY, AND VOLUME
Comment 9A-l:
The EPA-ARCO "remedy" would allow doubling of the volume of
contamination now in the Pit from 25 to 56-billion gallons before any Pit
water is cleaned. Superfund law reads "reduce" not "increase. " (G 2, 130, I
23, I 13, BSB 5, T 1, T 9 )
Response:
From present conditions until the CWL for the Pit System (5,410 ft) is
reached (potentially up to 30 years) there will be a doubling of impounded
acid mine drainage or contaminated water. Only after the sulfide ores/soils
have oxidized will acid mine drainage stop. To minimize the total acid mine
drainage (contaminated water) in the future, the Pit System should be flooded
to the highest level possible. By doing this the volume of impounded acid
mine drainage doubles. Pumping the Berkeley Pit dry or keeping water levels
at current conditions increases both the volume of acid mine drainage and the
metals loading in the acid mine drainage generated on a daily basis.
Comment 9A-2:
1 cannot believe at this point in time, that the people of the United States,
State of Montana, Bune-Silver Bow and the stockholders of the PRPs would
allow such a catastrophe of a high degree and volume of toxic waste and
water. (J 50)
Response:
EP A and the State believe that the natural recharging of this man-made
dewatered area (i.e., the MFOU) is not a " catastrophe. " EJ?A and the State
are taking action that will prevent the recharging (flooding) waters from ever
being a threat to the Summit Valley and Silver Bow Creek.
Comment 9A-3:
The Office of Technology Assessment has concluded that the Superfund
program has too often settled ftJr remedy technologies which would not reduce
the "toxicity, mobility, or volume" of the luwudous waste. All too often
Superfund has settled for remedies short of cletUUlp. Given the serious 1UllUre
of the contaminants at the Pit, we cannot allow any remedy short of cleanup.
(ESB 5, T 1)
-------
Response:
CommenJ 9A-4.. .
Response:
Commenz 9A-5:
Response:
PART I - ~O~-TEClL'\lCAL COMME:'\TS
The use of the word "cleanup" for this operable unit is arguably a misnomer.
The objective of the project is to "control mine flooding" and prevent a
release to Summit Valley and Silver Bow Creek of acid mine drainage
(contaminated water). To drain the Berkeley Pit or keep waters at current
levels only increases the generation of acid mine drainage on a daily basis and
does not cleanup the operable unit. Using the word cleanup has the
implication that some act can be performed and the "problem" goes away;
thus, allowing one to walk away without further consideration or threat. This
is not the case for the MFOU; there is no such act that can be performed (the
solution) that allows no further consideration. Acid mine drainage and the
recharging operable unit are natural phenomenon. Only after acid mine
drainage stops and the area has recharged will there be an end to the potential
threat to Summit Valley and Silver Bow Creek.
A number of people expressed their unhappiness with the plan's downgrading
of the Superfund "balancing criterion" which requires the remedy to "reduce
toxicity, mobility, and volume" of contaminants. Defense of this strategy
based on long term vs short-term protectiveness failed to appease these
participanzs. (G 1)
There was no "downgrading" of the balancing criteria. The "reduction in
toxicity, mobility, and volume of contaminantS" is only one of five balancing
criteria and was taken into consideration by EP A and the State. Although the
selected remedy will have a greater amount of acid mine drainage in storage
than would draining the Pit or keeping it at itS current level, allowing the
System to recover to a higher level reduces the long-term generation of acid
mine drainage. Keeping the Pit System at itS current level, or "draining" the
Pit System, would increase the long term total amount of acid mine drainage.
How does the Preferred Remedy reduce toxicity, mobility, and volume of
cOnJamination? We see that it increases the volume of conzaminated water
and groundwater in the short-term and doubles it in the long-term and
permanenJly. We see that it creates greater toxicit)' and that the pounds per
square inch (psi) increases the probability ofmobilizatioT/ throughfracrures in
the bedrock. It is also mobilized as it climbs to the 5,410-ft CM.. (G 2, T 9)
The .problem" at the MFOU is an acid mine drainage problem. For acid
mine drainage to occur, three factors are needed: sulfide ores/soils, water,
and oxygen. The total amount of acid mine drainage is a direct correlation to
the total amount of sulfide ores/soils. It is not feasible or possible to prevent
water from entering an area the size of the MFOU. The only way to reduce
the amount of acid mine drainage is to deny the sulfide ores/soils oxygen.
Allowing the water level in the System to recover as much as possible by
inundating the exposed ore bodies is one method to reduce acid mine drainage
because the flooding eliminates, at depth, oxygen from the ore body.
For the Pit. System, there are four situations, with respect to water, that may
be considered: (I) immediately filling/flooding the Pit, (2) "draining" the
-------
PART 1- NON-TECHNICAL COMMENTS
Pit, (3) keeping it at its current water level, or (4) slowly filling the Pit.
Immediately filling/flooding the Pit and slowly filling "the Pit will double the
impounded volume of acid mine drainage. Draining the Pit or keeping it at
current levels will keep constant or reduce the impounded volume of acid
mine drainage. Further, immediately filling the Pit would minimize the total
amount of acid mine drainage generated; draining the Pit would maximize the
total amount of acid mine drainage generated; slowly filling the Pit will
generate a greater amount of acid mine drainage than immediate filling (yet
less than keeping the Pit at its current level); and keeping the Pit at its current
water level would have the second greatest total amount of acid mine
drainage. The doubling of impounded acid mine drainage does not create a
"greater toxicity," it only doubles the volume of impounded acid mine
drainage.
The comment concerning the increased psi is incorrect. There are two issues
in this comment that require discussion: diffusion forces and hydraulic forces.
First, the Pit System is a dewatered system. Until the System is recharged,
there will be flow of water from all directions, including at depth and at the
bottom of the Pit. Contaminants would have to move (diffuse) "outward"
against this gradient. This is not possible. To illustrate, "[d}iffusion in
solutions is the process whereby ionic or molecular constituents move under
the influence of their kinetic activity in the direction of their concentration
gradient. Diffusion occurs in the absence of any bulk hydraulic movement of
the solution." (Freeze, R.A. and Cherry, J.A. 1979, Ground Warer, Prentice-
Hall, Inc., Englewood Cliffs, page 103) (Underlined for emphasis).
The kinetic force "outward" for the "contaminant" wiIJ always be less than the
hydraulic force "inward" of water recharging a dewatered system. For the
Berkeley Pit, the hydraulic force/movement of water is out of the bedrock and
alluvial aquifers, preventing upgradient ("uphill") migration of contaminants.
Mathematically, the forces which drive groundwater towards the Berkeley Pit
are one million times greater than the forces of diffusion (e.g., transmissivity
might be approximately 0.01 meters squared per second (m2/sec) versus a
diffusion coefficient of 0.00000oo1 m2/sec).
B.
CONCERNS ADOm SUPERFUND PROCESS IN GENERAL
OJmme1Jl 9B-1:
Response:
OJmme1Jl 9B-2:
Response:
"Should primary remedioJ aCtion objeCtives be listed as preliminary aCtion
goals?" (137)
We believe that the objectives were correctly listed as such.
"Giwn the considerable scientific Wlcenainty about the pit. moTe weight
should be given to community acceptance of the Remedial Plan since they are
being asked to take the risks. " (1 3)
Community acceptance is a modifying criterion according to the NCP. It is
used to modify a decision reached by an agency based on threshold and
RS3-31
-------
Commenl 9B-3:
Response:
Comment 9B-4:
Response:
Commenl 9B-5:
Response:
Commenl 9B-6:
PART 1- ~OS-TECH!\1CAL CO~fME:\7S
balancing criteria. While community acceptance of a proposed remedy is
desirable, and will play an important role, its weight in decision-making will
remain the same. Community acceptance cannot overrule the other criteria.
We do not believe that there is "considerable scientific uncertainty" about the
Pit; there are differences in opinion. In the ROD, EPA has modified the
preferred alternative presented in the Proposed Plan to accommodate these
concerns as much as we believe possible.
.Community acceptance should be given an extremely high priority when
sciences, such as hydrology and geochemistry of a very complex system, which
are inexact sciences at best, set public policy. " (I 1)
We do not believe that the information we have gained about the Pit
hydrogeol0gic system is based on "inexact science." While pr.. fcssionals may
differ in their analysis of information, we have weighed those opinions and
settled on the specified remedy. However, despite the scientific basis of
EPA's decision, we still listened closely over the last four and one-half years
to citizen concerns, and modified our analysis and preferred remedy based on
those concerns.
"A missed objective of the RI/FS is to protect human health and the
environmenl. " (I 37)
We do not list protection of human health and the environment in our RIIFS
objectives in the Proposed Plan because this is an underlying objective of all
actions. More important to the Butte populace is: "How is human health and
the environment to be protected?" This is discussed thoroughly in the
Proposed Plan.
The purpose of Superfund is to clean up sites of cOnlamination, permanent
cleanup remedy, not moving cOnlaminanls to anolher sile. The law directs
EPA 10 proteer citizens and make Superfund sites clean. Any remedy for the
Pit should be a cleanup remedy. The Superfund law emphasizes: (1) cleanup,
(2) to reduce toxicity, volume, and mobility of hazardous substances and
polluranls at the site, (3) must be permanenl, (4) must nOl move hazardous
material, and (5) cost should nol be a major factor. (BSB 4-A, BSB 5)
EP A and the State believe that we are reducing the risks to human health and
the environment with the remedy as detailed in this ROD.
The Berkeley Pil Mine Flooding is a unique problem thai will require unique
and creative solutions, both in technology and in the
implementation/administrative process. "Business as usual" will not solve the
problems nor render the most innovative solutions to this critical community
problem. The Butte-Silver Bow local government, through its OUef Executive
and Council of Commissioners, submitted comments on the Berkeley Pit Rl/FS
and Proposed Plan in hopes of fostering the level of innovation and creativity
needed to meet the concerns and needs of our citizens. (BSB 2)
-------
Response:
Comment 9B-7:
Response:
PART J - NON-TECHNICAL COMMENTS
Comment acknowledged.
One speaker expressed hope that this exhaustive process, with all its fits,
startS, and mistakes. would help make the subsequent phases of the decision-
making process at these sites more efficient and effective. (G 1)
Comment acknowledged.
C.
SHORT - TER.'f EFFECTlVEr--'ESS CONCERNS
Comment 9C-1:
Response:
Ccmment 9C-2:
Response:
Comment 9C-3:
Response:
Does the Preferred Plan have any short-term adverse effeCts? (G 2,112)
No, we do not believe that there are any increased short term adverse effects
associated with the prefe1;~d plan versus the other aJternatives.
-The short term effeCtiveness has curiously been defined in terms of the
damage that would occur from the aCtive remediation effortS. Again, I am
sure the RlIFS report followed correCt procedures in defining the s/wrt term
effeCtiveness of its alternatives in this way. S/wrt term effeCtiveness should
refer to alternatives that are effective in the near future. Using this logical
definition of short term effectiveness. Alternatives 18119 are the only ones that
take effective aCtions in the short term to stabilize the Pit water level. - (1 4)
EP A and the State do not believe that the time for stabilizing the Pit is related
to short-term effectiveness. The Pit water level cannot be .stabilized. without
pumping forever. The MFOU is a man-made dewatered system. Only when
or if the System has recharged will the System be .stabilized.. Alternative
18/19 increases the totaJ amount of acid mine drainage generated. Alternative
18/19 would reduce the volume of impounded acid mine drainage.
-It is stared that all the alternatives have short-term effectiveness because none
result in adverse short-term effeCts. We believe short-term effectiveness means
how effective the remedy is in the short-term and if it deals with the problem
quickly. None of the alternatives deal with the problem quickly, rarher the
alternatives attempt to justify putting off cleanup for decades. Why does EPA
not recognize the increased volume of contamination as a short-term effect for
exmnple?- (G 2)
See response to Comment 9C-2, Section 3.9C. EPA and ihe State
acknowledge that in the short term there would be a doubling in the volume of
impounded acid mine drainage; however, it must be reaJized that there are no
negative heaJth or environmental impacts due to the mine flooding problem
until water discharge to the aJluviaJ system on the upper Silver Bow Creek
drainage. The Preferred Alternative prevents this from happening.
-------
D.
LONG- TER..\f EFFECTIVE:\'ESS CO:-.JCER.."JS
PART I - ~O:-.J-TECH.'\lCAL COMMENTS
Comment 9D-1:
Response:
E.
"1M claims of long term effectiveness of all the alternatives are circumspect
because the objeCtive on which they are based is not ambitious enough to
ensure human health and environmental safety in perpetuity. The claims are
based on fulfilling the objeCtive from the work plan to prevent discharge of
mine water to the adjacent alluvial aquifer and Silver Bow Creek and to
maintain the flow of ground water toward the Pit by keeping the water level
below the criticf(ll water level (CDM Federal Programs Corporation, 1990).
All the alternatives. except one. meet this limited objeCtive.
"1M objeCtive should be to establish a truly permanent solution that doesn't
require maintenance into eternity. The work plan should request an RI/FS
that outlines real alternatives thar could lead to permanent solutions. not just
a gradient of treatment options and timelines. If the original work plan would
have outlined a more ambitious work plan that required the examination of
permanent closure options and treatment options then a reasonable decision
could be made in terms of costs. " (1 4)
See response to Comments 9A-3, Section 3.9A and 9C-2, Section 3.9C. EPA
and the State believe that there is not a significant increased threat by
stabilizing the Pit at a lower level. Pumping the Pit immediately (Alternative
18/19) does not significantly reduce threat nor does it reduce acid mine
drainage. Short-term effectiveness, therefore, is not increased. We believe
that the objectives established in the MFOU RIIFS Work Plan were
appropriate under the regulations set forth in the NCP. Specifically, EP A and
the State believe that from the perspective of what is logistically practicable to
accomplish, the Preferred Alternative provides the greatest degree of long-
. term effectiveness as compared to the other alternatives. The Preferred
Alternative will safeguard human health and the environment through
permanent water control and treatment. The MFOU is a man-made dewatered
system and a problem of acid mine drainage. There is no "quick fix" to the
System. Until acid mine drainage has stopped, there will be requirements for
treating contaminated water. An altering of the original work plan would not
change the laws of nature. We acknowledge that neither the Agencies nor the
PRPs will be able to "walk away" from the potential problems presented by
these contaminated waters, but believe that the Preferred Alt~mative combines
the best balance among EP A '5 nine evaluation criteria. .
OTIIER ALTERNATIVES
Comment 9E-1:
"1 recommend that Alternative 18/19 be adopted because of shon tenn
effeCtiveness (as 1 define it) and best long term effectiveness of the options
presented, i.e. it will have the lowest stabililed Water level. This will leave
the least burden upon future generations and establish the largeSt margin of
safety. " (1 4)
RS3-34
-
-------
Response:
PART 1- NON-TECH!\lCAL COMMEI'I.'TS
We do not believe that Alternative 18/19 combines the best balance between
the nine evaluation criteria. A significant lowering of the water level in the
Berkeley Pit at the present time would increase the amount of acid mine
drainage generated and would increase the metals concentration in the acid
mine drainage. We believe that minimizing the volume of Pit System water at
this time would create additional problems and would not reduce the threatS to
human health or the environment more than the Preferred Alternative.
F.
PERMM"ENT CLEANUP
Comment 9F-1:
Response:
Comment 9F-2:
Response:
Comment 9F-3:
Response:
Comment 9F-4:
Response:
Comment 9F-5:
"How is this solution of creating a 50 billion gallon plus body of toxic water
good for the State of MOn/ana or the people of Bune-Silver Bow? Is it only
the PRPs that will benefitfrom this solution?" (T 2)
We believe the Preferred Alternative combines the best balance between the
nine EPA evaluation criteria. Please refer to responses to CommentS 6A-3
and 6A-4, Section 3.6A and 9E-I, Section 3.9E.
"How man)' years will the Stale of Montana and the people of Bune-Silver
Bow hove to live with this very large amount o/toxic water, 1200 years, 1,000
years or forever?" rr 2)
A permanent fix that would allow the PRPs and the Agencies to "walk away"
from this problem does not exist. We will implement a response action that
provides the best combination of currently available technologies to eliminate
potential risks to human health and the environment from the Pit System
water. We will remain flexible about how the response action will be
implemented so that newly developed (and proven) technologies can be
implemented to best manage this larg~ volume of contaminated water.
77re plan needs to have stronger emphasis on eventual permlUJent cleanup. rr
1, 151)
Refer to responses to CommentS 9F-I and 9F-2, Section 3.9F.
"77re EP A. plan will saddle future generations with worries aboUl du! pit level
nTw(])'s at the 'full' mark. " (G 2)
The PreferreJ Alternative combines the best balance of currently available
technologies among all the alternatives evaluated. The Preferred Alternative
is also flexible in itS implementation and provides for a re-evaluation of new
technologies in the future. We realize that the contaminated water in the
Berkeley Pit is likely to always be a concern to the citizens of Butte. We
believe that the CWL of 5,410 ft is not a "full" mark. There is at least 50 ft
of additional volume before discharge out of the Pit System could occur.
"77re Pit is certainl)' a hazardous waste site. Does du! proposed plan really
call for a cleanup of the Pi!? Is this a cleanup solution when it leaves in
-------
Response:
PART I - :\ON- TEC"-,1CAL COMMENTS
place a lake of poison? Is this a cleanup solution when it leaves BUlle in a
state of perpetual environmental crisis?" (l51)
We do not believe that this leaves Butte in a state of perpetual environmental
crisis. Regardless of the solution employed, perpetual treatment will be
necessary. There is no technical solution for "eliminating" the problem
regardless of the volume of contaminated wat~r left in the Pit.
G.
PROTECT AGAINST RELEASE A.~l> THREAT OF RELEASE
Comment 9G-l:
Response:
Comment 9G-2:
Response:
"To say thaI contaminared mine waler is being contained in this OU is false.
Conraminants have migrated into the vadose zone, and soils, and other surface
warers outside of this OU. " (l 37)
A thorough review of the available data by EPA, the State, and ARCO
indicates that all contaminated bedrock groundwater in this operable unit is
flowing toward, and being contained in, the Berkeley Pit/East Camp System.
Contaminated water will fill presently unsaturated areas, but contaminated
waters cannot migrate out of the Pit System.
"How does the Prefe"ed Remedy protect against the release and the threat of
release of contamination given the fact thaI water can indeed move through
bedrock of the pit and contaminazed mine warer cu"ently enters Silver Bow
Creek from the bedrock aquifer at the end of the Colorado Tailings where it is
a gaining stream?" (G 2)
The currently available data indicate that the bedrock alluvial aquifer gradient
is toward the Berkeley Pit/East Camp System. The water elevation in this
System is currently between 5,080 ft and 5,118 ft and the elevation at the west
end of the Colorado Tailings is approximately 5,410 ft. Therefore, Pit
System water cannot be discharging to Silver Bow Creek. . Gaining conditions
in Silver Bow Creek in the area of the Colorado Tailings are due to the influx
of alluvial and bedrock groundwater that is not in contact with the Pit System
water.
H.
CONCERNS ABOUT THE PROPOSED PLAN
Comment 9H-l:
Response:
Comment 9H-2:
"More graphics in the Proposed Plan would have aided the reader to
understand the nature and extent of the problem. Figure 1 was terrible. One
can barely read the map. It would be helpful to depict Horseshoe Bend warer
and flow. "(137)
Comment acknowledged. Copy quality of maps varied significantly.
"Include a poStage paid comment sheet to the back 01 the Proposed Plan
addressed to Russ Forba. " (l 37)
-------
Response:
Comment 9H-3:
Response:
Commem 9H-4:
Response:
Comment 9H-5:
Response:
Comment 9H-6:
Response:
Comment 9H-7:
Response:
Comment 9H-8:
PART I . NON-TECHNICAL COMMENTS
We provide numerous opportunities for public comment. We do not feel a
postage-paid comment sheet is a cost-effective way of generating public
comment.
"The Proposed Plan was not written objectively. The Proposed Plan must
present each alternalive in equal light throughoUl the plan, with the exception
of the 'Discussion of the preferred alternalive' section. " (I 37)
EPA and the State disagree. The Proposed Plan was an objective document
that strived to make clear that EPA and the State had a preferred alternative.
"When presenting the preferred alternalive use 'would' instead of 'will.' We,
the public, want to feel as if an alternative hils not )'et been chosen and that
our comments count for something. " (I 37)
Our intent with language use is to make a document as readable and
understandable as possible. We assert often that public comment is
encouraged on all alternatives and that the preferred alternative is indeed
subject to change depending on public comment.
"Is the preferred alternative considered a 'Final ACtion, , a 'Limited Action' or
an 'Interim or Preliminary.' ACtion? This was never clear. Nor was it clear
how this OU is rolled imo the Silver Bow CreekIButte Area NPL site. " (I 37)
EP A Montana Office proposed plans indicate when an action is interim or
limited. We do not feel it is necessary to specify that an action is final; that is
the assumption at the end of an RIIFS and completion of a ROD.
"This plan is weak in mentioning ana1)'tical results. What is the extent of
comamination in terms ofppb?" (I 37)
In interviews and informal discussions with the public, we have been told time
and time again that public information should be as clear and non-technical as
possible. Thus, level (not extent, which indicates spread rather than level, of
contamination) is not as important to people as is what we intend to do at a
site. The RIfFS is available to the public, free of cost, if this information is
important to them.
"Should key elements of the Preferred Alternatives include ProteCtion of the
Aquifer and Institutional Controls?" (I 37)
We I isted key el ements that are active aspects of the preferred remedy.
Protection of the (alluvial) aquifer is a goal, not an element; institutional
controls are an element discussed in the plan. It could be listed as a key
element.
.Other neUlralizing agents. is too vague, as is .or l1y a trtatme1l1 In a newly
constrUaed treatment plant.. The treatment train should be part of the
RS3-37
-------
Response:
PART 1- NON-TECHl'1CAL COMMENTS
Preferred Alternative. Must be more specific on how it is treated. To
evaluaze costs effeCtively a .preferred rrearment rrain" must be assumed for
each airernarive. F1e~ibility can be written into the proposed plan that says
something to the effeCt that treatment l1y an on-site treatment plant has been
assumed unless something more efficient and cost-effective can be found.
(1 37)
Comment acknowledged.
I.
PUBLIC PARTICIPATION
Comment 91-1:
Response:
Comment 91-2:
Response:
The solution to the Pit problem must show sensitivity to public input. The best
environmental policy decisions and outcomes are achieved through public
discussion and through public debate. The public has a right and a duty to
subjeCt the opinions of so-called "apens" to intense criticism. The final
Berk£ley Pit decision must clearly demonsrrate and show not only that public
input was heard but that it was listened to, and that public input had some
impaCt, that it had some efficaciousness in arriving at the final decision about
how to deal with the Berk£ley Pit. (1' 1, 1 51)
EP A and the State agree that environmental decisions should be made with
public input. For the last four and one-half years EPA has gone to the public
at least every six months to discuss the ongoing RIIFS. We have listened
closely to public concerns. We believe that our Preferred Alternative is better
than it might have been precisely because of public input, and the ROD
reflectS community input. However, if EPA's public involvement program is
judged by whether EPA makes only those decisions that please a public group,
then our image must suffer. We listen to the public and use that information
to modify decisions that are based on scientific and technical information.
"Public involvement in the Berk£ley Pit clean up is extremely difficult due to
the immense amount of technical information involved. Few people have the
time or expenise to wade through the hundreds and hundreds of pages
included in the RIfFS. If the public is reall)' going to be involved in this
process. EPA must mak£ a more concened effon to interpret these 'Volumes of
informarion. However, the information should come from an independent.
objeaive source; someone who has not already aligned him/herselfwith a
specific alternative. Additionally, the public should be brought in at a point
more conducive towards participation in this decision making process.
Although the state was included from the begiMing, the public was brought in
at the last possible momelll. . (l 5)
We agree that is difficult to assimilate all the technical information involved
but it is incorrect to state that the public was brought in at the last possible
moment. As for the "independent, objective source," EPA funded a Technical
Assistance Grant in 1991 to a group in Butte (CTEC) who were to read and
interpret the documents and disseminate information to the public. 'Ibis is a
group that is not aligned with either EPA or the PRPs. We have worked with
-------
CoTTl1Tli!nt 9/-3:
Response:
PART I - ~ON- TEC~lCAL COMMENTS
CTEC and other members of the public, in public forums, for almost five
years.
I recommend that the written quality of the public documents be improved to
make them understandable to the public and to facilitate, rarher than
discourage public involvement. (/43)
Comment noted. We constantly strive to improve the readability of our public
documents, while balancing the need to get technical information
disseminated. Our goal in writing these documents is to facilitate public
involvement.
J.
SOCIAL A. '\'1> ECONO!\flC ISSUES
CoTTl1Tli!nt 9J-J:
Response:
CoTTl1Tli!nt 9J-2:
Response:
CoTTl1Tli!nt 9J-3:
Response:
"The EPA plan doesn't look at what it is doing to property values in Butte
today, and especially near the Pit. " rr 9)
EPA.is mandated to protect human health and the environment. We are not
charged with examining social or economic impacts. In general, however,
Superfund cleanups have improved property values (e.g., Anaconda near the
proposed golf course).
We hope that the plan that is being pur forth will take into account not only
the health and welfare of the community, bur also the economic development
of the community. rr 3, BSB J2-G, BSB 6. BSB 7)
EPA and MDHES have shown their willingness to work with a community
toward a mutually agreeable cleanup plan (e.g., Lower Area One in Butte, the
Old Works in Anaconda). If a remedy can create economic benefit, everyone
benefits. However, some remedies are limited by cost-effectiveness; the
remedy cannot be tied to economic benefit without increasing the costs
unreasonably.
17u! EP A/State of Momana Preferred Remedy actually harms Butte's economy
by flooding off access of historic underground resources. 17u! plan will surely
cause disastrous economic and social consequences. We need reasons for
businesses and professionals to relocate here, not the world's largest body of
toxic liquid to drive the folks we have away. We don't believe it is good
policy to pass our problems on to our kids and theirs and theirs. We need
innovative thinldng, not a Remedy that fits the old adage of cutting off one's
nose to spite one's face. (/ 50).
We acknowledge that flooding the underground mine will make underground
mining more expensive to resume. Superfund allows the Agencies only to
address human health and environmental impacts, not socioeconomic impacts.
-------
PART I - NON-TEC~lCAL COmIE~'TS
Comment 9J-4:
"My main concern is rhe economic impacr any delays would have on rhe
growrh and a"racriveness of Burre to outside interests. Right now it's nil.
Mining is temina/. is Burre?" (131)
Response:
See response to Comment 9J-3, Section 3.9J.
3.10
PETITION
The Clark Fork Pend Oreille Coalition circulated a petition, which was signed by 3,690 citizens.
Some individuals sent the language of.the petition directly to EPA in Helena based on an
advertisement in the Monrana Standard. The language of the petition was:
Comment 10-1:
"I/We, the Undersigned Citiz.en(s) of Montana, hereby petition the United
States Environmenral Protection Agency to reduce the water level in the
Berkeley Pit and clean it up now.
I/We don't want BUlte to have what would probably be the largeSt body of
toxic water in the world. EPA's plan to ler the pitjillfor the next 30 years
will ham BUlte's social and economic future. A full pit poses a perpetu/lJ
threat of release of contamination, /t passes our problems on to future
generations to worry aboUlforever. " (P 1 through P 12)
Response:
EP A and the State respect the position of the petitioners and can understand
the support for the petition. EPA and the State believe that to "reduce the
water level in the Berkeley Pit," would not "clean it up now," and is not more
protective of human health and the environment, EP A and the State are
mandated to make remedial decisions using nine criteria. Public acceptance is
one of the two modifying criteria and EP A and the State believe that reducing
the water level in the Pit is not the correct remedy when assessing all nine
criteria together.
In addition, the Clark Fork Coalition submitted a letter with the petition which included the following
comments:
rf)11!mem 10-2:
"Enclosi'; ;; ~ Berkeley Pit petition signed by 3,690 affecred citizens. Of
these 3,470 are residents of Bune-Silver Bow County. The balance are
concerned Anacondans and other residents of the Qark Fork Watershed, as
well as a few Montanans from nearby cities and towns.
17ze people who have signed this petition makI! up over 10.3% of the
population of Bune-Silver Bow. 17zeir number is abour the same as those who
voted in the recent school board election. 17ze number of signatures is
significant in that the petition was 'worked' for pans of the day on only three
Saturdays in one store in Bune (abour 2,()()() signatures),' a small donated
newspaper ad received an amazing 2.6" response rate (286 maUed-in
petitions),' petitions were oUlfor abour a week in six retaU establishme1lts. and
the balance came in from people who asked to take petitions from K-Man for
-------
Response:
PART I - NON-TECHNICAL COMME"'TS
their friends to sign. We believe that over 95% of those in BUtte who were
ask£d to sign the petition did so. Those who didn't were usually in a rush;
very few refused. The point is, this was something the citizens of Bune-Silver
Bow were able to agree on wholeheartedly. ThEy often said, 'thank you!' and
'bless )'ou, ' and expressed the y,~sh they had time to get more involved. .. (P 1)
See the response to-Comment 10-1, Section 3.10.
~fISCELLA.'ffiOUS ISSUFS.
SCIENTIFIC STUDY OF PIT
3.11
A.
CommentllA-I:
Response:
The environmental situation in the MFOU Berk£ley Pit System offers a
tremendous opportunity for scientific study which should not be lost, and
which Mll certainly be useful to others in future times and other places.
There are presenrly similar situations inrernationally where detailed
investigations have been in place for some years; bur these do not appear even
to have been identified during the feasibility study, let alone taken as example.
In the near future other mine operators y,i11 need to deal Mth situations
similar to those at the Berkeley Pit and a we11-documented aCtivity Mil be
appreciated. In the immediate future the WISMUT mines in Germany
(especially the Ronneburg Pir) Mil commence to flood and Mil take about 15
yearSto fill. (l53)
We acknowledge this comment and add that MSE is currently conducting a
five-year pilot scale program to test innovative technologies for the treatment
of Berkeley Pit water. This program solicited technologies from throughout
the world and, therefore, is testing the most promising technologies currently
available anywhere.
B.
UPDATING DATA AFTER RECORD OF DECISION
CommentllB-I:
-mhe County would recommend that the ROD include specific language that
clearly articulates the process for updating the data from the RI/FS,
particularly if any data or information used to decide on the preferred
alternative proves to be incorreCt or inaccurate. The County and its citizenry
need to know:
aJ
how the agency and PRPs will respond to new and/or better
information that emerges from actual data colleCted, panicularly if
this new information has arry impaCt on the environment or public
health,'
bJ
how and under what conditions the decisions in the ROD will be
clumged, based on updated information,' and
-------
Response:
3.12
PART I- NON-TECHI\1CAL COMMENTS
c)
how the Count)' or an independent party designaJed by th£ community
can be directl)' involved in the decision-making process throughoUJ the
monitoring period and the implementation o/the remedy." (BSB 2)
The following points address the specific questions outlined above:
a)
EPA and the State intend to produce yearly updates concerning the
monitoring information that is generated, as well as a more in depth
analysis of information and data every three years. This analysis
would include updates of the water level increases in the System,
recalculations of the remedial design, and construction completion
trigger dates, as well as updates in "I" classification discharge
standards. Also these updates would present new monitoring data,
which might dictate changes in the monitoring system, the CWL, or
schedules for construction of a treatment facility.
b)
The revised schedules derived from updating the predictive fill rate
model will not nece~sitate a ROD amendment because this activity is a
routinely planned update anticipated in the ROD. To enact more
significant changes, such as significant changes in technology to be
employed or changes to the CWL, will necessitate a ROD amendment
or an "explanation of significant differences (ESD). n Both of these
processes require a public participation step.
c)
EP A and the State would like to actively involve local government in
the yearly update and the three year data analysis process. We plan to
discuss methods for their involvement with Butte-Silver Bow. We
also envision the MBMG, currently located in Butte, to bead up the
technical portion of these activities. We believe this local involvement
will aid in communicating progress and updates to the general public.
INSTITUTIONAL CONTROLSI APPLICABLE OR RELEVANT M1> APPROPRIATE
REQUIREMENTS
A.
INSTITUI10NAL CO~'TROL ISSUES
Comment 124.-1:
. "Butte-Silver Bow has a contract with ARCO whereby they agreed to create
some yet-to-be-defined Institutional Controls that appear to include well bans.
To what extent, if any, does the Prefe"ed Remedy rely on Butte-Silver Bow
being able to condemn some wells andforbid drilling others?" (G 2) .
Response:
It should be noted that. regardless of the engineered remedy that is
implemented, the bedrock aquifer cannot be cleaned up. Under the remedy
espoused in the ROD, the quality will improve in the future, but the water
quality will not meet drinking water standards in much of the area in the
foreseeable future. There is no alternative to this fact. The engineered
remedy does not rely on Butte-Silver Bow to condemn wells or forbid drilling.
However, the remedy does rely on institutional controls (lCs) to protect
-------
Comment 12A-2:
Response:
Comment 12A-3:
Response:
B.
ARARs
Comment 12B-1:
Response:
Comment 12B-2:
PART I - NON-TECHNICAL COMME~'TS
citizens from exposure to contaminated bedrock waters within the area
outlined in the ROD. We believe that local management of the ICs by local
government is prudent and appropriate. The local government would be
compensated for running any such program.
These ICs could prevent the use of wells drilled into the bedrock aquifer of
the MFOU if the levels of contaminants pose a threat to human health and the
environment.
~Please define the geographic area expeCted to be affected along with the
types of restriCtions anticipated for each. ~ (G 2)
The geographic area is shown in the ROD (Technical Impracticability ARARs
Waiver - Attachment 2).
We anticipate the ICs to require testing of any bedrock well within this area to
confinn the presence or lack of contamination and allow usage accordingly.
The development of a specific program will occur after the issuance of the
ROD.
~Please state if the property owners involved were aware of these potential
restrictions before close of the public comment period for this Prefe"ed
Plan. ~ (G 2)
Many property owners probably were not aware of the potential for these
restrictions, even though it was general public knowledge throughout the
process. Institutional controls have always been presented as part of the
MFOU RIIFS remedy and language were included as part of the Proposed
Plan. It should be noted that, because the impaired bedrock aquifer cannot be
restored to drinking water standards in the foreseeable future regardless of the
technical remedy employed, the ICs are independent of the remedy and do not
impact the remedy selection process.
-List the ARARs (see the NCP.& Proposed Plan guidance). - (1 37)
The primary ARARs are discussed in the Proposed Plan. A complete listing
of ARARs is too lengthy to include in the Proposed Plan. They are included
in the FS (which EPA can supply to anyone upon request), and they will be
updated in the ROD.
The Migratory Bird Treaty ACt of 1918 (MBTA), as amended. 16 U.S.C. 703,
fi gg., and the Bald Eagle Protection ACtion of 1940 (BEPA). as amended.
16 U. S. C. 668. fi HJl., are not listed in the ARARs in Appendix Y of the FS
report. Similar to the Endangered Species ACt. both the MBTA and BEPA are
federal location-specific ARARS and should be included in the appropriate
section. (GOV 1)
RS3-43
-------
Response:
Comment 12B-3:
Response:
c.
WATER FOWL
Comment 12C-1:
Response:
PART 1- r\ON-TECHNlCAL COMMENTS
Comment noted. This regulation will be included in the ROD.
We agree tluJt if the "ultimate" ARAR for all projects relating to discharge of
waters to Silver Bow Creek are "Gold Book" criteria, including chronic water
quality criteria. (FS. Appendix Y, p. 30), the proposed remedy will be
protective of the Silver Bow Creek aquatic environment. We would
recommend tluJt the Mine Flooding remedy design be coordinated with the
remedy for the Streamside Tailings and Lower Area One Operable Units so
thai the Mine Flooding DiscluJrge will not affect the Silver Bow Creek
cluJnnel. (GOV 1) .
Comment noted. EPA and the State plan to coordinate the implementation of
all of these projectS to maximize water quality benefitS.
Considering the very brief and rudimentary nature of the study conducted by
Biosystems Analysis Inc., the potential cumulative effects from heavy
concentrations ofsix.differenr heavy metals, and the lack of information
regarding the effect of these toxins to waterfowl specifically, it is of primary
imponance that the Prefe"ed Alternative incorporate a plan for effectively
preventing access to the Berkeley Pit water by waterfowl. This will ensure
thai the Prefe"ed Alternative complies with the Bird Migratory Act. (1 5)
EPA and the State will be coordinating with the U.S. Department of Interior
to mitigate potential impactS on waterfowl in a cost-effective method.
D.
Th'TERACTlON OF PLAN WITH NATURAL RESOURCE DAMAGE ACTIONS
Comment 12D-1:
Response:
Comment 12D-2:
"How does this Superfund cleanup anticipate restoration work to be done as
required in the Natural Resource Damage Act ponion of CERCLA? Because
both are in the CERCLA law, a reasonable man would expect the one to be a
jumping off point for the other." (G 2)
We are unable to anticipate the restoration work to be done under the Natural
Resource Damage (NRD) program. The NRD program will be able to plan
their restoration activities more precisely following the ROD.
The selected remedy is a remediation response to protect human health and the
environment. Restoration (the "natural resource damage" portion and action)
is a separate issue. The commenter is correct, restoration ta1ces over where
remediation" ends. " .
"Resource damage recovery suit placed in jeopardy. .. (BSB 7)
-------
PART I - NON- TECHJ\1CAL COMMENTS
Response:
We do not believe that the proposed remedy places the NRD suit in jeopardy.
On the contrary, it gives the trustees a clear indication of the scope of the
remedial action to use as the baseline for restoration work.
Neither action - remediation or restoration - jeopardizes the other.
E.
I'fPACTS TO SILVER BOW CREEK
Comment 12E: Has the issue of cumulative impacts in the Silver Bow Creek/Butte Mine Flooding
operable unit been considered in the RI, FS, and Proposed Plan? (143)
Response:
Yes, the cumulative impact has been considered. That is one of the reasons
that Gold Book Water Quality Criteria (WQC)I have been used as a goal for
this project. Using Gold Book WQC as the goals dictates tha! water
discharged from a treatment plant meet all water quality goals, mcluding
support of a cold water fishery and drinking water.
F.
FUTURE LAND USE
Comme1ll12F-l:
How does this solution return the land to the minimum required .recreational
use,. i.e., backfill and revegetation? (152)
Response:
Superfund regulations do not require that a pit formed by hardrock mining be
returned to a minimum recreational use. The Montana Hardrock Mining Act
does have requirements for such things as waste rock dumps, leach pads, and
tailings ponds but not specifically for pits. The Act's variance for pits was
ruled unconstitutional by Judge Thomas Honzel on September 2, 1994.
Regardless, the reclamation issue is independent of the scOpe of this action,
which deals with groundwater contamination. This issue needs to be revisited
in the Active Mine Area operable unit, which will address reclamation
standards.
G.
GROUND COVER
Comme1ll12G-l:
.Stabilize mine waste and ground cover, i.e., grass, etc.. (1 34)
Response:
The stabilization of surface mining-related wastes was not part of the MFOU
RIIFS. Tbe stabilization of these materials is currently subject to State of
Montana regulations and is defined in MR's active mining permit.
This action does not include the reclamation of mine waste in the active
mining area. The Montana Hardrock Mining Act, administered by DSL, does
require this reciama[ion. DSL is currently working with MR to develop a
reclamation plan for the entire active mine area.
I On August 11, 1994 Montana Water Quality Bureau Cercular 7 (wQB-7) Standard replaced "Gold Book"'
standards as enforceable standards for \\'ater quality issues in the State of Montana. .
-------
H.
DUST
Comment 12H-1:
Response:
I.
WINTER FOG
Comment 12/-1:
Response:
PART I - NON-TECIL'1CAL COMMEI\'TS
Several individuals expressed concern about the blowing dust around the Pit
area not being fully addressed in the EPA plan. (BSB 4-M. BSB 4-J. / 13,
/42)
The action does not address blowing dust which we believe is independent of
the groundwater problem being addressed through this action. Dust problems
are handled through the DSL operating permit and reclamation program.
"We understand that winter fog from the Berk£ley Pit caused a pilot to be
unable to land at the Bune airport three years ago and that he was
subsequently killed after running out of gas enroute to another airport. How
does EPA propose to eliminate this type of permanent nuisance with a remedy
that will eventually widen the pit warer to nearly 500 acres, an increase of at
least two times over thar present },,'hen the cited accident took place? (G 2)
EP A and the State have no evidence that the incident was in any way related
to fog from the Berkeley Pit. EPA and the State do not plan to eliminate any
potential fog problem. There is a question of how much the Berkeley Pit will
contribute to winter fog. A Masters thesis paper prepared by Dave Klemp of
Montana Tech (May 9, 1994) concluded that the Pit does not contribute
significantly to fog formation. The Pit is also frozen over during the months
of December through March, which precludes fog formation for most of
winter.
J.
~mHES REPORT TO ENVIROJ'\~fENTAL QUALITY COUNCn..
Comment 121-1:
Response:
One individual requesred that "the Montana Department of Health and
Environmental Services make periodic reportS to the Environmental Quality
Council on the progress of the cleanup of the Berkeley Pit and the protection
of alluvial aquifers underlying the Silver Bow Creek Superfund Site. in
accordance with House Joint Resolution 20. (BSB 7)
MDHES will, upon request, respond to any Environmental Quality Council
(EQC) request for reports on the Berkeley Pit, MFOU, or any other issue.
Further, MDHES (through the monitoring program) will be preparing yearly
reports, which will be available to the public, on the data (water quality and
levels) with the State's interpretations on water flows and updated/future dates
for approaching the Pit System CWL.
-------
PART I - NOS-TECH!\1CAL COMMENTS
3.13
I:\"NOV A TIYE TECI£'iOLOGIES
Appropriate new technologies should be developed and used as they become
. available in the cleanup of the Pit. (T 1, BSB 12-K, / 31, / 22, / 28, / 24, /
16, /15, G 1, BSB 8, BSB 7, BSB 6, BSB 5, BSB 4-P, BSB 4-K, BSB 4-/,
T 5, / 51)
Commenr 13-1:
Response:
Comment 13-2: -
1)
2)
3)
Response: 1)
Comme1l113-3:
The ROD specifies that a technology reevaluation be undertaken when the
Berkeley Pit reaches the 5,260-ft level. This does not preclude independent
evaluations in the meantime. EP A and the State are open to amending the
ROD to employ' new technology if the technology meets all water quality
standards and is proposed collectively by the PRPs and the developers of such
technology .
The ROD should require the use of innovative technologies to supplement or
replace the hydroxide plan! and ensure that the 8best available 8 proven
technology is used at the time of implemenration, thus avoiding the problems
with hydroxide precipitation, such as: .
Sludge disposal in the Pit or new repository;
Future contamination from leaving billions of gallons of poison water
in the Pit,' and
The loss of the ore body, an enormous economic resource made i1l10 a
long-term communiry liabiliry. (BSB 2, T 8)
EP A and the State will encourage the use of new and innovative
technology which reduces potential problems associated with
hydroxide precipitation sludges. However, we will not require the
PRPs to use new technology if the costs are considered to be excessive
as compared with existing convention treatment technology that meets
discharge standards. A large ponion of the costs related to this
project are associated with sludge handling and disposal. We are
hopeful that technology is demonstrated that significantly reduces
sludge handling and disposal costs, thereby making the new
technology cost-effective.
2)
Under the plan outlined in the ROD, approximately 55-billion gallons
of contaminated water will be stored in the Pit. We believe that this
water will not pose a threat to human health and the environment
because it will not be allowed to rise above the CWL.
.3)
The economic impact of the flooding ore body is outside the scope of
the Superfund decision-making process.
Use of new technologies, regardless of cost. (G 2, BSB 12-D, / 19, / 14, 123,
BSB 7)
-------
Response:
Comment 13-4:
Response:
Comment 13-5:
Response:
Comment 13-6:
Response:
PART 1- NO~-TEClL'lCAL COMMENTS
See response to Comment 13-2, Section 3.13.
EPA should create a partnership with the PRPs and the County to set afirm
goal to develop a comparable remedy of equal effectiveness thaI is sensitive to
cost. (BSB 2. T 8)
EPA and the State are not planning to specifically form a partnership with the
PRPs. However, EPA, the State, and the PRPs are members of the advisory
committee for the DOE Resource Recovery Project, which is demonstrating
several innovative technologies using Berkeley Pit waters. The ROD also
requires a reevaluation of the remedial technology when the water level in the
Pit reaches the 5,260-ft level.
ARCO generally agrees with the treatment technology proposer. for any
necessary post-mining "eatment plant, but would like to empJumze thaI the
"hydroxide precipitation with aeration process" developed by Dr. Huang at
Montana Tech is an innovative technology. Accordingly, this technology, like
many others underlying the remedy, will need to be continually evaluated as
the appropriate treatment time approaches. Again, the Plan would be bener
tailored t.o the realities of the Pit situation, and would bener serve the public
interest, if it emphasized that flexibility and ongoing evaluation would be
necessary for treatment plant maners. (PRP 1) .
EPA and the State have emphasized flexibility in the methods of inflow
control, bedrock aquifer withdrawal points, and treatment technology in the
ROD. The ROD also requires a reevaluation of technology when the Pit
water level reaches the 5,260-ft level.
Regarding innovative technology and timing, EPA should go forwardfrom
today, not backward from the year 2022. Here is a plan thaI most of Bune
would likely find acceptable. Bune-Silver Bow County has asked EPA to find
research dollars in their S.I. T.E., Site Program. or another of their research
programs. It could be used to help come up with newer cost-effective
technologies. Adding dollars to DOE funding of the Resources Recovery
ProjeCt of Montana Technologies Company in Bune, would mean technologies
could be tested in a shorter time period. One idea is to have the projeCt send
out a call internationally for new technologies. Let competition and market
forces prevail. Interested companies andlor MSE could test their ideas. EPA
could require that within the following jive years, a pumping plant be
designed and construCted. Within seven or eight years, we could have clean
water running down Silver Bow Creek. (1'9, G 2, BSB 14, BSB 6)
EP A and the State presently plan to pursue additional federal funding for
technology development programs for the Berkeley Pit. The ROD does not
require specific technology development and demonstration except for the
reevaluation of technology when the Berkeley Pit reaches the S,260-ft level.
This does not preclude such program funding in the future independent of this
ROD and subsequent enforcement action. EPA has, however, funded
-------
Comment 13-7:
Response:
Comment 13-8:
Response:
Comment 13-10:
Response:
Comment 13-11:
PART I - ~ON-TECHNICAL COMMENTS
numerous projects through the Mine Waste Pilot Program coordinated by
MSE and Montana Tech. This program, as well as the DOE Resource
Recovery Program, have the ability to test innovative technologies.
"We specifically want to draw attention to the Call for Acrion on innovative
technologies in Paragraph 3.1 in which the local government takes a position
that the RIfFS is defective because the remedial technologies were not
considered in combinations. It is preordained results for the arwlysis to have
been mlJde in the manner as ref/eCted in that draft document.. (1' 12)
EPA and the state disagree with the conclusion that the RIffS is defective or
that the results were preordained. We believe that the proposed treatment
scheme is the most straightforward, cost-effective treatment available. We
expect new technologies, variations of this conventional technology, and
combinations of technoJogies to be developed in the future. This decision can
be amended if such technology is developed and proposed collectively by the
PRPs and the developers of such technologies.
"Because of cost, EPA did not consider condensation or other newer
technologies that could be made available soon.. (1' 8)
These technologies were considered in the scoping portion of the FS. Some
of these technologies were rejected because of costs, which were considered to
be excessive as compared to conventional treatment costs. Relative costs are
considered to be one of the three criteria used for scoping of alternatives,
along with effectiveness and implementability. .
817re solution that's been proposed no matter what anyone says is the cheapest
and not the best. There are way better technologies out there ifwe would
look at these technologies and try to use some of those technologies. The best
thing we can do as a community without question is to figure out a way to
mine that water, take the resources from that water and, most impOrfanlly,
turn the water back to water. 17re most valuable asset in the Berkeley Pit
today, I believe, is the water. . (1' 5)
The term "best" needs to be clarified. There are technologies which may
produce less sludge, recover metals, etc., and may be considered "best" by
some people. EP A and the State believe that the proposed technology is the
"best" balance between costs, effectiveness, and implementability. All of
these criteria, including costs, are required to be considered in our evaluatioD .
of technologies. .
1 think that the onl)' way this problem is ever going to be solved is by some
independent third agency or some independent third body. 1 do not believe
ARCO and EPA are going 10 solve lhis problem. This problem is going 10 be
solved 11)' Metanetix, Montana Technologies Company, or some other similar
company. (T 5, BSB J 3)
-------
Response:
Comment 13-12:
Response:
Comment 13-13:
Re~ponse:
Comment 13-14:
Response:
Comment 13-15:
PART 1- SON-TEClU\lCAL COMMENTS
EPA and the State would be pleased if a third party solved the Berkeley Pit
problem and reduced costs of the solution through a market driven process
(Le., metals recovery for profit). As was previously stat"ed, EPA and the
State are open to new, innovative, cost-effective technology if proposed
collectively by the developers of such technology and the PRPs.
"Either putting the sludge in the Pit or creating a new tailings dump will have
serious, potentially harmful effects on both human health and the environment.
The goal should be to keep the production of sludge to a minimum. " (/ 51)
Management of. sludge from a treatment facility is not an overwhelming
obstacle. Sludge will be managed to eliminate the potential for harmful
effects to human health and the environment. However, the management of
sludge is a significant ponion of the expense of the remedy outlined in the
ROD. Reducing or eliminating sludge generation will reduce the overall cost
of the project. The cost savings associated with sludge reduction may
eventually make alternative innovative treatment technology cost-effective.
"MUlt ope of advertisement has the EPA, MDHES, and PRPs done so far for
the solicitation of innovative ideas for the Berkeley Pit toxic water issue - or
was this solicitation process given to only a select few for their ideas? - (/ 50)
EP A and the State did not solicit ideas for any type of technology during the
FS. The FS screening process evaluated technologies commonJy utilized for
these types of projects as prescribed by EP A guidance.
What ope of funding and inquiT)' mechanism for innovative ideas will the
EPA, MDHES, and the PRPs put into place for the solicitation of innovative
ideas? lffunding is available, could a panel of expertS, as well as people
from the community, mining, timber, agricultural, and recreational industry,
sit on a panel for the adoption or the declination of innovative ideas? (/ 50)
EP A and the State plan to pursue additional federal funding for development
and demonstration of innovative treatment of Berkeley Pit waters. These
types of removal and design programs usually include some type of
solicitation of ideas and a process for adopting or declining ideas. Hopefully,
local residents, as well as experts, would be involved in this process. EPA
has previously funded various treatment demonstration projects through
programs, such as the SITE Program and the Mine Waste Technology Pilot
Project. These programs are not designed specifically to address. Berkeley Pit
issues, but are designed to demonstrate treatment technology in general.
-The proposal to dump lime into the Pit and letlVt the accumulDled sludge
there forever ignores the technologies now available for treating the water.
Folks who maintain that ARCa has been given the 'cheapest' alternative make'
a good case here. EPA should be helping commwzitiesfind the latest
technologies to deal with their environmental disasters, notjusr the ones that
are cheapest fonhe responsible parties. - (/13)
-------
Response:
Comment 13-16:
Response:
Comment 13-17:
Response:
Comment 13-18:
Response:
Comment 13-19:
PART I - :\ON-TEClIl\lCAL COMME!'I.7S
We believe that sludge management is not an overwhelming technical obstacle
and that it can be managed in a manner that presents no threat to human
health or the environment. The technology proposed in the ROD to treat
Berkeley Pit waters is the most cost-effective, implementable, and effective
treatment technology presently available. This technology was selected using
the criteria set forth in the NCP.
"Everyone who has a plan should be allowed to prove their technology, and
we should start immediately to halt further degradation of the pit problem. 1t
should take no ,more than 5 years to choose the best plan and have that plan
in place. instead of allowing 28 years to pass before attempting to treat the
water. " (115)
There are programs available, such as the SITE Program, the DOE Resource
Recovery Project, and the Mine Waste Technology Pilot Project, where
developers of technology can demonstrate their technology. The ROD
requires that there be a reevaluation of technology when the Pit level reaches
the S,260-ft level. This new technology may be developed to the point that it
meets the Superfund criteria better than the existing conventional treatment
technology. We believe that the Pit does not pose a threat until the water in
the East Camp approaches the S,410-ft level. It is not necessary, therefore, to
have a treatment plant to treat Pit water until that time period. The ROD does
require immediate inflow control and treatment of that inflow.
Most of the technologies required to turn the present catastrophe of a highly
contaminated area into an asset for OUT community are currently achievable.
Now is the time in the Superfund process to put these technologies into place
for beneficial uses by this community and the State of Montana. (1 50)
We assume that the author of this comment is referring to metals recovery
processes. There are technologies available that could recover metals from
the Berkeley Pit waters. We believe, however, that the overall combined
cost-effectiveness, technical effectiveness, and implementabiJity are greater for
the conventional technology outlined in the ROD than the metals recovery
processes currently available.
"The EPA needs to allow competition and market forces to compete for
workable solutions. " (1 14)
We also believe that competition and market forces wilJ eventually allow for
innovative treatment technology to be developed for the Berkeley Pit. Sludge
management is a major cost for the selected technologies and technologies
which are able to meet discharge standards and reduce sludge management
costs are likely to be prime alternatives or additions to the conventional
technology outlined in the ROD.
One commenter asked if innovative technology hod to be proven by April 29,
1994. (BSB 4-C)
-------
Response:
Commenr 13-20:
Response:
Comment 13-21:
Response:
Comment 13-22:
Response:
PART 1- ~O~-TECIL'lCAL COMMENTS
No, innovative technology does not have to be proven by that date. EPA and
the State are willing to entertain any new technologies presented collectively
by the PRPs and the developers of that technology if that technology meets the
performance standards established for this project.
"The preferred alternative as proposed by the EPA and MDHES should be
unacceptable by this governing body and this community. We can't totally
rely on expert opinion on this issue because nowhere else in the world has a
cleanup of this magnitude taken place before." (ESB 4-G)
. The Berkeley Pit project is a large project, but wastewater treatment projects
much larger than this project are common, and mine drainage projects
approaching this magnitude have been completed (i.e., Yak Tunnel -
Colorado, Leadville Tunnel - Colorado).
"The County would suggest thai the ROD be wrinen to require the use of
innovative technologies to supplement or replace the hydroxide plant and
ensure that the best available, proven technology is used at the time of
implementation. Further, the ROD should require the EPA, based on a
thorough technology assessment and review over the next tWenty years, to
verify the suitability of the seleeted technology. The EPA should join forces
with the PRPs and set a goal to develop alternative technologies thai offer a
comparable remedy of equal effeCtiveness that is sensitive to cost. The ROD
should clearly allow for sufficient access to the Pit water and provide needed
indemnification from Superfund liabiliry for those parries interested in proving
the viabiliry of alternative technologies. In the absence of such provisions, it
would appear that any language in the ROD aboUt the possibility of using
innovative technology in the future is purely gratuitous. " (ESB 2)
The ROD requires that a reevaluation of treatment technology be conducted
when the water level in the Pit reaches the 5,260-ft level. Although
technology demonstration is not a component of the ROD, we believe that
considerable innovative treatment technology testing will occur before the
water reaches that level through one of several technology demonsttation
programs or through developers of such technologies. EPA and the State are
commined to pursue additional federal funding for the development and
demonsttation of innovative technology.
"Although the Count)' believes afirm schedule and trigger point should be
established to build a treatment plant, a greater goal is to develop an
alternative technology solution to preclude construCtion of a conventional
treatment plant. Even under the most conservative scenario for plant
construCtion, the County believes there is an ample window of opportunity to
develop reliable technology alternatives." (ESB 2)
We believe tf1a! ? ",,",.~.,t;""'~1 tteatment plant will meet the Superfund goal of
protecting human health and the environment; however, we also believe that
there is ample time to develop alternate technologies or improve on existing
-------
Commem 13-23:
Response:
Commem13-24:
Response:
Comment 13-25:
Response:
Commem13-26:
Response:
PART I - NON-TECHNICAL COMMENTS
conventional technology that may produce less sludge or recover metals
economically.
"A firm commirmem by EPA. MDHES, and the PRPs to investigaJe and
implement innovative technologies is needed to spur action toward this
developmem objective. " (BSB 2)
The ROD requires a reevaluation of innovative technologies when the Pit
reaches the 5,260-ft level.
The commemer suggests that, "for those who feel that other technologies
would be more appropriate, they provide to the responsible parties and to the
agencies proof, credible, sciemificfacts that show that the technology they are
purporting is both sciemifically sound and alleast as equally cost-effective if
not more cost-effective than what is curremly on the table. .. (1' 4)
EPA and the State also believe that to select an innovative treatment
technology there must be a strong scientific basis for that technology and the
technology should be cost-effective as compared to conventional technology.
1he commemer believes that in the 10 to 20 years that will ensue before the
large Berkeley Pit treatment plam needs to be built, there will be ample time
for additional technology developmem. (1' 4)
EP A and the State also believe that there is ample time for the development
and evaluation of new technology. The ROD specifies that a reevaluation of
technology be conducted when the Pit reaches the 5,260-ft level.
.Will the preferred alternative enJumce mining in our area or make less the
amoUnl of minerals that can be taken from this ore body by allowing the Waler
table to rise? Will the preferred alteT7llllive creale more or less jobs in our
community? Will the preferred alteT7llllive enJumce our community image as a
greal cleanup project that will have a multitude of institutional controls?
Controls thai could prevem the people of this community the benefit to utilile
a natural resource of clean water and easy accessibility to the mineral deposit
in our area. I would like to know if the EPA, MDHES, and PRPs are willing
to go the extra mile to turn our community imo a model of a highly productive
alternative project that could be used for future clean up projects allover the
world. In the past, there has been seed money for other projects in OUT
community by the PRPs. Would tM PRPs also provide seed monry to creale a
ptJMl of not only expertS, but also people in mining, agricultural, timber,
re.:reational and industry? 1his panel would decide on the adoption of
innovative ideas thai could be cost-effective and also a unique alteT7llllive 10 a
massive cleanup problem we are all now facing." (1 50)
We do not have replies to many of these questions and even if we could reply
the responses would have no bearing on the remedial decision because these
factors cannot be used as criteria in the decision making process. We do
-------
Comment 13-27:
Response:
3.14
SLUDGES
Commem14-1:
Response: .
Comment 14-2:
Response:
PART I - ~ON-TEC~1CAL COMMENTS
realize that allowing the water level in the East Camp to rise will probably
discourage underground mining because of the increased costs placed on
mining companies to dewater the mines and meet discharge standards. The
NCP does not allow this factor to be integrated into our decision. Mining
companies can still dewater the mines and apply for a discharge permit, but
they would bear the financial burden of treatment. The objective of
Superfund is to protect human health and the environment. Enhancement of
image and economic viability of a community is not an objective. Sometimes
image and economic viability are enhanced by completed Superfund projects,
but EP A and the State have no authority to force the PRPs or use fund monies
to specifically meet these objectives.
"The toxic water is a threat to the health of the people in this community. An
all out effort should be made now and develop technologies to recover
valuable minerals and to purify wharever is unusable." (1 44)
EP A and the State do not believe that a threat is posed to the health of the
people in Butte until the water level in the East Camp exceeds the S,410-ft
level. The ROD dictates that the water level must be kept below this level,
thereby never allowing the people's health to be directly impacted. Innovative
technology development, including metals recovery technology, is not required
under the ROD. The ROD does require reevaluation of technologies when the
Pit reaches the S,260-ft level. Development and demonstration of
technologies need to occur outside of the ROD and associated enforcement
process through programs such as the DOE Resource Recovery Project and
demonstration by developers of such technology.
The sludge should not be disposed of in the Pit. The Preferred Alternative
perpetuates and increases the problem instead of solving the problem. (T 12,
BSB 4-F)
EP A and the State believe that sludge disposal in the Pit should not be
discounted. However, additional study is necessary before disposal of sludge
in the Pit will be allowed.
If Alte17Ultive 7 is chosen, repository siting for Pit sludge must begin now.
Several repository sites have already been idemified in a 1992 study ("Mining
& Milling Waste Disposal Area Siting Study-). An off-site repository for
sludge will have unique requiremems. Each of the possible repository sites
already identified should be evaluated for possible sludge disposal. (BSB 3)
EP A and the State agree with this statement. Several of the repository sites
are in the active mining area and are convenient to the Berkeley Pit. We plan
to have the repository sited following the design of the inflow control and
Horseshoe Bend/tailings circuit integration. This siting process should stan
by 1996.
-------
Comment 14-3:
Response:
Comment 14-4:
Response:
Comment 14-5:
Response:
Comment 14-6:
Response:
Comment 14-7:
Response:
Comment 14-9:
PART I - NON-TECHNICAL COMMEr--'TS
Discourage EPA from simply moving waste (sludge) from one spot to another.
(151, BSB 5, T 1)
The plan outlined in the ROD caBs for placing sludge in a secure repository
or in the Pit (contingent on additional studies). We do not believe that this
constitutes "moving wastes (sludge) from one spot to another..
How. can a solution which increases the problem be lav.fuJ? (T 12)
EP A and the State believe the plan presented in the ROD protects human
health and the environment as required by the law and will ultimately reduce
the acid mine drainage from the present generation rate.
We would suggest to EPA and MDHES in their final decision-making that the
question of sludge disposal is best left until the final design is done for the
technolog)' for the final treatment and not try to be determined right now.
(T4)
We believe that this is a good suggestion, except repository areas need to be
identified in the near future. Several issues need to be resolved (see response
to Comment 8-2, Section 4.8) concerning Pit disposal of sludge and the
specific sludge characteristics before the Pit disposal option can be approved.
/ftreatment sludge was added to the Pit, it would dramaIically affeCt the Pit
sediment and the reaCtions occurring in the sediment and su"ountling
groundwater and perhaps deep groundwater. These possibilities should at
least be considered and preferably investigated in some detail in a pilot
experiment that could be carried out on site. (1 53)
Although we do not want to preclude disposal of sludge in the Pit, we agree
that these issues should be evaluated before sludge is placed in the Berkeley
Pit. The ROD specifies that the potential impacts be more thoroughly
evaluated before sludge disposal in the Pit is approved.
One commenter expressed dissatisfaCtion with the solutions of liming the
pollUted water in the Pit and creating sludge. This is not cleaning up the
contamination, it only serves to maintain or create another Superfund site.
(18)
EPA and the State believe the sludges generated by the technologies proposed
in the ROD can be managed without creating new hazards.
We realize that the Proposed Plan is generic and that the detailed construction
design will be done during RDIRA after signing of the ROD. However, we
recommend that the treaiment sludge disposal facility be designed to prevent
exposure of migratory birds to the sludge. This siudge will contain elewlled
metals and arsenic concentrations, and any warer ponding on the surface may
anraCt waterfowl and shorebirds. (GOV 1) .
RS3-SS
-------
Response:
Comment ]4-10:
~ :><~"Jnse:
Comment 14-11:
Response:
Comment 14-12:
Response:
Comment 14-13:
PART I - ~ON-TECH1'lCAL CO~IMENTS
Comment noted. Any repository would include a design to prevent ponding
and placement of surface soil precluding exposure to waterfowl.
The commenter generally agrees that sludge disposal location must be left
open and requests that this point be made explicit in the plan. The sludge
disposal question of whether sludge goes "into the pit" or "into a repository"
does not need to be answered today. Much more testing needs to be
performed in the future on innovative technologies, as well as pilot scale
testing on the hJdro~ide precipitation process design by Dr. Huang. The point
in time when tr~atment plant design aCtually begins is the best time to make
the detennination of where best to dispose of sludge. (PRP 1)
EP A and the State generally agree with this statement except that identifying
the location for the repository should begin in the near future. The specific
design of the repository should wait until the sludge characteristics are more
thoroughly evaluated. There are also several issues regarding disposal of
sludge in the Pit which must be evaluated before this option can be approved
(see Comment 8-2, Section 4.8).
The need for flexibility to accoullt for evolving innovative technology is
particularly pertinent to the sludge issue. Once sludge is placed in an our-of-
pit repository, the metals on the sludge will never be extraCted because of the
manner in which metals are bound up as metal hydroxides and the added costs
associated with extracting the metals. However, if the sludge is returned to
the Berkeley Pit, there is a much greater chance that metals will be available
for extraction in the future by an innovative technology and will become more
. concentrated as more sludge is ad4ed to the Pit. (pRP 1)
EPA and the State agree with this statement. However, this would not be a
major criterion used for evaluating the choice between landfilling sludge and
disposing of sludge in the Pit. Protection of human health and the
environment would be the major objective.
How long do you perceive that land disposal of sludges would be required
before new technology might be approved by you that produces no sludges?
How much area would be required for land disposal of those sludges? (G 2)
EP A and the State are uncertain how long a time period sludge disposal may
be required. We are hopeful that technologies that generate usable products
instead of sludges will eventually become cost-effective. We believe that it
will take from 1.25 to 2.5 acres of land per year to dispose of sludges
generated by the process outlined in the ROD, assuming a repository depth of
60 ft.
What long-tenn assurance does this plan provide the communiry that the
sludge generation associated with the prefe"ed alternative tre~nt
technology will not itself become another Superfund-rype problem down the
road? (G 1, BSB 5)
-------
Response:
3.15
PART I - NON-TEClThlCAL COMMENTS
The sludge generated from the selected treatment technology will be an
alkaline, lime-based material chemically similar to the tailings presently
generated by the mining operation. The daily sludge generation for a full
scale treatment plant will be only one to two percent of the volume of tailings
that is produced in the mining operation. Any sludge repository wiJI have to
be designed to reduce precipitation infiltration, leachate generation, and
leachate migration. It is likely that this repository would be built in the active
mine area which naturally drains to the Pit System. The Pit would, therefore,
act as a natural collection system for the minimal amount of leachate that
might ever escape from the repository. Any small amount of leachate that
would be collected would be treated in this facility because a treaunen~ plant is
necessary, regardless of the remedial alternative or CWL selected.
Commenr 15~ 1 :
WATER TREATMENT FACILITY
Response:
Comment 15-2:
Response:
Commenr 15-3:
Response:
Commenrl5-4:
There has always been an engineering, construction, and shakedown period of
about tWo years built into the Rl/FS. This period should be written inro the
order. (BSB 8)
Comment noted. On the basis of this and similar comments, the ROD was
written to require construction of a treatment plant, capable of meeting
discharge standards and maintaining the water level in the East Camp System
below the 5,410-ft level, to be completed four years prior to the projected
water level reaching the CWL as measured at the highest water level with the
East Camp System (presently the Anselmo Mine).
Commenrers requested assurances on the scheduling of the construction of the
planr. The proposed plans should documenr a firm schedule about the
conservative trigger poinr to planr construction to provide grealer assurances
that the eM. is never approached. rr 8, BSB 2, BSB 4-D)
See response to Comment 15-1, Section 3.15.
The EPA and PRPs should proceed with haste to develop and implemenr plans
and design criteria for a facility to treal contaminaled Waler before it reaches
the alluvial aquifers surrounding the Berkeley Pit. (BSB 7, 11, BSB 2. BSB
4-D, BSB 13, 113, 11, G 1, BSB 6)
See response to Comment 15-1, Section 3.15.
Ralher than wait nearly 30 years and hope and wish for new, inexpensive
technology for cleaning Pit water, and ralher than complain with 110 solution,
let's force new technology to come forward IIOW. There is nothing like a
deadline to get things off dead center. Competition, capitalism, and market
forces can bring forward the needed ,;;osl-iffc,;;;i.... .t:chnoiogy and get it up
and running within eight years. (BSB 14, G 2, BSB 4-N)
RS3-57
-------
PART I - ~OS-TECJTh1CAL COMMENTS
Response:
EPA and the State have set deadlines based on the CWL which is dictated by
the rate of flooding in the System. The ROD, therefore, emphasizes inflow
control because, by controlling and treating inflow, the time frame for
building a full scale treatment plant is delayed and significant monies are
saved. This strategy provides a significant amount of time to allow
development and demonstration of new technologies.
3.16
WATER ISSUES
A.
BEDROCK AQUIFER
Commenr 16A-l:
77u! Proposed Plan .writes ojJ" the bedrock aquifer as i"emediably
contaminated. "MIat are the proposed boundaries of the -written ojJ" bedrock
aquifer (3 dimensional) and what assurances does the community have thai
these boundaries will not change over time?
Response:
A map is attached to the ROD which defines the boundary for which the
"waiver" of State groundwater standards applies. The boundaries include
areas within the lateral extent of the underground mine workings in the East
and weSt Camps. Significant amounts of information are available which
outline the lateral extent of the underground workings in the East and West
Camps. The map depicts the areal boundary and is not three dimensional. It
should be noted that this "waiver- and the corresponding boundaries had to be
established regardless of the remedial option employed or the level at which
the Pit is maintained. No assurances can be provided that the boundaries will
not change over time because the final water quality in this area cannot be
predicted. The water quality should improve in some areas as the System
rises and this may decrease the area where bedrock water quality does not
meet state groundwater standards.
Commenr 16A-2:
On the issue of bedrock aquifer. EPA is suggesting thai it is impractical to fix.
and the commenter agrees. 77u! wells that are drilled at the Pit cost $100,000
each and we question whether this is the type of aquifer that is the source of
water for the community. (BSB 4-K)
Response:
EPA and MDHES acknowledge the comments. This type of aquifer is not
typically used to supply water to a large population because individual well
yields are generally small. There are, however, wells in the bedrock aquifer
which are large enough to supply smaller local needs (e.g., Hebgen Park
well).
Comment 16A.;3:
Initially. greater volumes ofwa/er were entering the Berk/!Iey Pit each day
than are at pre~ent, and less is expected in the julure. We understand this is
because the gradient decreases as the water rises. Anyone can realil.e thai the
balance of the contaminated bedrock water has to going S011U! where. Please
tell us where. (G 2)
-------
Response:
PART I - NON- TECH1'rlCAL COMMENTS
As the water rises in the Pit, the gradient decreases and the cone of depression
surrounding the Pit decreases. Some of the water that was originally draining
into the underground workings is no longer draining in that direction. This
water is being held in storage in previously unsaturated bedrock or moving
away from the East Camp System adding to the regional bedrock flow which
eventually contributes to the general Clark Fork basin flow. We believe that
the majority of this bedrock water is very good quality, but becomes
contaminated when it enters the underground workings. By raising the water
level, less clean water is allowed from the periphery of the System to enter.
the underground workings and the Pit and becomes contaminated. This fact is
borne out when looking at the bedrock water quality in wells at the periphery
of the East Camp which have good water quality.
B.
W AT£R QUALITY
Comment 16B-1:
Response:
Comment 16B-2:
Response:
Regarding the 25 billion gallons of toxic water now captured in the Berkeley
Pit which would be 56 billion before any is cleaned and discharged to the
creek about 28 years from now under the prefe"ed plan, to what beneficial
use is that water being applied? There is a fixed amount of water on this
earth. Why could 56 billion gallons be tied up in perpetuity? 17Iat is what
this prefe"ed remedy would do and that is unacceptable. (1' 8, G 2,113)
It is true that significant amounts of water will accumulate in the Pit.
However, the Superfund remedial process is designed to protect human health
and the environment and not to completely restore a resource. Natural
resource impacts are more properly addressed in NRD claims such as the one
now underway between ARCO and the State of Montana.
EPA's prefe"ed plan would divert the water from the Horseshoe Bend away
from the Pit, but that won't be cleaned for our use for many, many years.
Once in the Pit, EPA and ARCO say the toxic water cannot leave. /t is true
Silver Bow Creek. Metro Storm Drain is mostly dry through town, bUt thm
does not mean the water is not leaving. Berkeley Pit water can leave the Pit.
And contra')' to what EPA and ARCO tell us, there is strong empirical
evidence that it is leaving rhe Pit System. You don or need a hydrology degree
to understand that it would not have been possible for the Anaconda Company
to dewater the mines and the Pit ifwater could not move through the bedrock
aquifer. (1' 9)
-'
EP A and the State disagree that water is leaving the Berkeley Pit and there is
no evidence ("strong empirical" or otherwise) indicating anything but flow of
bedrock water to the Berkeley Pit within the cone of influence. The MFOU
RI fully supports this conclusion. Silver Bow Creek and the Metro Storm
Drain are outside the cone of influence of the Pit System.
-------
PART 1- r\ON-TECHNICAL COMMENTS
c.
BERKELEY PIT FILLING RATE
Commenr 16C-l:
Response:
Commenr 16C-2:
Response:
If the water level in rhe Pit levels off and stops rising, it should be assumed
that th£ Pit is discharging water and pumping should start immedialely. In
addition, the $25,000 fine should come into effect as th£ environmenr is being
degraded. A water budget is needed that addresses how much Waler needs to
be pumped out, ifwater is leaking out. It is important to realize the difficulty
in proving that water is exiting the Pit. and not from some other source. In a
system monitored b)' people, people and science can and do 11UJke mistakes. A
contingency plan must address this real possibility. (/1, 13)
It should not be assumed that if the Pit stops rising that a discharge is
occurring. There is a possibility that with enough inflow control (including
upper Yankee Doodle and Silver Bow Creeks and East Ridge and other
surface drainages), decreased bedrock flow due to the constricted Pit cone of
depression, and increased evaporation from the larger Pit surface area, that a
homeostatic level may be reached in the Pit. There would still be a need,
however, for a permanent facility to treat Horseshoe Bend water. The Pit
would continue to fill if the pumping/treatment requirements for Horseshoe
Bend Water were stopped. As for the contingency plan, EPA and the State
have the ability to order the PRPs or use fund monies to take action (including'
construction of a treatment plant) if an unanticipated threat arose or was
discovered through the monitoring program.
People are worried aboUt induced infiltration where conramilUlled waler from
th£ Hill or in the Pit could travel sOUth and contamilUlle wells. People hope
thai th£ existence of conract berween Butte-Silver Bow County and ARca for
post Superfund well bans isn't being considered by EP A and preferring to let
th£ Pit fill. People worry thai putting off cleaning Pit waler for up to 28
years will affeCt the ability to get oth£r sites cleaned up soon; for example,
stream bed sediments in Silver Bow Creek. rr 9)
We believe that induced infiltration is impossible south of the Pit. The entire
alluviaJ aquifer would have to be drained, including the draining of Blacktail
Creek, before this induced infiltration could occur. InstitutionaJ controls will
be necessary for the bedrock aquifer regardless of whether the Pit is allowed
to fill or if it is drained. The selected remedy will prevent the migration of
contaminated water from the MFOU towards the Summit VaJley. The
monitoring program is the constant check on the findings of the MFOU RI.
The ability of EP A and the State to respond to unknown/unforeseen issues is
not compromised by the selected remedy. The ICs drilling private bedrock
wells is a response to protect human health from exposure to contaminated
water within the bedrock aquifer of the MFOU. This need for ICs is
independent of the selection of a preferred engineered remedy. If the System
is not aJlowed to fill further, then there would be no bedrock aquifer water to
"tap into" above 5,000 ft. With surface topography in the MFOU ranging
from 5,500 ft to 6,200 ft, this would mean drilling from 500 ft to 1.200 ft to
RS3-60
-------
PART I - NOS-TECIDJICAL COMMENTS
reach water. Few are willing to drill private wells to this depth and spend the
amount of monies this would require.
The selected remedy has no negative effects on other operable unit
remediation plans. We believe that the ability to clean up other sites,
including streambed sediments in Silver Bow Creek, is not impacted by
allowing the water level in the Pit to rise to the 5,41O-ft level. To prevent
impact to the other sites, the contaminated East Camp water must be kept out
of the alluvial system. This is accomplished by keeping the water level in the
East Camp below the CWL.
D.
DOMESTIC WELL WATER QUALITY
Comment 16D-1:
Why not stan now to clean up the Pit? You are not protectin~ my well or the
safety of our drinking water supply by allowing the water in the Pit to near a
critical level that could (no one knows for sure that it will or it won't) cross
into the alluvium aquifer. From my kitchen sink I can look out the window
and see Berkeley Pit. I look from there to the water and wonder how will I
know when and if the water will become unsafe to drink. Why must I live with
the threat of the water leaving the Pit and entering the alluvium aquifer? You
are a federal agency that is mandated by law to proteer me and my family
from such a threat. I only ask that you do what you are charged by law to
do. (l 23, /4/, /8, BSB 4-F, /33)
Response:
EPA and the State believe that, by keeping the water leveJ below the S,4lo-ft
level, the drinking water in the alluvial aquifer is protected. We beJieve that
pumping the Pit to a lower level is not cost-effective or the technically proper
response. If the Pit rises to the highest level po.ssible, it will thereby reduce
acid mine drainage production and total daily metals loadings to the System.
Any contamination (future or current) to domestic wells will Dot be a result of
contaminated bedrock aquifer waters from the MFOU. The citizens of Butte-
Silver Bow are not living with a threat of water leaving the Pit. EPA and the
State are protecting the human health and the environment with the selected
remedy.
E.
DRAIN TIlE PIT
Comment 16£-1:
Why doesn't the Proposed Plan call for draining the Pit? (G 1)
Response:
The Proposed Plan does not call for draining the Pit for three reasons:
1)
EPA believes that draining the Berkeley Pit is Dot DecesSary to achieve
protection of human health and the environment than letting the Pit
rise to higher level.
-------
PART I. ~ON.TECHNICAL COMMENTS
2)
Although the volume of water in storage is less if the Pit is drained,
the volume of water treated on a daily basis is considerably more (up
to 2 mgd more) and the quality of water to be treated will be worse
than if the Pit is allowed to rise higher.
3)
The estimated cost of draining the Pit ($350-450 million) is
considerably more than the preferred alternative ($50 million), even
though EP A believes draining the Pit provides no significant increase
in protectiveness.
F.
FLOOD TIlE PIT
Comment 16F-1:
Response:
Comment 16F-2:
Response:
G.
If flooding of the Pit as fast as possible is a good idea (which was suggested
by the State). why not use all available resources and fill it right away. such
as Silver Bow Creek, diverting Big Hole Warer, etc? (G 1)
If the reduction of the total volume of acid mine drainage was the only criteria
for selecting a remedial response, then the immediate filling/flooding of the
Pit would be selected. However, this is only one of five balancing criteria.
As the MFOU FS pointed out, filling/flooding the Pit faster increases the cost
of the remedy. We also believe that it is prudent to allow the Pit to rise
slowly so the impact of the rising bedrock aquifer can be completely evaluated
as it occurs.
If the detennination of what is best for the Pit is to let it reach the static level
or another level that would take years to reach, why not pwnp the Silver Bow
I
Creek into it for a couple of years? Not only to get closer to the permanent
solution, but also to perfonn reclamation on Silver Bow Creek while it is dry.
(16)
See response to Comment 16F-l, Section 3.16F.
WATER ESCAPING PIT
Comment 16G-1:
Response:
"] recommend that EPA and MDHES publicl)' acknowledge that the
asswnption that no water is escaping out of the Pit is exaCtly that: an
assumption. It is based on theory, not fact. 1 found the public documents ta
be misleading on this point, making it seem as though the hydraulic gradient
is a known measurement." (143)
The conclusion that l:Iedrock aquifer water is not leaving the MFOU but
flowing towards the dewatered Pit System is based on the science of
hydrogeology with large amounts of data to suppon this conclusion. The
science of hydrogeology is a long standing discipline based on research and
peer review. The statement that the findings of the MFOU RI are based on
"theory, not fact" is an unsubstantiated criticism that can be said about
anything.
-------
Comment 16G-2:
Response:
Comment 16G-3:
Response:
H.
PART I - NON-TECHNICAL COMMENTS
The EPA-ARCa plan wouldn't absolutely assure toxic water isn't leaving the
pit. Instead, it would provide new wells to catch it after the faCt. If ARCa
and EPA. are sure contaminated water can't leave the pit, how did Butte
miners pump all the water out of the bedrock aquifer? (G 2)
Butte miners were able to pump water out of the bedrock aquifer because of
the law of nature: water flows downhill. This same truth is what assures
EPA and the State that the selected remedy is correct.
After $10 million of study done over 10 years, ARCa and EPA. rely on
theories and their opinions in stating that water isn't leaving. 1hey do not
know what is happening at depth, no one knows for sure. Their prefe"ed
plan for the Pit and minejlooding is based on hydrology theory and guesses,
not faCts. The faCt is: Bedrock aquifer water is entering Silver Bow Creek at
the west end of town where the bedrock rises to the surface. We know this is
true because Silver Bow Creek has a gaining stream at that point. MDHES
Superfund manager for the Pit Mine Flooding au said that the water entering
the creek from the bedrock is poor-quality water. (T 9)
See response to Comment 16G-l, Section 3.16G. The bedrock aquifer water
entering Silver Bow Creek at the Colorado Tailings is bedrock aquifer water
outside the cone of influence of the MFOU (see Figures 6-8 and 14-1 of the
RI). This is neither East Camp or West Camp water. The bedrock aquifer in
the Priority Soils Operable Unit (PSOU) and outside the MFOU will be
investigated further during Phase n of RI for the PSOU. Its quality is not
impacted by the MFOU.
USE OF TREATED HORSESHOE BEND WATER
Co1T/lTU!nt 16H-1:
Since July 1986, MR has been operating open pit mining in rhe East
Continental Pit. In the milling process, they are using water imporredfrom
Silver Lake Pipeline. After the ore has been mil/ed, rhe outflow from the MR
concentrator is being pumped via the McQueen Booster Station up to the
Yankee Doodle Tailings Pond. Along the way, some of the tailings slu"y are
being released into the Berkeley Pit.
In essence, MR is using clean water from the Silver Lake Pipeline,
contaminating it in the milling process. and releasing it into an established
Superfund site. aearly, this situation must not continue and it IfUlSt be
addressed in the prefe"ed remedy. Not only does it contradiCt Superfund
criteria which calls for a remedy which will reduce the volume of
contaminanlS, it also contradiCts the criteria that calls for shorr term
effectiveness. MR must be required to treat its own eJJluent to State Water
Quality Standards and release it into Silver Bow Creek.
This holds true for all aspeCts of MR 's cu"ent mining operations. Ourent
mining practices must not be allowed to delay or compound the dean up
process.
RS3-63
-------
Response:
I.
PART I - NON-TECHNICAL COMMEI\'TS
One possible alternative with regard to a water supply for current mining
operations is to have MR negotiate for the use of treated Horseshoe Bend
water. (1 5)
The remedy outlined in the ROD has control of Horseshoe Bend water as one
of the major componentS. We believe that the most cost-effective method for
accomplishing this task is to integrate this flow into the tailings circuit. If the
PRPs choose to control the Horseshoe Bend flow in this manner, the amount
of Silver Lake water needed at the concentrator will decrease. See response
to CommentS 8-3 and 8-5, Section 3.8.
WEST CAMP W ATERrfRA VONA
Comment 16/-1:
Response:
Comment 16/-2:
Response:
Comment 16/-3:
Response:
Why was the contaminated bedrock aquifer water which enters Silver Bow
Creek at the end of the C:Jlorado Tailings not identified as a 'c::~ase of
contamination in the RifFS or Preferred Plan? Will a study be done to
identify how much of this water is of the (worst) East Camp quality and how
much is of West Camp quality? What exactly are the levels of contaminants in
the water over all? (You will recall it was identified by the State in a recent
public meeting as being of "poor quality"). (G 2. T 8) .
See response to CommentI6G-3, Section 3.16G.
What will be done with the West Camp water if the Metro Sewer is UNlble to
meet discharge standards due to contaminant loading from the mine
discharge? (G 1. G 2)
The West Camp water is very different chemically from the Pit System water
and is presently being treated in the Metro Treatment Plant. If the Metro
Plant is no longer able to handle this flow, the PRPs are required by past
orders with EPA to build a facility to treat this water. This treatment plant
has already been designed and these plans are available for public review.
EPA believes that the West Camp water may be compatible with the Colorado
Tailings groundwater and that these streams may be combined for efficient
treatment in the future.
What will happen if, at some future date. deep bedrock contami1UUUS are
transported iniv V"")~II~ u,"iuvium (oU/sUie lhe defined bounaanes of lhe
wrinen off aquifer). An example is the known vertical upgradielllflow from
the bedrock aquifer to the alluvial aquifer under the Colorado TaUmgs. What
data. assumptions. and calculations have been made to ensure thai the
contaminant transport cannot happen via this known hydraulic system or
similar undiscovered mechanisms? (G 1)
EPA believes that this cannot happen between the Pit System and the alluvial
system as long as we maintain the negative gradient between the presently
dewatered system and the alluvial system. The bedrock in the Colorado.
Tailings area has not been dewatered. There is continuous saturation from the
RS3-64
-------
Comment 161-4:
Response:
Commenl 16/-5:
Response:
PART I - ~O~-TECHNICAL COMMENTS
surface soils down through the bedrock. In fact, the ultimate remedy for the
residuaJ groundwater contaminants in the Colorado Tailings groundwater,
after the tailings removal is completed will probably include pumping and
treating the aJluvial groundwater and the stream. In the dewatered Pit System
there aJready exists a negative gradient between the Pit System and the aJluviaJ
system and our plan will be to continue to maintain this gradient. The
primary assumption is made to ensure that contaminants transport will not
occur revolves around keeping a gradient from the aJluviaJ system toward the
underground workings and the Berkeley Pit. .
Additional infonnation is needed on the West Camp to further define the water
level fluctuations over time. To protect the West Camp area from flooding, it
would be prudenl to perform additional monitoring in locations hydraulically
lower than the Travona and, at a minimum, reconstrUct Well 21 to obtain
more reliable data. (BSB 3)
EPA and the State acknowledge and agree with the comments. Currently,
there is weekly water level monitoring for the Travona, Emma, Ophir, and
AMC-21. The selected remedy caJls for four additionaJ monitOring wells to
be constructed in the "shaJlow bedrock" at those locations that had surface
discharge as a result of the uncontrolled flooding/filling of the mid 19605.
Further, a "new" AMC-21 monitoring well will be instaJled. Reconstruction
of AMC-21 is not considered feasible.
Can EP A assure residenls that "treared" Travona mine warer cOnlaminanrs of
concern - copper, zinc, cadmium, lead, etc. - are not going to become
remobilized downstream through forces of nature? (G 2)
Any disposaJ of sludges from the treatment of Travona Mine waters would be
regulated by current federaJ and State laws.
J.
OUTER CAMPILONG-TERM VIABILITY
Commenll6J-l:
Response:
'"
How can the division of the Mine Flooding OU from the non-priority soils
(oUler Camp seeps and flows) be justified when each is affected by the dJJm
hydrologic system (i.e., rising groundwarer levels resultlngfrom
discontinuation of pumping)? (G 1)
This point is well taken but not for the reason stated. The Outer Camp has
been at homeostatic conditions and has been discharging to the surface for
many years. It has not to this point been affected by the cessation of pumping
in the Pit System and will not be affected for many more years. The water
levels in the Outer Camp shafts have not responded to the discontinuation of
pumping as you have suggested in your question. The water level in the
Outer Camp is at about the 5,58o-ft level, which is over 500 ft above the
present level in the East camp system and 170 ft above the CWL. EP A and
the State do see the need to evaJuate the Outer Camp and the impact of the
existing discharge in its own right. In retrospect, it would have been better to
-------
Comment 161-2:
Response:
Comment 161-3:
Response:
Commem 161-4:
Response:
Commem 161-5:
Response:
PART I - NON-TECHNICAL COMMENTS
tie the Outer Camp in with the East and West Camp evaluations. The
proposed monitoring plan includes several monitoring points in the Outer
Camp and the potential threats existing in the Outer Camp will be addressed at
a later time. ..
What is the effect of Pit contamination on the outer part of the camp? (1 51)
See response to Comment 16J-l, Section 3.161. EPA and the State do not
believe there is an "effect" from the Pit System on the Outer Camp bedrock
aquifer system.
/s contaminated water entering groundwater and Silver Bow Creekfrom areas
such as the Green Lake seep, the Orphan Girl shaft, etc. in the Ourer Camp
area? (G 2)
There is a possibility that Outer Camp water is entering the Silver Bow Creek
drainage. This issue, which is unrelated to the Berkeley Pit flooding, will be
addressed as part of the Non-Priority Soils Operable Unit RI.
Some members of the community believe we should also callfor deep "quality"
monitoring wells at Rocker and possibly at a low poim mid-valley, as .
determined by depth-sounding equipmem. We understand depth to bedrock is
unknown in both locations. (BSB 6)
EPA and the State do not agree that an investigation on "deep" (in excess of
5,000 ft below surface level) bedrock aquifer water is needed. Further, EPA
and the State do not believe that the two locations sited in the comment would
have any coMection to the bedrock aquifer of the MFOU.
Long-term viabiliry of the plan was questioned by one pany in terms of vast
unknowns at the boundary of this operable unit with the Outer Cmnp (Non-
Prioriry Soils Operable Unit) (G 1)
The long-term "viability" (correctness?) of the selected remedy will be
continually checked by the monitoring program.
3.17
EFFECTS OF EARlHOUAKE ON BERKELEY PIT
Commem17-1:
Insure dam safety at Yankee Doodle Tailings Pond. There is a possibility thllJ
an earthquake could release saturated tailings from w Yankee Doodle
Tailings Pond imo the Pit. Thus, to provide public assurances, it would seem
prudem to provide a buffer of 10ft (to 5,340 ft) to accomm.odtue w tailings
thllJ could flow imo the Pit after a large earthquake.
Note: The anal)'sis done by HLA is not the worst-case scenario. Uquefactlon
is predicted to occur in the top 50 feet of the dam after an earthquake
equivalem to 6.5 magnitude. No effon was made to chiuaaeri1.e w materials
at the base of the dam, which former Anaconda Mi1U!raJ Company employees
RS3-66
-------
PART 1- ~O~-TECIL'I1CAL CO~IMENTS
have called casually deposited, random fill material (at the time there were no
dam design plans comparable to those now required under the active mine
permit). Several recommendations are made by HLA to "beef up" and
monitor the dam. These recommendations (which should be incorporaled into
MR's permit revision issued by DSL) also must be included as requirements in
thefinaJ ROD to insure future dam stability. (BSB 2, BSB 3, BSB 4-N, G 2,
BSB 8, 14, I 29, I 1, I 51, T 9, 145, I 36)
Response:
The HLA report was reviewed by the Dam Safety Section of the DNRC and
the Hard Rock Bureau of DSL. It was the consensus of the technical staff of
DNRC and DSL that the dam is currently stable, would be stable during an
earthquake (a maximum credible earthquake (MCE) for this area), and will be
stable during the dam's enlargement as long as the recommendations in the
HLA report are followed. As the HLA report evaluated the dam's stability
under a maximum credible earthquake for this area, there is no basis for
providing a "buffer of 10 ft" in the CWL to accommodate tailing flowing into
the Pit.
The comment that the report was "not the worst-case scenario" is arguably
incorrect. Although an earthquake of unlimited magnitude can be theorized,
the reasonable question is "what is the maximum credible earthquake" that this
area is likely to experience. The HLA report evaluated this question and then
evaluated the dam stability question accordingly. The HLA investigation did
evaluate the history of dam construction and existing dam conditions at depth.
Although the HLA report did discuss a possible liquefaction in the upper
portions of the dam, this liquefaction possibility was limited to the upstream
side (north side) of the dam in a limited area with no release of tailing from
the impoundment. The recommendations in the HLA report for expansion of
the dam, plus additional monitoring ~'equirements from DNRC and DSL, are
included in the ROD and associated monitoring program.
Commenr17-2:
Will the pumping and treatment plant for the Berkeley Pit waler withstand a
sizable earthquake? (G 2)
Response:
The selected remedy will require that the design of any treatment plant be able
to withstand an earthquake equivalent to the maximum credible earthquake for
this area.
3.18
ARCO'S RESPONSIBILITY
Commenr18-1 :
There were many commenrs on ARCO's responsibUities and commitmenr to
cleanup of the Berkeley Pit and future financial obligations. The commenrers
believe tlull EP.If must take a firm stand on enforcemenr of the Superfund law
and that ARCO pay for the cleanup. rr 13, I 40, I 8, I 21, I 33, G 2, I 33, I
38, BSB 12-E, I 18, I 12, BSB 7, 130)
-------
PART 1- ~ON-TECHNICAL COMME~'TS
RespC'!'!se:
EP A and the State expect ARCO and other responsible parties, including the
Montana Resources group, to pay for the cleanup of the MFOU. We expect
to use whatever enforcement authority is necessary to accomplish this goal.
3.19
MINI~G-RELA TED CO~fMENTS
The following comments have been divided into two groups: (A) potential problems with the
Continental Pit, and (B) present and future mining.
A.
POTE~'TIAL CONTINENTAL PIT PROBLEMS
Comment 19A-1:
"I recommend that the current mining operation be prohibited from
discharging contaminated waler from their mining activities into the Berkeley
Pit System. This current discharge is only adding to contamination 01 a
Superfund site thal is on the National Priorities Ust lor cleanup, which seems
to be in violation of the goals 01 CERCU." (1 43) .
Response:
The ROD will not allow such discharges, except for upset conditions and
during shut down of operations, before a treatment plant can be constructed.
These conditions should only be for a relatively short time frame and would
not appreciably add to the volume of water in the Pit.
The only surface waters flowing directly into the Berkeley Pit are the waters
from the Horseshoe Bend area and occasional "upset" waters from a failure in
the tailings lines. The origin or source of the Horseshoe Bend waters are part
of the ARCO vs. MRI lawsuit currently in litigation. EPA and the State make
no determination on the origin and source of these waters. However, these
waters become surface flows on and at the south face of the Horseshoe Bend.
ARCO and MR have "joint and several liability" for the cleanup remedy.
The selected remedy of the ROD requires that all surface flows be captured
and "treated."
Comment 19..1-2:
. "Montana Resources must stop dumping millions 01 gallons into the Pit. "
(1 49)
Response:
See response to Comment 19A-l, Section 3.19A.
Comment 19A-3:
~ about the East Ridge Pit; who is going to clean thaJ mess up when MRl
is through with it? (147)
Response:
The Continental Pit is hydraulically connected to the Berkeley Pit although
flow between them is impeded by soils and bedrock with relatively low
permeability. The Continental Pit, therefore. wi)) eventually flood as the
Berkeley Pit rises if it is not dewatered to enable mining to continue. The
ROD does not allow the water level in the Continental Pit to exCeed the CWL
because the Continental Pit is part of the East Camp.
-------
B.
PART 1- NON-TECH.\lCAL COMMENTS
Reclamation of surface disturbance is subject to the current permit closure
requirements. The DSL sets closure requirements in accordance with State
law.
Commi!nI J9B-J: .
PRESENT A.'1> FUTURE MINING
Response:
Commi!nt J9B-3:
Response:
Commi!nI J9B-4:
Response:
'"The clean-up scheduled should not be tied to the cessation of the mining
operation. The PRPs should start taking responsibility for the clean-up now." .
(I J)
The cleanup schedule is not tied to cessation of mining except for the
requirement to bypass clean upgradient water around the System. While
mining is active, this water is used in the process. It must be bypassed
around the System upon suspension of mining. We do not believe that bypass
of this water during mining is appropriate because MR would impon Silver
Lake basin water to replace this soft water. On the other hand, immediate
control of Horseshoe Bend water must take place regardless of mining. We
do believe, however, that this control can be cost-effective if this flow is
integrated into the tailings circuit. Likewise, the water level in the East Camp
Pit System must be maintained below the CWL regardless of mining activities.
One COmmi!nler stated that the eM. is the real issue. but we cannot change it.
so we should look for the next best thing, which is to come up with another
solution to the problem. This commenrer further stated that the elearicity
involved in pumping will be the major expense in EPA's presenl proposal-
EPA and ARCO have ignored this. /t is important that EPA knows that we
support aaive mining. (BSB l2-A)
The CWL can be changed if information is generated that,. by allowing the Pit
to rise to the 5,410-ft level, a threat to human health and the environment
exists. Information received by EPA and the State to date indicates that no
threat exists until the water level gets well above the 5,410-ft level. EPA and
the State recognize that pumping costs will be a major expense in the remedy.
This fact is recognized in the FS. Although EPA's and the State's main
objective is to protect human health and the environment from threats posed
by the mine flooding problem, we are cognizant of the benefitS to the
community that active mining contributes and we have tried to make the
remedy the most cost-effective solution possible.
One COmmi!nler stated that EP A must be very cogniulnt of the people who rely
on the mining jubs. The water level was addressed, while coming up with a
solution that will protea the best inlerest of Bune. He supports the resolution.
(BSB 12-H)
EP A and the State acknowledge the statements that the commenter supports
active mining and supports the BSB resolution. The prime objective of EP A
and the State is to protect human health and the environment from threats
-------
Comment 19B-5:
Response:
Commem 19B-6:
Response:
Commem19B-7:
Response:
Commem:
Response:
Commem19B-9:
PART I - NOS-TECH!\lCAL COMMENTS
posed by the mine flooding problem. We are also cognizant that the mining
operation is a valuable asset to the community. EPA and the State have tried
to design the remedy outlined in the ROD to be cost-effective ..iiJ
accommodate the active mining operation.
"/ also tesrified at the public hearing that I felt a strong statement should be
made in the resolution indicating the imponance of th£ conrinuarion of active
mining. As elected officials we are forced to walk a fine right rope when it
comes to making decisions in which we have to balance one of our main
economic resources against the safet)' of our community. Every attempt
should be made throughout the process to assure th£ continuation of active
mining. Every attempt should also be made to assure the economic, social
and environmental safety of this community. / regret Montana Resources did
not suppon the legislation / proposed during the last tWo legislative sessions.
This le;fslarion would have piOvided the imponant safeo' net this community is
now so desperately seeldng." (BSB 13)
See response to Comment 19B-4, Section 3.19B.
"Will the proposed plan end mining in Burte?" (151)
No, we do not believe that the Proposed Plan will end mining in Butte. See
response to Comment 19B-4, Section 3.19B.
A loss of future resources assessmem has been perfonned, i.e., dumping
sludge imo Pit could preclude julure mining. (1 52)
There are technical issues which need to be evaluated before disposal of
sludges in the Pit can occur, but EP A and the State believe that placing sludge
in the Pit will not preclude future mining.
The selected remedy (controlled flooding of the Berkeley Pit) and disposal of
sludges in the Pit do not preclude future mining. The flooding of the
Berkeley Pit and associated underground mine workings and disposal of
sludges in the Pit do not eliminate the "resource" (i.e., the mineralized ore
body) from being mined in the future. The flooding is a natural recharging of
the man-made dewatered area. There is nothing foreign in having to dewater
an area and remove overburden ("sludges") to mine a min~ralized ore body.
State when .after th£ suspension of mining. is. (137)
Suspension of mining shall be defined for this action as .when mill operation
is shut down (i.e., no concentrate production) for a six (6) month period with
concurrent economically minable reserves left that could be mined at a profit
when economic factors become more favorable."
1he Berkeley Pit and its su"oundings pose many environmemal, economic,
and social problems for the community of Burte. But, mining is our h£ritage
-------
Response:
Comment 19B-10:
Response:
Comment 19B-12:
Response:
Comment 19B-13:
Response:
'.
"
PART I - NON-TECHNICAL COMMENTS
and our future. We need to learn from our past mistakes and misuses. not
perperuare the indifference and shorr-sighted attitudes which led us up to this
point. The mining barons that bore into this hill. erected the smelters. and
ultimaJely poisoned the valle)' over the last century did so in the name of greed
and progress. Greed lined the pockets of the barons. the bosses. the miners
and the politicians and progress mode us blind to anything unsavory around
us. They knew that there would be hell to pay. Someday. Bur. someone else
would pay it. not they.
Well. we as a sociery grew up - a linle. We became a little less indifferent,
we learned from the past - a little. Your agency was created and you have a
job to do: levy whatever force is necessary to insure that this environmental
problem is eliminared. Yes. they will kick and scream and cry, "It's not our
fault!" Bur that was the bed the)' made when they purchased the Anaconda
operations." (I 18) .
EPA and the State believe that the selected remedy protects the Butte
community, Silver Bow Creek, the Summit VaHey. EPA and the State will
pursue enforcement of the remedy upon issuance of the ROD. EPA and the
State believe that the first stage of the remedy will be implemented in 1996
with control of surface flows.
Continuation of mining a major concern as is the ARCOlMRllawsuit. (BSB-7)
EP A and the State believe that the selected remedy will not cause a suspension
of current .mining. Regardless, EP A and the State must take action to protect
human health and the environment from the threat of the MFOU. The
ARCO/MRJ lawsuit was not a factor in the remedy selection or EPA and the
State action. ARCO and MR have "joint and several liability" (Le., they are
collectively and/or individually responsible) for the cleanup remedy.
Accordingly, and regardless of the outcome of the lawsuit, EPA and the State
hold both responsible for the liability/cost of the " cleanup. "
One commenter is concerned that we can affect the cu"ent active mining and
it is in our best interest to concentrate on the best type of cleanup possible.
(BSB 4-N)
EP A and the State believe that the selected remedy is the best balance of all
factors (Le., the nine criteria) and protects the Butte community, Silver Bow
Creek, the Summit Valley groundwater. See response to Comment 19B-4,
Section 3.19B.
"What is the contingency plan ifmining does not cease in 20061" (G 2)
The FS used the year 2006 as a date for suspension of mining as a baseline to
compare the costs of alternatives. The various tasks outlined as part of the
remedy in the ROD must be implemented regardless of when mining ceases.
-------
Comment 19B-14:
Response:
PART 1- NON-TEClU\1CAL COMMENTS
""'har role has present and furure mining played in the selection of this
alternative?" (G 1) .
Present and future mining plans have played only a minor role in the remedy
selection. EPA and the State believe that if mining was not ongoing, the
Agencies would still prescribe the same CWL, the same final treatment
scheme, and the same inflow control strategy. The only portions of the
remedy which are impacted by .the ongoing mining operations are:
1)
The proposed plan integrates the Horseshoe Bend water into the
tailings circuit because EP A believes that this alternative is much less
expensive, and while mine operations continue, as effective as
treatment of the Horseshoe Bend water in an independent treatment
facility; and
2)
The plan does not require upper basin clean water diversions because
of the need for this flow as makeup water in the mining operation.
-------
PART n - TECHNICAL COMMENTS
4.0 PART n: TECHr\1CAL COMMENTS
4.1
USE OTHER TECHNOLOGIES FOR TREATMENT
Commem 1-1:
The Metanetix technology is a technology that's been developing since 1980.
We hold 19 patenrs in the chelation area, 5 patents in the engineering area.
and we have seven patems pending. some ofth£m thal aCtUally penain to the
Berkeley Pit water.
This technology now has $35.5 million behind it in its developmem. We are
here in Bune on a cOmnl£rcial operation to take metals from th£ mine waler
and th£ Pit and conven these to metal products. We now. on our first scale of
this operation, are processing more than 500,()()() gallons a day, not too far
from the million that has been mentioned.
This technology has been tested for plutonium by Banelle Laboralory. Dutch
Independent Laboratories. and Baleman Corporation. Nalco Corporation
spent 10 and a half - or 11 months - and $10.5 million testing in Canadafor
cleaning of harbor sediments. The EPA came in. reviewed th£ study and in a
publication that is now oUlfrom th£ EPA. November 1993, saying that this
technology successfully cleaned conraminaled soilfrom heavy metals, soil from
a lead smelter removing the lead. the harbor bonom sedimems. sewage
sludge. and sewage sludge hash. 17ze technology is now removing the metals
from the Berkeley Pit Waler and the mines.
17ze Metanetix technology will .reduce the waste and be a pemuJ1U!m solution.
It uses all th£ metals that it retrieves for products and it cleans the water and
pUIS OUI clean water.. It was not .considered by ARCO. and in fact was
rejected by ARCO. (I' 7)
Response:
EP A and the State recognize that metals can be removed successfully using
this type of technology. We do not believe that chelation processes in general
are cost-effective as compared to the conventional treatment technology
proposed in the ROD. We are open to amending the ROD if the developers
of such technology and the PRPs collectively propose alternative processes
that meet the performance standards for this project. The ROD also requires
the reevaluation of technologies, including chelation of metals, when the water
in the Pit reaches the 5,41G-ft level.
Comment 1-2:
What 1 would like to do is turn to a section of the RIIFS and it is Section
5.1.10 titled. .Chelation Chromalography.. In this review, the PRPs
sponsored an analysis of technologies, which are available for treatmem of
acid mine Waler. Chelation Chromalography describes the type of separations
process. which is also being sold in the marla!tplace by competitors of
Chromalochem Company, such as Dow and Roman Hause. It is a recognized
technology. generically, and ChrOmalochem's palent is recognition of an
improvement of this technology in its cost-effectiveness and the cleanliness of
the water it produces. (I' 6)
-------
Response:
Comment 1-3:
Response:
Commem 1-4:
Response:
Commem1-5:
Response:
Commem 1-6:.
Response:
PART n - TECIL'1CAL CO!\l\fEIII'TS
See response to Comment 1-1, Section 4.1.
Paragraph 2 of Section 5.1.10 (Rl/FS) stares: "Recent research effortS have
successfully conducted laboratory scales tests on new synthetic resins to
improve the seleCTivit)' of the resins." (Jones and Grinstead. 1977). These
are not recent results which were reported or discussed in this analysis of new
technology. The statement goes on: "However, the new process has not been
demonstrated successfully on a pilot- or full-scale basis." 1hat semence is
incorrect. Roman Hause ana Dow chelating resins are deployed for treating
millions of gallons of water everyday as a well-known process. (I' 6)
We stand corrected. There has been deployment of chelating resins to treat
wastewaters. However, we believe that the application of chelation
chromatography in mine waste water treatment applications is in the study and
demonstration stage of development. We believe, therefore, that more work
needs to be done concerning the technical and commercial implementability of
this process. Regardless, the ROD requires a reevaluation of technology,
including metals chelation, when the water level in the Pit reaches the 5,260-ft
level.
The RI/FS says, "EffeCTiveness: Chelation Chromatography has been tested in
limited pilot skill application. Preliminary data indicate that this method of
ion absorption is not quanJitative, i.e., repeatable over time." 1 refer to the
paper 1 have submined to the record that shows this process was demonstrated
to be repeatable over time of 1,500 cycles of use. Developmem subsequem to
the publication of that paper have increased the stability and reproduced
stability in that produCT and that process. (I' 6)
We stand corrected. This information is included in the administrative record.
See response to Comment 1-3, Section 4.1.
The RI/FS says, "Preliminary data also appeared to indicate a degradation of
a thinfilm of chelating aging over time." That semence is inCO"eCT in thai
we demonstrated that after this 1,500 cycles of use, thai over 80 percem of the
original material's capacity still remains, so that the Chelation
Chromatography is not a material or a process which is sensitive to changes
or process variation. (I' 6)
See response to Comments 1-3 and 1-4, Section 4.1.
The RIfFS says, "It has not been proven on a large-scale operation and is not
technically feasible for treating 1.5- to 2.3- million gallons per day of waste
water during remedial action." Inco"ect. Chelation chromatography is in
use with other commercial resi~ on a project of that scale and we have
proposals outstanding for treatnrem processes that are in the tens 01 millions
of gallons per day in size. It is a scalable technology. (I' 6)
See response to Comments 1-1 and 1-2, Section 4.1.
-------
Comment J-7:
Response:
Comment J -8:
Response:
Q)mment 1-9:
Response:
Q)mment 1-10:
Response:
Comment 1-11:
Response:
PART n . TECHNICAL COMMENTS
The RIfFS says, -Implementation of this process technology would require
relatively moderate to high capital costs. - That is incorrect. The capital
coStS of a Chelation Chromatography system deployed for Berkeley Pit water
cleanup to the drinking warer stage of recovery of the metals is less than any
of the capital costs in any of the plans presented in the RIfFS, except for the
No Action Plan. (1' 6) .
EPA and the State have no information to prove that this point is true. We
assume that the capital costs for such a process would be similar to those costs
with technologies which have a relatively similar methods of water handling
and processing equipment (e.g., ion exchange columns) which aJso have
moderate to high capital costs.
The combination of Freez.e Concentration and Multiple EffeCt Evaporation was
not evaluared to determine if Bune 's dry, cold climaJe could be used to
advantage. Freez.e concentration was dismissed because of energy
requirements. No effort was made to evaluare the potential for using the cold
wearher thai dominates Bune for six months each year to reduce man-made
energy needs. Nor was any effort made to evaluare the possibility of using
sunny and semi-arid climate in Bune to see if solar energy could be used to
run (or supplement energy needed to run) the evaporation units required for
Multiple Effect Evaporation. (BSB 3)
TypicaJly the FS utilizes an anaJysis of energy costs based on the cost of
conventionaJ energy sources. 'Ibis is done for aJl treatment aJtematives
because there are usually too many variables which cannot be precisely
defined before the design period. It is especiaUy difficult to explore the
potentiaJ downside costs of innovative technology at this stage of analyzing
alternatives; we, therefore, use conservative cost figures which are well
defined.
The commenter included a paper entitled -Chemical Interactions in Sulfide
Mineral Tailings. - (1 53)
This paper has been included in the Administrative Record for this operable
unit.
The commenter included a paper entitled -Water Purification ProjeCt. - (1 50)
'Ibis paper has been included in the Administrative Record for this operable
unit.
The commenter included a paper, -SITE Technology Profiles Sixth Edition,
Toronto Harbour Q)mmission (Soil Recycling). - (BSB 9)
This paper has been included in the Administrative Record for this operable
unit.
-------
Comme1l1 1-12:
Response:
Comment 1-13:
Response:
PART D - TEClL'1CAL COMMENTS
The commenter included a paper, HPowershaft Limited. " (BSB 10)
This paper has been included in the Administrative Record for this operable
unit.
The commenter requested that a full treatability study be done with the
application of his process. (G 3)
The information presented by the commenter indicates that this panicular
process (GYP-SIX) may have some beneficial application to the treattnent of
the Berkeley Pit water. There are several avenues for demonstration of this
technology, including the DOE Resource Recovery Project and the EP A SITE
Program. .
4.2
~O!\1TORING PROGRAM
Comme1l1 2-1:
Response:
Comment 2-2:
Response:
Comme1l1 2-3.'
How can data generated from a comprehensive monitoring program ensure
treatme1l1 facilities are in place and operating prior to mine walers reaching
the eM? (1 37)
There will be yearly evaluations of the data from the monitoring program that
will calculate/predict when the CWL will be reached. Also, the RI
established a predictive model on future date predictions for when the CWL
would be reached. This model will also be updated yearly using the new.
data. This information, coupled with other triggers in the declaration for the
ROD, will ensure that treattnent facilities are in place and operating properly
prior to the CWL being reached.
A downjlow ofwaler over geologic time is evidenced l1y the Anaconda
Company maps (Mcaave, 1973, Figures K-1 to K-3) showing the position of
the zone of supergene enrichme1l1 which lay in the volume thai is now the Pit
itself, and still exists in su"ounding areas. These diagrams show a downward
extension of the enriched zone al faults and veins (e. g., to levels al an
elevation of 3,800 ft in the Middle Fault al the Kelley shaft), where there
would have been a downjlow of surface Waler. A downjlow of Pit Waler
(benealh the Pit) will still be prese1l1 and will be furthering the supergene
enrichme1l1 process and carrying reduced solutions with lower metal ion
conce1l1rations to grealer depths where enormous dilution will occur with
circulation to depths of 1-2 miles (Blackwell and Robertson, 1973).
"Contaminaled" waler from the MFOU may never injluence surface ground
Walers. (153)
EPA and MDHES acknowledge the commentS.
The comme1l1er makes the following recommendations regarding the
monitoring program.'
.
1ha1 a Pit sedime1l1 study be part of the monitoring program,'
-------
Response:
Comment 2-4:
Response:
'"
PART n - TECHNICAL COMMENTS
.
That a microbiological study be a part of the monitoring program,'
.
That there be detailed consideration of geochemical and
microbiological interactions in the Pit System;
.
That an overall monthly water balance be used to assess both
upgradienr warer control and recycle possibilities;
.
That s)'stem-outflow water quantities and patterns be assessed. with
some monitoring, to support any conclusions;
.
That in considering chemical trearment options, due consideration be
given to recycling of "I.'ontaminated" Walers, as well as the integration
of walers from different sources; and,
.
That all of the above activities be supported by an f&Wl "advisory-
and-review" panel consisting of persons outside the commercial
consultant organization. (1 53)
EPA and MDHES acknowledge the comments. EPA and MDHES received
several technical comments pointing out unknowns relating to the disposal of
sludge in the Pit and the Pit sediments.. These comments have prompted the
Agencies to reevaluate the Pit sludge disposal issue. Given the unknowns we
have decided that additional study related to the geochemical impacts of such
disposal must be done before any disposal of treatment plant sludge in the Pit
can occur. Although the scope of such investigations have not been
developed, we plan to include a wide range of "experts" to advise us in this
area. Many of the other comments are research/academic endeavors requiring
many years of investigation and likely requiring other investigations prior to
being settled and would not change the outcome of the selected remedy. EP A
and MDHES encourage the separate academic pursuit of such inquiries as
mentioned by the commenter.
The commenter suggests thai a monitoring system be established west of the
Bune Hill to identify any irregularities in waler flow and quality. The
commenter suggests the installation of wells in the following drainages: Bull
Run Creek; Oro FinolBeef Straight; Brown's Gulch,' Whiskey Gulch,' and
Gimlet Gulch/Rocker. The commenter also suggests upgrading the existing
gauging stations aI Colorado Tailings and Miles Crossing, the inclusion of w
Orphan Girl Shaft in future (MBMG) water level monitoring, and water level
monitoring in either the Nettie or the Norwich mines. (154)
EP A and MDHES believe that the addition of two bedrock monitoring wells
for the East Camp and four monitoring wells in the West Camp to the existing
monitoring network will be adequate to discern whether contaminated
groundwater could exit the MFOU. The Agencies have the ability and
authority to install additional wells if future data indicate that the present
monitoring system might be inadequate. Additional monitoring in the area,
-------
4.3
ros:r
Comment 3-1:
Response:
CoTn11U!nt 3-2:
Response:
Comment 3-3:
Response:
PART n . TECIl'\1CAL COMMENTS
suggested by the commenter, will be further evaluated in the Non-Priority
Soils RIfFS where the "Outer Camp" will be investigated.
There should never be $0 for No Action - No Action can still be the required
monitoring associated with an NPL site or institutional controls. This was a
BAD mistake. Read the NCP. (1 37)
This is not a requirement of the NCP. The publication Guidance for
Conducting Remedial Investigations and Feasibiliry Studies under CERCU,
October 1988, (OSWER Directive 9355.3-01) states that "[a]lthough a no-
action alternative may include some type of environmental monitoring, actions
taken to reduce exposure (e.g., site fencing, deed resttictions) should IlQ1 be
included as a component of the no action alternatives. Such minimal actions
should constitute a separate 'limited' action alternative." Monitoring costs
are available in the FS, and in retrospect could have been included under the
No-Action Alternative. However, we believe that the annual monitoring cost
of approximately $100,000 is inconsequential for selection of the remedy for
this particular project. These costs are relatively minor as compared to the
costs of the alternatives necessary to protect human health and the
environment and to meet the ARARs.
You cannot screen an option based on cost alone as was done for lhe people-
preferred alternative through pumping. Check Ihe NCP. (1 37)
This statement is incorrect; alternatives were never screened on cost alone.
They were screened on effectiveness, implementability, and cost. This
particular alternative was rejected because of our determination that there were
inordinately high costs as compared to other alternatives with no increase in
effectiveness. .
The COSIS in Ihe FS are in present value figures. This rype of financial
analysis rewards proposals lhat delay taking aCtion till the latest possible time.
This has lhe effeCt of pushing the costs upon jurure generations. The
Preferred Allernative should minimize lhe COSIS in Ihe future I1y having the
responsible parties pay lhe full bill now. Then, actions lhat reduce jurure
costs would be preferred. because it would lower the amount of money thilt
responsible parties would have to pUl up 10 cover future costs. (1 4)
The commenter is correct in the fact that the analysis presented emphasizes
the present value of money and rewards proposals that delay capital
expenditures and ongoing operation and maintenance costs as much as
possible. However,.since the NCP and Guidancefor Conducting Remedial
Investigations and Feasibility Studies under CERCU, October 1988 (OSWER
directive 9355.3-01) require that cost analysis be calculated in this way, EPA
will calculate the costS based on present value.
-------
4.4
CO~TROL IJ'I.'FLOW
PART n - TEC~'JCAL COMMENTS
Comment 4- J:
Response:
Comment 4-2:
Response:
The proposal to recycle Horseshoe Bend waler to the Yankee Doodle Tailings
Pond is a good stan to water control. but it also presents the possibility of
additional chemical control. There will be chemical (and biological) reactions
between the recycled waler and the tailings sediment and this could lead to a
positive OUlcome. An investigation of these reactions should be part of the
Comprehensive:\1onilOring Program. (1 53)
The incorporation of the Horseshoe Bend water into the tailings circuit will
require significant lime addition to neutralize the water and precipitate metals
so the water is suitable for concentrator use. MR has already incorporated
900,000 gallons per day of Horseshoe Bend water into the tailing circuit. MR
indicated to EPA and the State that additional evaluation needs to be done
concerning the incorporation of the additional 1.5 mgd from Horseshoe Bend.
This would include the evaluation of the resulting water quality for use in
their process or for discharge.
Besides the 2.4 mgd from Horseshoe Bend, what other potentially controllable
injlows contribute to the rising Pit waler? What control measures were
considered for these sources during the RiffS? What are the maximum
potential reductions ofinjlow that were calculated as part of the RiffS? How
much water can be divened from entering the Pit after mining ceases, thus
reducing the volume of water that needs to be treated? (G J)
The other controllable inflows into the System include Upper Yankee Doodle
Creek, Upper Silver Bow Creek, the East Ridge flow, other minor upper
basin flows, and the Silver Lake pipeline flow. Upper Yankee Doodle Creek,
Upper Silver Bow Creek, East Ridge, and other upper basin flows are about
1.5 mgd each and about 4.5 mgd is delivered through the Silver Lake
pipeline. Approximately 0.5 mgd are consumed in the MR concentrator
process, 3.1 mgd is stored as in-situ water in the tailings, and about 0.2 mgd
lost to evaporation.
All of the Horseshoe Bend water, the Upper Silver Bow and Yankee Doodle
Creeks, and the East Ridge flows can be diverted after mine closure. Based
on comments received from the public, these diversions after cessation of
mining are expressly required by the ROD.
EPA evaluated these inflows and the potential for reducing or eliminating
them. However, all of these flows are needed and used as makeup water for
the concentrator with the water rights owned by MR. Even though the Silver
Lake import is likely to be reduced because of the integration of the
Horseshoe Bend water, reducing the other upper basin clean water sources
would likely be replaced by increased Silver Lake flow because there are
minimum total and soft water needs at the concentrator. EP A, therefore,
-------
Cvnvnem 4-3:
Response:
PART n . TECIDJICAL COMMENTS
included only the Horseshoe Bend water as controllable water in the FS
during active mining.
The most critical aspect of the Plan thar requires cIarificarion and/or
modification surrounds requirements for control of surface water flow, both
before and after mining. The Plan in numerous places refers to surface warer
inflow as synonymous with and equal to Horseshoe Bend flow. See. e. ~. p.2
(referring to treatment of "surface water inflows (i.e., Horseshoe Bend)").
Apparently drawing from R1 /FS dara indicating that the average flow of
Horseshoe Bend is 2.4 mgd, the Plan seems to imply tlwr a total of 2.4 mgd
surface inflow must be treated regardless of future actuill surface flow rares at
Horseshoe Bend. . .
On this point, ARCO believes thaI EPA has anempted to set a rigid volume for
treatment and/or warer diversion where more flexibility is needed. EPA stares
throughour the Plan that it will maintain a flexible position with respect to
actual 17II!thods of controlling and trearing surface warers. See. e. i.. Plan ar
p. 2. In comrast, EPA's apparent designation of an arbitrary treatmem
volume is not only coumerproductive, bur ignores th£ evolutionary and
dynamic nature of the Berkeley Pit situation and su"ounding mining activities.
First, adoption ofth£ 2.4 mgdfigure assumes without arry supporting dara tlwr
th£ Horseshoe Bend flow will remain in a steady stare once mining ceases.
Since EPA's Plan assumes thar the predominant surface warer contribution
will be Horseshoe Bend water, the Plan needs to be tailored to the actual
amoum of Horseshoe Bend flow over time. For instance, upon suspension of
mining activities, ARCO believes that Horseshoe Bend flow may well diminish
significamly over time. Thus, by arbitrarily designating a 2.4 mgd treatment
requiremem, EP A may actually require that warer be pumped. up from the Pit
for treatmem where Horseshoe Bend flow is insufficient to accoum for this
volume. Such a program would increase dramatically remediation costs
without contributing to the overall goal of preventing Berkeley Pit overflow to
alluvial systems. (PRP 1)
The selected remedy does not require a 2.4 mgd of inflow control and
treabDent unJess an alternate inflow control site (i.e., a shaft) is used rather
than capturing Horseshoe Bend water. It mandates a permanent control and
treatment of contaminated surface inflow, including all of the Horseshoe Bend
water which is currently 2.4 mgd. It also requires permanent control and
treatment of subsurface flow in the Horseshoe Bend area and upgradient
diversions of uncontaminated flows after mining is suspended or the mine
closes. .
-------
4.5
WORK PLAJ'l ISSUES
PART n - TECHNICAL COMMENTS
A.
WORK PLAN TOO NARROW
Comment 514-1:
Response:
Comment 514-2:
Response:
The CDM Federal Programs Corporation work plan provided the objeCtives
and CERCLA and CFR provided the framework for the RIfFS. The RIfFS
were completed in an excellent fashion following these guiding documems;
however, 1 feel/he work plan has defined the problem of human health and
environmental risk from the Operable Unit 100 narrowly which, lherefore, led
to a RI thlll was 100 narrow in scope and recommendations Ihlll are
inadequare to protect human health and lhe environment from the threats
within lhe Mine Flooding Operable Unit.
The work plan limited the scope of analysis of dangers from .off-site emission"
to water only. This ignores a very imponant threat from airborne
contaminants. The only mention of this imponantlhreat to human heallh in
the RIIFS comes in relation to distUrbed soils during construction of remedial
efforTs, which was determined to be insignificant.
1 recommend that a new work plan be developed that is broader in scope -
thlll addresses not only the threat to groundwater contamination, but airborne
contaminants, habitat qualities, and aesthetic values. (14)
The commenter is correct in stating that the work plan addressed only the
groundwater issues. The potential dust problems associated with the permitted
mining areas and the mining operation are not evaluated in the MFOU RlIFS.
Potential dust problems associated with ongoing mining activities are regulated
by the DSL through MR's mining permit. DSL also requires reclamation of
disturbed areas after closure of the mine. This reclamation should curb any
potential dust problems associated with the active mine area. EP A plans to
work with the State (MDHES and DSL) in the development of the
specifications for this final reclamation.
The walls of Berkeley Pit are probably a significant source of airborne
contaminants. Different alternatives will affect whatever remediation might
eventUally be prescribed for the walls. Therefore, it is unwise to delay
considering the impact of the Pit walls on human health. Any mine flooding
alternative should consider the Pit walls at the same time. A study of the
effeCts of the Pit walls and recommendations for remediation should be
included in a new work plan. f! 4)
EPA and the. State believe that the Pit walls are not a source of significant
airborne contaminants. Air studies done in the active mining complex do not
indicate that the Pit walls are a significant source of airborne contamination.
-------
Comment 5A-3:
Response:
PART D - TEC~'CAL COMMENTS
Another imponanr area of consideration that was left our of the work plan
includes reclamation for aesthetic va/ues including re-establis~nl of habittJl
qualities. I believe that aesthetic values could be reclaimed by establishing a
mandate to study options for ground cover of exposed areas and anempt to
reestablish riparian areas. At the very least, the five naJural drainages to the
nonh, east, and west of the Yankee Doodle Tailings Pond could be redirected
around the site to prevenl the clean water in these streams from becoming
cOnlaminated. Redirecting these streams will create some aqUtJlic and
riparian habitars to replace the portion of the original Silver Bow Creek
channel thtJl was destroyed by mining activities betWeen the Tailings Pond and
the MR Concenlrator. (l 4)
The remedy outlined in the ROD requires that the uncontaminated upgradient
drainages be bypassed around the Pit System. The DSL mining permit calls
for the final use of the reclaimed mining area to be wildlife habitat, although
not specifically riparian habitat. We believe that establishing riparian habitat
in the active area is outside the scope of the MFOU action and should be
addressed either in the Active Mine Area operable unit or through the DSL
permit. .
B.
~"EED FOR FLEXIBILITY
Comment 5B-I:
Response:
As you know, ARCO was responsible for preparation of the Rl and FS for the
MFOU, which serve as the basis for the alternatives reviewed in the Plan for
addressing Berkeley Pit warers. Accordingly, ARCa is intimately familiar
with the various details, complications, and uncertainties involved in
developing a remediation plan for Berkeley Pit walers. In particular, ARCa
has grappled with the many difficult issues presented by the fact thtJl the
remt!dy will evolve over a course of decades and is largely dependenl upon the
timing and evolution of onsite mining activities and associtJled waler
discharges, as well as future Berkeley Pit filling rtJles. Due to this unusual
situation. ARCa believes thtJl the Plan must balance certainty and
concreteness against the inherent need for flexibility as the situation unfolds.
(.oRP 1)
EPA and the State generally agree with this statement. We recognize that
flexibility is needed to operate the mine. We openly ackno.wledge in the ROD
flexibility in the potential type of treatment technology 10 be used, the
withdrawal point of water into the System, and the use of the water. Specific
performance standards which must be met are: (1) control of Horseshoe Bend
flow or 2.4 mgd of other water in the System during mining, (2) control of
2.4 mgd post-mining water, and (3) the ability of any technology used to meet
"}" classification discharge standards.
-------
c.
HOW WILL WE KNOW TIlE PLAN WORKS
PART n - TECHNICAL COMMENTS
Comment 5C-1:
Response:
Comment 5C-2:
Response:
Comment 5C-3:
Response:
Comment 5C-4:
Response:
Comment 5C-5:
Since so much of the Proposed Plan is based on prediaive models. the plan
must clearly provide a definite safery factor. Human error of calculation or
operation must not produce an environmental catas"ophe. What if
EP A/MDHES predictions are faulry? Can remedial action be undertak2n
quickly enough to avert an environmental disaster? (1 51. T 1)
Tbe monitoring 'program is a significant aspect of the selected remedy that
constantly checks the correctness of the remedy. If new data collected during
the monitoring program demonstrates that the remedy is not protective, the
Agencies have the authority to react and take whatever action is necessary to
assure protection to human health and the environment.
We are dealing with complex hydrologic and geologic strUctures along with
countless other variables. What are our assurances when even the experts are
in disagreement about the dangers? (BSB 15. 136)
Tbe fundamentals of the selected remedy, such as keeping the East
CamplBerkeley Pit System as a contaminated water sink, the validity of the
CWLs, the accuracy of the science of hydrogeology, etc., are generally
agreed upon by scientists and engineers from EP A, the State and the PRPs,
and other experts in these fields. The selected remedy protects human health
and the environment. Should new data collected during the monitoring
program demonstrate that the remedy is not protective, the Agencies bave the
authority to react and take whatever action is necessary to assure protection.
The Butte Hill. of which the Berkeley Pit is part. is very complex. Do we
really Ioww what is going on? Are we relying excessively on models and
predictions which could befound to be inadequate? (151)
See response to Comment 5C-2, Section 4.5.
I recomn::,~.:! that some action be tak£n to increase confidence in the direction
of groundwater flow at depth in the MFOU. whether it be in deep well
drilling. sediment testing. or improved monitoring from existing wells and
mine shafts. Ifno action is tak2n to accomplish this. I recommend thai the
eM. be lowered for a greater margin of safery. (1 43) .
EP A and MDHES believe the findings of the RI are accurate, the selected
remedy is protective, and the monitoring program will gather the required
information to confirm these points. A lowering of the CWLs is not justified
at this time.
We need more water in this valley. We could have it if the contaminated
water were pumped and cleaned. To come to its opinions and preferred
RS4-11
-------
PART n - TECIL''ICAL COMMENTS
remedy, EPA and ARCO did what is called -modeling - of underground waler
flows. In these, they assume a constant head pressure. Scientists tell us thai
such an assumption would allow one to create any result they desired. EPA
must review their modeling and dismiss conclusions from it. rr 9)
Response:
As the MFOU is a man-made dewatered body, until it is recharged it will only
continue to serve as a sink. This sink will be maintained in perpetuity and
kept aniticially below the natural recharged level by the pumping and treating
requirementS. The Natural Resource Damage provisions in CERCLA and the
State's action in this aTea will address the issue of the lost resource.
Commenr 5 C-6:
Once the ROD is finalized, whaI tangible evidence will indicale thai the
problem has been solved? What parameters are envisioned as indicQ/ors of
success or failure? (G 1)
Response:
This project is different from other projectS because the Agencies are trying to
prevent a problem from occurring rather than remedying an existing
condition. The objective is to prevent the degradation of the alluvial system
by contaminated mine waters, and the primary indicators that the problem is
solved will be: (1) that the CWL will never be reached, and (2) there will be
no degradation of the alluvial system from the Pit System. The proposed
monitoring netWork will monitor both the water levels and the water quality
throughout the area. In other words, the tangible evidence will be the absence
of degradation.
4.6
PIT SEDIMENTS
Comment 6-1:
An important aspect of Pit System chemistry relales to the reacrions thai are
occurring in the sediment thaI is forming on the Pit bottom, submerged
benches, and previously connected old underground mine workings. The
sediment thickness at the Pit bottom (1993) was said to be possibly 200ft.
The sediment generally will almost certainly be becoming sulfidized by a
variety of chemical interactions, but there appears never to have been the
suggeslw/l VJ an lnve'>llglJlion of sedimenr in the Berkeley Pit, apart from my
own in 1993.
There is other evidence of suljidation acrually occurring in the Pit: Lead
weights used to anchor a sampling platform in the Pit were noticed to be
blackened on recovery (personal communication: J. Medish, MBMG). This
was probably due to the presence of a coating of PbS formed by sulftdation,' a
copper bar lowered onto the Pit sediment in September 19931uJd a sulfide
coating when recovered one month laler (personal observation).
Due 10 sediment sulfidation it is likely thai an oxidation-reducrion boundiJry
has already developed in Berkeley Pit sediment, near the sediment surface, so
thai the quality of Waler on the reduction side of the boundary will differ from
-------
PART II - TECHNICAL COMME!\TS
that in the Pit itself, which will be oxidized with respect to the HS ISOl
interface. An oxidation-reduction boundary could separate the dissolved ionic
species in the Pit water from those in the underlying groundwater (but
allowing downjlow, reduction and sulfidation) such that the lower
groundwater would be of beller quality due to the decreased solubility of metal
ions from a reduced sulfide environment. The oxidation-reduction boundary is
likely to have developed in the Pit sediment due to both the interaction of pore
water with underlying sulfidic minerals and solutions and the l~ly
microbiological reduction of sulfate to form sulfides. The formed process is
similar to supergene enrichment in sulfide ore bodies where descending
solutions from surface oxidation react with the lower levels of hypogene
sulfidic mineralization to form a region of enriched sulfides. Some ores,
which have been mined economically, are attributed to this enrichment process
(this includes pan of the original BUlle ore body as described by McGave
(1973). The proposition of oxidation and supergene enrichment of sulfide ore
bodies staned with the work of Whitenes (1855), and by the 1960s the
paragenesis of oxidized and enriched ores was well established. Accounts of
the process have been published by Bateman (1950) and Anderson (1955).
More recent treatmenrs of the hydrology and geochemistry of these processes
are presented by Brimhal, et al (1985) and Brimhall and Crear (1987), and
some related chemistry for tailings interactions was proposed by Rqbins
(1992).
A complete understanding of geochemistry in the Berkeley Pit needs
informalionfrom a sediment study. (153)
Response:
We acknowledge that there are several unanswered questions concerning the
sediment geochemistry in the sediment Pit including the impact of placing
sludges over that sediment. We believe that it is necessary to address some of
these issues before disposal of sludges can be approved.
Comment 6-2:
In the Rl no data were collected to characterize the geochemistry of current
Pit sediments. Consequently, the feasibility of sulfide precipitation was not
fully evaluated as a possible remedy. Pit sediments must be beller understood
before any consideration is given to sludge disposal in the Pit. (BSB 3, 153)
Response:
See response to Comment 6-1, Section 4.6.
4.7
INNOVATIVE 'i'ECHNOLOGIES
Comment 7-1:
The water treatment technology associated with the Preferred Alternative
creates substantial amounts of sludge that must be disposed of Alternative
technologies exist which recover metals, thus reducing the amount of sludge
requiring disposal. Why were these not pan of the Proposed Plan? (G 1)
-------
Response:
Commenr 7-2:
Response:
Commenr 7-3:
Response:
PART n - TECHNICAL COMMENTS
Many of the proven common metals recovery technologies, such as copper
cementation and solvent extractionlelectrowinning (SXIEW), would not
significantly reduce the amount of sludge generated. The amount of sludge
generated is largely dependent on the pH of the wastewater. With the Pit
water having a pH of 3.0, large amounts of neutralizing agents are necessary
to bring the pH up to a satisfactory level for discharge regardless of metals
concentrations. The basic conclusion of the FS concerning these metals
recovery technologies is that the value of the metals does not offset the capital
and O&M costs for the metals recovery facility and that there are still
significant wastewater treatment costs after the metals are recovered (and
significant amounts of sludge generated). EPA and MDHES are hopeful that
cost-effective innovative metals recovery technologies will be developed in the
future that will reduce sludge volumes. Some are being explored presently in
Butte. EPA and MDHES would encourage the development of such
technology and would amend any decision to include such technology if the
PRPs and the developers of the technology would collectively propose a viable
alternative.
Aside from ARCO touting age-old precipitation methods as the cleanup
instrument, new technologies which yield far bener results such as chelation
chromatography are currently employed to perform this type of cleanup. This
method could be used immediately, not 20 or 20 years down the road. (118)
See response to Comment 7-1, Section 4.7.
In the Rl/FS, each of the 19 remedial technologies was evaluated individually
and not in combinations. Thus, no effon was made to determine whether
cenain combinations of technologies might achieve some synergistic benefit
that does not occur with jusr a single technology. ]he County would suggest
that an evaluation of combined rechnologies could become pan of the
"innovative technology" research on waste remediation being done in Bune
through a variet)' of business ventures. In general, the County believes that
all of the questions that could be asked and answered through this evaluation
would lend increased assurance to Bune citizens that the "right" choice will be
made at the time of implementation. (BSB 2)
To a certain degree, technologies were evaluated in combinations. This was
done by looking at the ability of each technology for metals recovery and
primary and polishing treatment purposes. In fact, the remedy outlined in the
ROD calls for a combination of alkaline precipitation and aeration for primary
treatment, and reverse osmosis for polishing. We do agree, however, that
additional evaluation in this area is merited, especially in light of the
likelihood that new or innovative technologies may be demonstrated. A
reevaluation of technology is required by the ROD when the Pit level reaches
the S,260-ft level. EPA and the State will encourage the evaluation of
combinations of technologies in upcoming independent demonstration projects.
-------
Comment 7-4:
Response:
Comment 7-5:
Response:
Comment 7-6:
Response:
PART n - TECHNICAL COMMENTS
There has been much discussion and debate on the use of technologies for the
Berkeley Pit treatment. ARCO is in total agreement with the remedy as
specified by EPA and the State of Montana. The lime aeration technology that
was chosen for this remedy is indeed an innovative technology, and is an
innovative technology developed here in Butte at Montana Tech. Never before
has lime aeration been used in a cleanup treatment with the types of volumes
being looked at. rr 4)
EPA and the State believe that the selected technology is a reliable, proven,
and conventional treatment technology. The proposed treatment train is
innovative in that the technology proposed is tailored for this specific
wastewater in a two-step precipitation and aeration process.
Mechanical Vapor Recompression Evaporation - This report gives a cost of $2
to $4 per 1,000 gal/ons of water. I seriously question this dol/ar amount
when a few added energy enhancements could create a clean drinkable water
supply for $.50 per 10,000 gal/ons of water. Is this the cost of the plant thaI
will produce 1,000 gallons of water, or is this the cost to clean up 1,000
gallons of water? If the cost of $2 to $4 per 1,000 gallons is both whaI would
the cost be to treat the 1,000 gal/ons of water after the plant is construCted?
What type of eTU!rgy sources are needed for this type of plant's operational
cycle? How many gal/ons of water per day is this rype of plant able to
. produce? Could we see a set of plans on this ope ofunil? (/50)
Costs for treatment are routinely reponed on a .per 1000 gallon. basis. This
cost range covers a range of treatment unit sizes producing significant
quantities of water (usually in the hundreds of thousands, or millions of
gallons per day range). The costs include amonization, operational, and
maintenance costs of such a treatment unit. We do not have a set of plans for
such a unit.
Freeze Concentration - It states in this report the use of refrigeration to freeze
water. Did the expert on this process take into consideration the faCt thaI at
certain times of the year (due to our location), Mother Nature would freeze
this water for nothing? It is a faCt thaI very large bodies of Waler can be
frozen by Mother Nature in a short time frame. It takes larger amounts of
eTU!rgy to turn cold water into ice and also large amounts of eTU!rgy to turn ice
back into water. As I stated earlier, Mother Nature will do itfor nothing.
(/ 50)
No, we did not take into accOunt that the climatic conditions in Butte could
lower energy costs. We do not believe, however, that the differences in
climatic conditions (as compared to conditions in other parts of the country)
wiJ) be significant enough to drastically lower the cost of treatment.
-------
4.8
SLl1>GES
Comment 8-1:
Response:
Comment 8-2:
Response:
Comment 8-3:
Response:
PART n - TEClJJ\lCAL COMMENTS
Sludges from the proposed trearme1l1 process must be stabilized or they will
contain RCRA metals. (I 52)
The sludges produced by the treattnent process outlined in the ROD (aeration
and hydroxide precipitation) produce a stable sludge, and preliminary studies
have shown it to be nonhazardous waste. If a tr'eaunent technology is utilized
which produces a characteristically hazardous waste, all Federal and State
hazardous waste regulations must be met.
Alternative 6 is cheaper than Alternative 7 because it dumps the sludge and
brine waters from the treatme1l1 process i1l10 the Pit rather than dewatering
and landfilling the wastes in a RCRA Subtitle D landfill. Sludge disposal into
the Berktley Pit is not a proven technology (FS, 1994). Treatability testing
done by Qlnonie (1993) hasfound the sludge to be non-toxic. 11u! authors
assume the sludge is stable enough not to break down when placed in Berkeley
Pit's water. However, the report recommends more research be conducted to
determine if the sludge is stable enough to not break down in the Pit's murky
depths. Until it has been studied in more detail and conclusive results found,
the landfill is the only logical option. If it is found that the sludge breaks
down and releases metals, which would concentrate the c01l1amination of the
Pit's water, the sludge should be landfilled. (I 4)
Based on public comment, EPA and the State have decided to require
additional evaluations of this disposal option before it can be implemented.
We do not want to completely preclude this option, however, because there
may be significant benefits, such as in situ neutralization, as a result of this
disposal method.
Questions and concerns were raised about the sludges that would be generated
through application of the Preferred Alternative:
1)
If they are disposed of in the Pit, wouldn't they generate more oxygen,
thus perpetuating the acid-generating oxidation cycle?
2)
Will disposal of sludge into the Pit result in increased concentrations
of contaminants?
3)
Any remedy that seems. to make the problem worse by generating
sludges that will have to be dealt with by julure generations as another
Superfund-type problem does not seem like much of a remedy. (G 1)
1.
We do not believe that the introduction of oxygen in the treatment plant
sludge will perpetuate the AMD cycle. The dissolved oxygen in the sludge
will not add enough oxygen to the much larger Pit volume to appreciably
-------
Comment 8-4:
Response:
Comment 8-5:
PART II - TECID-1CAL COMMENTS
increase acid production, and the alkalinity and excess lime will more than
offset the acid generation.
2.
We do not know whether or not the placement sludges in the Pit will increase
the long-term metals concentrations in the Pit water. We believe that the
addition of excess lime, and the resulting increase in pH and precipitation of
metals, will more than offset the potential redisolution of metals in the
System. Because the Pit water is saturated by many of the metals, there
cannot be an increase in metals unJess the pH is further reduced regardless of
the level of metals in the sludge. However, if the alkaline sludge input was
stopped the continued input of acid underground waters could lower the pH
and dissolve some of the precipitated metals, potentially increasing metals
levels at that time.
3.
The Pit problem will have to be dealt with by future generations because a
treatment plant will have to operated in perpetuity. The management of
sludges will be done in a manner that will allow for final disposal and ensure
that future generations will not have to address them. Tbe sludges will be
disposed of in a manner consistent with Federal and State solid waste disposal
regulations.
Based on input from several mining professionals residing in Bune, it appears
thaI using the Pit itself as a hydroxide sludge disposal facility is unwise,
inefficient. and ultimately counter-productive. Much time and money will be
spent to raise the pH of the Pit water by adding lime in a treatment plant. It
is expeCted thaI the sludge produced will have a pH of 7. If sludge is
disposed of in the Pit. it will be re-solubilized. Thus. the same metals will be
treated over and over. Disposing the sludge in the Pit would also cause the
eM. to be reached sooner. For these reasons. disposing of any sludge in the
Pit is unacceptable (Alternative 6. Prefe"ed Alternative). (BSB 2)
Based on public cornrnent, EP A and the State are requiring such questions
associated with metals becoming resoluble, geochemical reactions, etc., to be
answered before any approval of Pit disposal would be made. We do not,
however, want to completely preclude this option because there may be
significant benefits, such as in-situ neutralization, due to this disposal method.
If sludge disposal were to occur in the Pit, a corresponding increase in the
flow rate treated would be required so that there would be no net increase in
the fill rate of the Pit.
Hydroxide precipitation with reverse ormosis polishing would generate from
500 to 1,()()() tons of sludge every day. Using the assumptions in Appendix A
olthe FS, about 0.2 mgd of sludge would result in a volwne of 2,867 cubicft
of sludge to be disposed of each day. The County estimDles thDI if this volume
of sludge were piled 12ft deep. it would require about two acres of land each
year for disposal. Thus. in 50 years. a IOO-acre repository would hold about
RS4-17
-------
Response:
Comment 8-6:
Response:
PART n - TECHNICAL COMMENTS
52,322,750 cubic ft of sludge that would have to be monitoredfor leaks in
perpetuity. (BSB 2)
As the commenter noted, a significant amount of sludge will be generated by
the treatment process outlined in the ROD. Monitoring will need to be
conducted for a long period of time. We believe that this program is very
manageable. The present tailings pond holds a larger volume of materials
than any potentjal sludge disposal facility, which will also have to be
monitored.
Preliminary testing of the sludge generated from this treatment technology
indicates that it will not be a hazardous waste but an alkaline, lime-based
material chemically similar to the tailings presently generated by the mining
operation.
The daily sludge generation for a full-scale treatment plant will be only 1-2
percent of the volume of tailings produced in the mining operation. Any
sludge repository will have to be designed to reduce precipitation infiltration,
leachate generation, and leachate migration. It is likely that this repository
would be built in the active mine area which naturally drains to the Pit
System. The Pit would, therefore, act as a natural collection system for the
minimal amount of leachate that might ever escape from the repository.
Building a Subtitle D RCRA repository would be expensive, given the need for
the installation of liners and leachate colleCtion systems. Also, a sizeable
amount of Count)' property would be needed for the acrual repository, as well
as additional acreage for a buffer zoae surrounding the repository. In
addition, the County may. aJ the request of the PRPs, assume responsibility to
monitor the repository and perform routine O&M (with PRP funding).
Although these activities are challenging, a non-Pit repository appears
preferable, given the disadvantages of using the Pit. IIJ alfY eve1l1, the FS
does not adequarel)' assess the rasks of siting and designing a non-Pit
repository, which seems to infer that a decision to use the Pit has already
been made. (BSB 2)
We believe that a sludge repository (Subtitle D facility) could be
accommodated easily within the active mining area and that the biggest factor
affecting the repository location is the future mine plans. The exact location,
which would be designated, and the specific design of the repository would be
done during the Remedial Design process following the ROD, The decision
to use the Pit as a repository has not been made. Public comment has
prompted EP A and the State to further evaluate the option. Additional
evaluation of the impact that the sludge may have on the Pit needs to be done
before this sludge disposal option is approved.
-------
PART n - TEClL'.1CAL COMMENTS
4.9
WATER TREATMENT FACILITY
Commenl 9-1:
. Response:
Plant construcrion/operations lead time. Most industry expens estimate a three-year
"shahdown" period is needed to mah a trearmenl planr fully operable. As for
linking this .shahdown" period to a point in time in the future, the County suggests
the following:
Currenrly, the Pit water level rises 25 ft per year; however, the predictive
model indicales this fill rale should decrease over time. In light of these facts.
the County recommends using the fill rale al the time the waler reaches 5,260
ft as the timing indicator to determine when planr construction should
commence.
For example, according to the model and dalafor the Preferred Alternative
6/7, the 5,260-ft level will be reached in the year 2009, and the fill rale that
year is expecred to be about 10ft. If the model holds true, then a three-year
shahdown period would eqUale to 30ft (3 x 10ft), and plant constrUction
would commence when the eM. reaches 5,310 ft (5,340 ft minus 30ft),
predicred to be in the year 2014.
Again, the actual fill rate when the waler reaches 5,260 ft will determine when
the planr constrUcrion would begin. If the fill rale proves to be more or less
than 10ft al that time, the timing of the shahdown period would be adjusted
accordingly.
Thus, the recommended level thal triggers action to establish a constrUction
schedule should be set al 5.260 ft and the treatment plant should be
guaranteed to be fully operable by the time the waler reaches the 5,340-ft
level. This schedule would leave 70 ft of free board below the currenr eM..
.1he 5,260-ft level is also within range of the original eM. 015,216 ft, which
is the conract betWeen the alluvium and bedrock. thus providing added
assurance thal the trigger poinr for acrion is sufficienrly protective. (BSB 2)
The Agencies have structured the ROD to meet the objectives of the program
outlined above because of public comment. The ROD will require
construction completion of a treatment facility, capable of treating a flow rate
that will keep the Pit at a static level, four years before the water level reaches
the CWL as measured at the highest point in the East Camp System (presently
the Anselmo Shaft). It should be noted that the water level in the Anselmo is
presently 40 ft above the Pit ~ater level. Using current projections, assuming
inflow control of 2.4 mgd starting in 1996, and assuming thatthe water level
in the Anselmo will be 20 ft higher than Pit water level, the present
construction completion date is projected to be in the year 2021. This
construction completion date will be updated every three years based on the
water level data generated.
-------
PART n - TECID\lCAL COMMENTS
Comment 9-2:
The importance of flexibility in surfac: '. .;.;.:;r ;';')r:v'0\' iriu.iilJt:1ll volwne direcrly
ties into the design and construction of any fuJure treatment plant. The
appropriate parties will be in a much bener position to design a useful, cost-
efficient treatment planr for Horseshoe Bend water rather than a potential mix
of Horseshoe Bend and other waters needed solely to reach the 2.4-mgd
figure.
EPA's Plan, as wrinen, seems to suggest that the parties must design a plant
in the relatively near future that accounts for a 2.4-mgd volume that may not
exist at the time the plant becomes operational. Again, ARCO has shown, in
developing the Ri/FS and accepting the general contours of Alternative 6/7
(which is more expensive than other feasible options presented in the FS), that
it is willing to work within a very conservative and proactive framework to
prevent Berkeley Pit water from reaching the CM. Yet, 'by mandating the
2.4-mgd inflow threshold, EPA threatens to require the parties to incur
unnecessary costs based on a .snapshot. analysis of water flows, where
absolutely no additional protection to human health and the environment is
afforded by these costs. (PRP 1)
Response:
Tbe selected remedy does not require a 2.4 mgd of inflow control and
treatment unless an alternate inflow control site (Le., a shaft) is used rather
than capturing Horseshoe Bend water. It mandates a permanent control and
treatment of contaminated surface inflow, including all of the Horseshoe Bend
water which is currently 2.4 mgd. It also requires permanent control and
treatment of subsurface flow in the Horseshoe Bend area and upgradient
diversions of uncontaminated flows after mining is suspended or the mine
closes.
4.10
WATER ISSUES
BEDROCK AQUIFER
A.
Comment 10A-1:
EPA has announced in public meetings that the Agency will be issuing a
waiver (as part of the ROD) for restoration of the contaminated part of the
bedrock aquifer. This decision means that no effort will be made to remediate
the contaminated portion of the bedrock aquifer because it is technically and
economically infeasible to do so.
This waiver will set a precedent lor Superfund cleanup on the aark Fork and
allow EPA to ignore one of the main criteria for cleanup: reducing W
volume, mobility, and toxicity 01 contamination. When EPA issues the waiver
as part of the ROD, it is assumed the requirements 01 -Guidancejor
Evaluating the Technicallmpraaicability of Groundwater Restoration.
(OSV,'ER Directive 9234.2-25) will be followed. (G 2, BSB 2, 113, BSB 6,
BSB 7, T 5, I 51, T 9, T 8, 143, I 37)
-------
Response:
Comment lOA-2:
Response:
PART n - TECHJ\lCAL COMMENTS
The County's concern is the specific language of this waiver. The County
would request full involvemeTll in the review of the documeTll. The County's
interest will be to ensure that a full evaluation has been done and thai no
linkage is made between the cOTllaminated bedrock aquifers and other aquifers
that would allow additional waivers in the future. In addition, the boundaries
of the contaminated bedrock aquifer must be clearly delineated on a map, and
explicit language must be included in the waiver to explain restrietions on
future uses of the cOTllaminated groundwater. (BSB 2, G 1)
EPA and the State recognize BSB's concern about the waiver of the State
groundwater standards. A map clearly delineating the area is included in the
Technical Impracticability Waiver concerning the boundaries r:-f the waiver
area. BSB will be involved in this issue and will be an activ.: participant in
the development of the institutionaJ controls required to go aJong with this
waiver. Specific restrictions and implementation of those restrictions will be
discussed during the development of the InstitutionaJ Control program.
Considerable alarm was expressed by several commenters aboUlthe Plan's
treatment of deep bedrock aquifer: .
.
The plan gives no assurances abOUl the dynamics of COTllaminated
warer over the long term in the deep bedrock aquifer, we just don't
/aww enough about it.
.
What we do know about old mining works in the bedrock aquifer
concerns some people with underground mining experience,' they refer
to "bad ground" to the east and southeast, where unpredictable water-
flow dynamics were always a concern to mining operations (G 1)
EPA and MDHES believe the information gathered during the RI is complete
and the issues adequately investigated. The monitoring program will continue
to collect data that will check the accuracy of the conclusions of the RI. We
believe that there will be little transpon of contaminants in the deep regionaJ
bedrock system because: (1) the rate of regionaJ bedrock flow is very slow,
(2) the relative size of the contaminated bedrock system is small compared to
. the regionaJ system, (3) the regionaJ system has a large attenuation capacity,
(4) the water quaJity in the periphery of the East Camp is quite good, and
(5) the water quaJity in the shafts throughout the area has improved as the
shafts have inundated.
We have also heard reliable reports of the "bad" groundwater where perched
groundwater is encountered in the undergrounds. MR personnel have
reponed similar phenomenon where perched groundwater is encountered and
quickly drained. This is not unexpected but poses no particular concern as far
as contaminant transpon is concerned. We expect these areas to become
resaturated as water levels come up; however, we do not expect Pit water to
-------
Comment IOA-3:
Response:
Comment lOA-4:
Response:
PART D - TEC~1CAL COMMENTS
be transported to the upper Silver Bow/Blaclctaii Creek alluvial system through
these areas because the gradient will always remain toward the Pit.
Based on the data in the RI. a critical saddle point in the top of weathered
bedrock exists near the southeast edge of the Pit at the 5.35G-jt level. Water
reaching this alluvium level could behave unprediCtably, i.e., short-term rises
in water level, due to the density differences in the alluvium and the weathered
bedrock, could potentially yield a short-term change of gradient for this
locale, thus allowing water to flow away from (and not toward) the Pit.
Therefore, the Count)' believes it would seem reasonable to consider this level
as a starting point to trigger action. (BSB 2)
EPA and the State disagree with the conclusion of this comment. While. we
agree that this change in stratigraphy could cause changes in rise rates, the
water levels in the alluvium at the groundwater divide south of the Pit are at
least at the 5,460-ft level and saturated down to the decomposed bedrock. Pit
water, therefore, cannot escape the System through the alluvium until the
water level in the alluvium gets much higher than 5,350 ft. We acknowledge
that there is a potential for the migration of water eastward from the Berkeley
Pit toward the Continental Pit, if the level in the Berkeley Pit gets above the
dewatering level in the Continental. Water will still not be able to get out of
the East Camp System, however, because the overall gradient will be inward
toward the Berkeley andlor the Continental Pits. Additionally, as part of the
monitoring program, a bedrock monitoring well is being installed in this area.
This additional bedrock monitoring well evaluated with data from existing
wells will further address the issue.
What is the quality of the bedrock llfJuifer in the middle of the valley, near the
airport? What is the groundwater quality at depth where the bedrock drops
off toward Rocker? Could a new industry using high volumes of water in
Butte or in Rocker cause induced infiltration to contaminate existing wells?
~~ .
The aquifers referred to in this comment are outside the influence of the
Berkeley PitlEast Camp System. The quality of water in the bedrock aquifer
near the airport is unknown. The depth of the alluvium in the that area is also
unknown, but probably in excess of 1,000 ft and no wells have been put down
to bedrock. The bedrock aquifer water quality north of this area is quite good
based on the results of water quality sampling done during the RI. We would
assume, therefore, that the water quality of the bedrock aquifer is very good
in this area. .
A water user with a well pumping such high volumes of water to cause an
-induced infiltration of contaminant- from the MFOU would first cause a
dewatering of the surrounding bedrock andlor alluvial aquifers (and an
associated loss to water well users in the influence of the new well). We do
-------
PART D - TECHNICAL COMMENTS
not believe that "induced infiltration" could be massive enough to draw
contaminated East Camp/Berkeley Pit water into these areas.
B. WATER QUALITY
Commenr lOB-l:
Response:
Commenr lOB-2:
Response:
/n the Proposed Plan there is the suggestion that there is an upjlow of deep
groundwaler from the bedrock inro the MFOU. PerhtJps a groundwaler model
was the source of that idea. but / wonde"r ifit is realistic. 7here are simple
aperimenral procedures that could be used here to add to a realistic water
balance. (/53)
EP A and MDHES believe there is upflow into the Berkeley Pit from the
surrounding bedrock (deep or otherwise) and this is believed to be based on
several separate arguments. There is a connection between the Pit and the
associated mine workings surrounding and "under" the Pit. Flow has been
observed entering the Pit from the current operations at the Kelley Mine
Shaft. The water level data from deep bedrock wells, such as the DDH wells,
support this belief.
/t is suggested that the Berk£ley Pit and su"ounding areas could become
enveloped by a sulfidic barrier such that the underlying groundwaler is in a
reduced condition where the metal ion concentrations will. be considerably
lower than in the Pit water. 1here is some evidence that this is the case
(MBMG data). /n the West Camp the 1Tavona shaft waler is sulfidic. and
although the groundwater at that location is more or less cross-gradienr to the
Pit. it shows that the condition of reduced groundwaler does exist. It also
suggests the use of West Camp water (or similar Water) to su/fidise other
waters in the system.
Water samples from the Belmonr mine shaft. which is downgradienr of the Pit.
show metal ion concenrrations considerably lower than in Pit Water. Water
samples pumped from the upgradienr Kelley Mine shaft (MBMG. 1992)
indicated that both pH and E decreased with depth (pH: 5 to 3. and E :380
to 360m V). which could mean that the Kelley is isolated from the Pit by a
redox (ox/redlox) barrier. Cation concentrations in the Kell~ appear to be
generally higher than in the Pit. but this is probably due panly to enhanced.
and localized oxidation caused by a more elevated temperatures which exist in
the deeper Water levels. (/ 53)
As pointed out in the previous response, the Pit is not isolated from its
associated mine workings; and, flow bas been observed entering the Pit from
the current operations at the Kelley Mine Shaft. Also, it should be noted that
the current operations at the Kelley Mine Shaft bave water rights to
appropriate water from the Berkeley Pit by way of these connections.
RS4-23
-------
Comment 10B-3:
Response:
Comment 10B-4:
PART II- TEC~1CAL COMMENTS
Another consideration is the influence of the MFOU groundwater on deep
groundwater, and the fate of that water. A complete water balance on t~
whole Pit System is not reponed, but could add perspective to understanding
the likely outcome of any chosen remedial action. For example, the maximum
average monthly (June) precipitation of 2. 42 inc~s in the catchmenr of the Pit
system (aboUl 19.5 square miles) could result in the generation of about 27
mgd of water (data from Borz. 1969), which would have been accommodated
(pre-mining) by stream flow. groundwater flow and evapotranspiration.
Presenrly the only additional water inro the system is 6.2 mgd of Silver Lake
water to t~ MR concenrraror. In all months other than June t~ precipitation
is less than in June by more than t~ 6.2 mgd from Silver Lake. Aetual
measuremenrs of monthly evapotranspiration would be more ac,:urate than
using calculations such as the CFR 40 Ch.1 (7-1-93). Upgra.i".,ll Waler
control, as in fact panly exists with the Yankee Doodle Tailings Dam. should
be carefully integrated with recycling, to result in the appropriate water
balance for contamination control. (1 53)
The commenter is correct in the calculation of total maximum daily
precipitation input into the upper basin (27 mgd). As is pointed out, this is
not the total ending up in the Pit, however, because of the evapottanspiration
(ET) losses. ET measurements would add to the knowledge base concerning
the water balance in the basin, but we do not believe that conducting ET
measurements would help in inflow (upgradient) conttol decisions. Only
certain upgradient surface flows are conttollable. These have been identified
and the relative flow rates assessed. Precipitation entering the alluvial or
bedrock groundwater system cannot be kept out of the Pit System very
efficiently,. except at the alluvial system discharge point at Horseshoe Bend.
The likely mediation of sedimenrary reactions by microorganisms depends to .
some extent on the presence of organic carbon, although t~re are ot~r
energy sources that suppon the wide range of organisms that are encounrered
in t~ reduction of sulfate to sulfide. To date it appears that no analysis of
Berkeley Pit water (or any ot~r waters in t~ MFOU) has included t~
determination of organic carbon, although it is likely to be presenr from
various sources, which include a huge vegetated water catchmenr (greater
than 5 square miles) to the north in which humic substances are cenainly
being generaled. Algal blooms which occur regularly in the water al the
North of the Yankee Doodle tailings are evidence of organic marerial, which
in that region at least could suppon bioreduction of metal ions. Recycle of
conraminated water to pan of this tailings area in order to form sulfides is
worth consideration. In t~ Pit itself it has been said (without any evidence)
that there is not likely to be any bioreduction due to the -extr'erM- conditions
in t~ water (acidity 4nd metal ion concenrrations). This is not co"ect, and
in similar mine waste pits. such as at Rum Jungle in Australia, reducing
organisms have been reponed at deep submerged sedimenr (Baby, et al,
1980). (1 53)
-------
Response:
Cmnment10B-5:
Response:
PART 11- TECH1\lCAL COMMENTS
The Agencies have chosen a technology to implement which we believe is the
most cost effective proven technology available (aerationlhydroxide
precipitation). The potential for bioreduction of metal ions in the System has
not been evaluated by EPA and the State. The use of natural, in situ or unit
process sulfide precipitation is an intriguing innovative technology worthy of
additional research. The ROD mandates that a reevaluation of treatment
technology be conducted when the water level in the Pit reaches the 5,260-ft
level. This technology is likely to be one of the technologies reevaluated at
that time.
What NEPA documemaJion has been compiled to dale that allows the aired
discharge oftrealed Waler to Silver Bow Creek? At which levels can water be
discharged to the Creck? I hope MCLs are mentioned somewhere for each
contaminant of concern. (l37)
Silver Bow Creek has been classified by the State of Montana as an "}" Class
water. This classification recognizes the impacted nature of the water body.
Discharge limits to Silver Bow Creek are determined by calculating the
minimum monthly means from the data from a three-year period prior to
discharge. The discharge values are recalculated every three years and
eventually will reach "Gold Book" values (chronic water quality limits).
These chronic water quality values are more restrictive than MCLs. The
treatability studies of the FS demonstrated that these values could be reached.
c. WATER USERS AND RIGHTS
Comment 10C-1:
Response:
Was a water right given to the PRPs to take over 5.5 cubicft of water per
second or 2,468.4 gallons per minute of the Stale of Mont/lNJ 's groundwarer
with or without the approval of the stale legislature?
If the PRPs have the approval of the stale legislalure for this amount of
groundwater. whal was the beneficial use described to the Stale legislature in
order to obtain this permit?
The Metal Mine ReclamaJion ACt (MCA i 83-4-30) stales: .Reco~ry of
damages for a waler loss in quantity and quality is provided for if an
investigaJion establishes thai a hard rock mining operaJion is responsible for
the loss.. What I would like to laww is: Is this a lump sum fine or payment
on the total amount of water that is being contaminated or on the amount of
waler per year that is being contaminated? Also, what would the amount of
damages be for 25 billion galions or 50 billion gallons? rr 2)
No water right permit is required at this tim~ for the filling of the Berkeley
Pit because there is no diversion of water for a beneficial use. In Montana,
private parties can receive a water right only for "diversions" of water, which
are then applied to a beneficial use. ~ MCA i 85-2-102. Rising water
-------
PART n - TECHNICAL COMMENTS
levels in the Berkeley Pit are not considered a diversion, but are caused by
natural groundwater recovering after cessation of underground mine
dewatering. Also, the PRPs are not currently applying the water in the Pit to
beneficial use.
Please note that MCA ~ 83-4-30 does not exist. Assuming the comment is
referencing MCA ~ 82-4-355, this section allows a user of groundwater to sue
a licensed mine operator for loss in quality or quantity of groundwater caused
by the mining operation. The groundwater user must first file a complaint
with the DSL. DSL is required to conduct an investigation of valid
complaints and issue a finding of the cause of the water loss. Any damages
awarded in a subsequent lawsuit would probably be in an amount designed to
compensate the groundwater user for actual losses.
D. BERKELEY PIT FILLING RATE
Comment 1 OD-1:
The importance of focusing surface inflow controls on future Horseshoe Bend
flows. as opposed to an arbitrary 2.4 mgdfigure. is underscored IJy
uncertaint)' surrounding Pit infilling tates. In 1993. ARCO issued a study
which suggested that Berk£ley Pit waters would not reach the CWL under
current conditions until at least 40 years from now. and thllt. if Horseshoe
Bend was properly controlled. the CWL would never be reached.
.Preliminary Modeling of Future Berk£ley Pit Water-Level Elevations and
Inflow Rates, . February. 1993. Certainly, if such predictions were to
marerialize. ARCO would seek a reexamination of the need to build any
treatment plant for Horseshoe Bend waters. In the meantime. EPA has pushed
for. and ARCO has accepted. a very conservative and proactive approach to
ensure thllt Berk£ley Pit waters are contained. Adopting this approach. EPA
was unwilling to use Pit infilling rates refleCted in the 1993 study, and
projeCted in the Plan Pit infilling dates of 2015, if no remedial actions are
tak£n, and 2022, if Horseshoe Bend is controlled.
By virtue of its years of intensive study of this problem, ARCO believes thllt
Pit infilling rates will continue to diminish. Yet. the extensive monitoring
program included within Alternative 6/7 will eliminate this .crystal ball.
aspect of the remedy by providing ongoing data necessary to calculate Pit
filling dynamics. ARCO believes thai there is a significant chance thai the
rerouting and permanent control or treatment of Horseshoe Bend Waters,
regardless of their exact volume, will likely result in stabilization of the PiJ
such thllt the goal of protectiveness will be accomplished. It seems
unreasonable and illogical giVen this potential for stabilization to establish a
2.4 mgd figure which may not reflect future surface flow conditions. When
viewed in light of the uncertainties surrounding Pit infilling rates, mandating
such a figure may result in the requirement thai waters actually be pumped
from the Berkeley Pit notwithstanding thllt the Pit has already reached a
. steady state.
-------
Response:
Comment lOD-2:
Response:
Comment IOD-3:
Response:
Comment lOD-4:
Response:
PART n - TECHNICAL COMMENTS
In this regard. EPA notes that one alternative that was screened and rejeCted
during the FS process was the immediate pumping of Berkeley Pit water to
maintain or lower the water level in the Pit System. EPA rightfully points oUt
that this much more costly option provided no increased protection of human
health and the environment, because the Alternative 6/7 was more than
sufficient to prevent reaching the CM:.. ARCO believes that this exaCt
rationale applies to the arbitrary designation of the 2.4 mgd ftgure
representing Horseshoe Bend flow, when Horseshoe Bend flow may not
continue at that threshold. Accordingly, ARCO requests that the Plan be
rewrinen to state the up-to-2.4 mgd, as refleCted by ongoing Horseshoe Bend
sampling and aCtUal site conditions, along with other surface flows, be
controlled or treated as oUtlined in Alternative 6/7. (pRP I)
The selected remedy does not require a 2.4 mgd of inflow control and
treatment unless an alternate inflow control site (i.e., a shaft) is used rather
than capturing Horseshoe Bend water. It mandates a permanent control and
treatment of contaminated surface inflow, including all of the Horseshoe Bend
water which is currently 2.4 mgd. It also requires permanent control and
treatment of subsurface flow in the Horseshoe Bend area and upgradient
diversions of uncontaminated flows after mining is suspended or the mine
closes.
Use of averages (RI, Fig 3-2) is an inadequate representation of water thaI
must be diverted from the Pit and could result in underestimation of Pit fill
rate. (BSB 3)
The Pit filling rate will be recalcula~.;:d yearly as part of the monitoring
program. "Hard" or actual data will be used to predict when the CWL will
be reached.
Regional recharge, evaporation, precipitation, and runoff data are excluded
from the Pit injlow calculations in Section 3 in the Rl and result in the
incon-eCt assumption that the Pit is a .closed system.. (BSB 3)
Regional recharge, evaporation, precipitation, and runoff water were not
excluded from the RI. EPA and MDHES believe that all water in the
. Berkeley PitlEast Camp System have been accounted for and that the Pit is the
low point or "sink" for water in the system (i.e., all water is flowing to the
Pit).
The assumption made by BSB on theftll rate as the level approa~s 5,410ft
is based on 25 ftlyear which should be more in the range of 2-8 ftlyear.
(BSB 8)
As the Pit continues to fill, the rate of fill (i.e., rise in feet per year) will
decrease. There are several reasons for this decrease, e.g., increase in water
-------
Comment 10D-5:
Response:
PART n - TEClL'.1CAL COMMENTS
surface in the Pit which results in increased evaporation, the decreased
recovery rate, etc. The Agencies plan to use a f1ll rate that is routinely
updated for future predictions based on actual measurements.
Several assumptions made in the groundwater modeling are flawed: (1) the
Pit aquifer is not isotropic and homogeneous,' (2) no rationale is given for
selecting marry of the boundary conditions; (3) impacts to the alluvial water
table as a result. of water rising in the bedrock aquifer are not addressed, and
(4) inconsistencies were noted in the sensitiviry analyses for wells GS-28 and
GS-29s. (BSB 3)
The bedrock aquifer associated with the Berkeley Pit/East Camp System and
the associated mine workings has been functioning as a homogeneous unit.
This has been demonstrated through a statistical analysis performed by the
State on selected shafts, bedrock wells, and the Pit. The selection of the
boundary conditions (if the comment is referring to the boundary for the area
of influence of the Pit Syster::) .. ~ ":.;.~.:~;nined using current and historic
information. Boundary condition parameters are described in detail in Section
11.4.4 of the RI report. EPA and MDHES believe the groundwater model to
be accurate.
Inconsistencies in the sensitivity analysis were deemed insignificant to the
general results of the modeling. . The RI and associated CWL for the Berkeley
PitlEast Camp System were limited to the bedrock aquifer. Rising water
levels in the bedrock aquifer and the coinciding impact on the overlying
alluvial aquifer were preliminarily investigated in the RI. 'Ibis numerical
model predicted a minimal effect on the alluvial aquifer. 'Ibe monitoring
program will track this issue with the collection of hard data.
E. WEST CAMP W A TERfTRA VONA
Comment 10£-1:
Response:
"
The Preferred Plan allows the Travona water to go as high as 5,435 ft in
elevation. It's at 5,427 ft now before it is pumped. 1hat water may also
conrribUle to the poor qualiry entering Silver Bow Creek from the bedrock
aquifer, particularly since where it is pumped is 25 ft higher than where the
creek becomes a gaining stream. EPA must lower the level at ~ich that
water is pumped. Also regarding Silver Bow water, arsenic and iron currtntly
~."':~~:: "':'~:.'" .:;::;.':.j' .::::..-..1::.,-.;; ';J7i:i d;!:.::!~" (It :hi 4~:r;;ro Sfihiir Planl. EPA
and the State must insist in the ROD on meeting the applicable standard
instead of creating early precedents for waiving legal requirements. (I' 9, G
2)
EPA and MDHES believe the S,43S-ft CWL for the West Camp is
appropriate. The points of compliance for the TravonalWest Camp System
CWL shall be: the Emma and Ophir shafts and the additional monitoring
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PART n - TECHSICAL COMMENTS
wells for the Travona/West Camp System installed as part of the monitoring
program. This will maintain flow in this System to the Travona mine shaft.
No legal requirements have been waived for iron and arsenic in the Metro
Plant discharge. The requirements for the Metro Plan discharge are set by the
MDHES Water Quality Bureau not the EPA or State Superfund programs.
Comment 10E-2:
Regarding the Travona Mine water, which is pumped to the BSB Metro Sewer
and diluted before discharge to Silver Bow Creek, how do EPA and MDHES.
justify not meeiing State water quality standards for arsenic and iron in this
"treatment''? This commenter asks that EPA and MDHES not set an early
precedent for waiving water quality standards during Superfund cleanup of the
headwaters of the Qark Fork River. (G 2)
Res~onse:
The BSB Metro Sewer discharge is regulated and must meet Silver Bow Creek
discharge limits. At present they meet the State's discharge limits. As the
cleanup of Silver Bow Creek continues, BSB may no longer be .able to accept
this mine pump water and still meet discharge limits. Existing orders
establish that if BSB cannot or will not accept these mine waters, a treatment
facility will be constructed that will meet Silver Bow Creek discharge
standards.
4.11
MTh'ING-RELA TED COMMENTS
The following comments have been divided into three groups: (A) loss of the ore body, (B) potential
problems with the Continental Pit, and (C) present and future mining.
A. LOSS OF THE ORE BODY
Comment 11..4-1:
Another ramification of the use of the Pit as a sludge repository is the loss of
the underground ore body. Allowing water to approach the 5,41Q-ft level
means the loss of potentially tens of billions of dollars in gross revenues from
the sale of metals and tens of millions of dollars in lost tax revenues to the
County, State, and Federal governments. Valuable ore that could provide
jobs and tax revenues and insure the economic future of BSB for years to
come is being written off in advance as contamination. The ore body must be
considered a long-term, strategic economic resource, not potential
contamination.
The following scenario has been developed from historical data collected by
.Anaconda Cor?er Mining Company and New Butte Mining to illustrate some
of the potential economic benefits to be derived from protecting and mining the
ore bodies underlying the Butte Hill.
Shallow ore reserves are 122,786,894 tons containing 0.88% copper and 0.33
ozhon silver. Using the assumption that: (1) 100% of the reserves would be
mined, (2) 80% of the copper and silver and 70~ of the molybdenum would
-------
Response:
CommentllA-2:
Response:
PART II . TECHNICAL COMMENTS
be recovered from the are mined, and (3) the copper is worth $1 Rb, the silver
is worth $4/oz and the moly $0.50Rb. the copper in the shallow reserves is
worth $1,728.839.467. and the silver is worth $129,662.960. Shallow
reserves represent a combined value of $1.858,502,427.
Deep reserves are 2.231.034,219 tons of 0.06% copper, 0.210z/ton gold. and
0.028% molybdenum. Using the asswnptions above, the value of the copper
is $21,417,929,000; the silver is worth $1,499,254,995; and the molybdenum
is worth $437,282,707. Deep resen'es represent a value of $23,354,467,000.
Using the assumptions above, the combined value of shallow and deep ore
reserves is $25,212,969,000.
These conservative estimates are based on proven reserves de/inealed by AMC
and reported by Richard N. Mil/er, Chief Geologist, in the document "Ore
Reserves and Resources: The Anaconda Mineral Company, Bune District,
MontaTlll to January 1. 1978." According to this AMC report, significant
deposits ofmilnganese. zinc, and lead also remilin to be mined under and
adjacent to the Berkeley Pit. If continued flooding is allowed in the Pit. and
worse, if the Pit is used as a sludge repository, this ore body would essentially
be lost or rendered considerably less valuable for future generations. Worse
yet, an enormous economic resource would be written offin advance as a
/iabUiry to be "eated with lime and disposed of in sludge. (BSB 2)
EP A and the State believe that sludge disposal in the Pit will not render the
ore body unminable. The flooding of the Berkeley Pit and associated
underground mine workings and disposal of sludges in the Pit do not eliminate
the "resource" (Le., the mineralized ore body) from being mined in the
future. We do realize that allowing the East Camp System to rise to the
S,41o-ft level will inundate much of the ore reserves and that the cost of
dewatering the System will be high and may discourage underground mining.
The remedy outlined in the ROD will place no restrictions on underground
mining.
This commenter aclawwledges the previous comment but goes on to talk about
the potential for mining the waler in the Berkeley Pit. The commenter point is
that studies are underway to assess technologies for extracting metals from
this water. MSE and the Resources Recovery Program issued a worldwide
RFP, which went out to more than 200 companies in the major industrial
nations of the world. There were over 32 responses to that RFP. The
decision process narrowed thqse 32 responses down to 10.7he final selection
process is underway right now. Those proof of technologies on actUal
Berkeley Pit water altreatment-scale levels could be occurring as early as
September of this year. (1' 12)
EPA and the State believe that programs such as the DOE Resource Recovery
Program will aid in the development of technology, which may contribute to
-------
PART n - TEClMCAL COMMENTS
more cost-effective solutions to the mine flooding problem. The ROD
specifies that there must be a reevaluation of the available technologies when
the Pit level reaches the 5,260-ft level. We expect technologies, such as those
being demonstrated by the Resource Recovery Project, to be evaluated at that
time.
B. POTENTIAL CONTINENTAL PIT PROBLEMS
Cominent 11 B-1:
Response:
Present generations should pay for the best available treatment option, if a
permanent non-treatm~nt solution is not available, to establish a precedent of
paying the true price of commodities like metal. Then public suppOrT would be
strong to prevent mining that doesn't have a permanent remediation solution
and a large enough bond to properly close the site. For example. what
remediation efforTs. if any, are in place for the Continental Pit once mining
ceases? Will we allow the mining comparry to turn off the pumps and let that
pit fill and become a big problem like we did at the Berkeley Pit? If no
permanent so/utinn PT;W ''''nr rl'/n p/iminare rhp danger and cost to future
generation, rhen we showd ban rhis type of mining until adequate permanent
solutions are developed. (l 4)
The Continental Pit is part of the East Camp System and we expect the water
level in the Continental Pit to be similar to the water level in the Berkeley Pit
and the rest of the East Camp. By controlling the level of the East Camp as
specified in the ROD, regardless of the withdrawal point, the level of the
Continental Pit will be maintained at a level which precludes migration out of
the system. .
It should also be noted that DSL is currently conducting a review of the
existing reclamation plan at MR pursuant to the Metal Mine Reclamation Act
(MCA ~ 82-4-337). In its review, DSL is evaluating the need for a
permanent water treatment plan as part of an updated MR reclamation plan.
An updated plan is due to be submitted to DSL on January 1, 1995.
DSL will review the updated plan, evaluating the quality and quantity of water
that can be expected to report to the Continental Pit from all sources. A
decision must then be made on whether to allow that water to accumulate in
the Continental Pit and if so, to what level. MR's plan will include specific
plans for water management. DSL must review the proposed plans and also
evaluate alternatives. The decision maker must select an alternative for
implementation. The alternative selected would have to meet the standards
established in the Water Qual.ity Act and the Metal Mine Reclamation Act.
Bond would be assessed based on the plan selected by the decision maker.
DSL permitted and bonded for permanent water treatment at MR in 1993.
That bond calculation and methodology is similar to that used for other mine
site in Montana with an open pit. The level of water in the Continental Pit
-------
CoTn11U!nt llB-2:
Response:
PART II - TEClL'lCAL COMMENTS
would be limited to the capacity of a sump which would be designed to hold
water that accumulates in the Continental Pit over winter. Water would be
treated the following spring, summer, and fall. Thus, no more than six
months of water would be allowed to accumulate at anyone time.
Permanent water treatment is both an operational requirement and a
contingency plan to be used once reclamation limits the amounts of water
needed to be treated. The goal of reclamation is to minimize the volume of
water needing treatment. If the remaining seepage is more than the
environment can absorb or evaporate without off site impacts to water quality,
a contingency water treatment plan is needed.
Bonds are posted as surety bonds which are converted to trust funds at the end
of mine life. Trust fund bonds include the costs of constructing treatment
plants, operating and maintaining the plants, and costs of replacing the plants
every 20 years. DSL must assume that the mining company would leave the
unreclaimed site and DSL would have to step in and initiate reclamation and
water treatment if necessary.
First. why.. haven't EPA and MDHES prohibired rhe nearby mine currently in
operarionfrom dumping their wastewater into the Berkeley Pit? lfthis a
federal Superfund site, shou/dn 't po/lUlers be prohibited from increasing the
contamination? The current mining operarion is not only adding to the
contamination in the Berkeley Pit; it is also adding to the surface water
inflows to the Pit - inflows that might have been clean warer bUl have been
degraded by the current mining operation. According to CERCLA, as
amended by SARA, the aim of Superfund is to reduce contamination, not to
add to it. Why have none of EPA 's alternatives considered prohibiting the
cu"ent mining operation from continuing the practice. of dumping their
wastewater into the Pit? (143)
Several statements in this comment are incorrect. The current operator is not
dumping their wastewater into the Berkeley Pit. Waters from the concentrator
are placed in the Yankee Doodle Tailings Pond. Then "decant" water is taken
from the Pond and returned to the concentrator. As the RI demonstrates,
there is a "closed loop" in the water balance of the current operator. (Also
see response to Comments 19A-l and 19A-3, Section 3.l9A.)
EP A does not have the authority, outside of Superfund, to control surface
w~ter inputs to jte Pit. The Pit is considered to be a giant holding lagoon
which is not regulated under the Clean Water Act. Discharges out of the
"lagoon" are regulated under the Clean Water Act but these type of discharges
will not occur for many years. Under Superfund, however, EP A is allowed
to take additional actions necessary protect human health and the environment.
To take this action the Agency must follow the NCP and go through the
RIIFS, ROD, and associated enforcement processes as is currently being done.
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PART n - TECHNICAL COMMENTS
C. PRESENT A..'\1> FUroRE r.fiNlNG
Comment 11 C- 1:
Response:
Comment 11 C-2:
Response:
Comment llC-3:
In the Preferred Alternative. treatment of the Berkeley Pit water will not occur
until present mining operations cease. The year 2005 has been used for
calculation purposes in the Ri/FS. This figure is purely arbitrary, yet the
Ri/FS offers no contingenc)' plans in the event that mining operations continue
beyond the )'ear 2005. Apparently, MR can wait unril the eM.. is reached
before rJ,e)' even "egin to construct a water treatment system. A water
treatmenr system generally requires at least a tWo year 'shake down' period
before it is on-line and fully junctional.
According to the Preferred Alternative, the CWL may be reached 1:Jy the year
2022. MR has estimated that the ore body in the East Continental Pit area
will last until 2015-2025. As both of these figures are estimates, it is clear
that an unacceptable situation could arise. EPA must include a contingency
plan in the Preferred Alternative that addresses this situation. (1 5)
EPA and the State have included provisions in the ROD, because of public
comments such as this, that dictate that construction of a tteatment plant,
capable of maintaining the water level in the East Camp System below the "
CWL and meeting discharge standards, be completed four years prior to when
the water level "in the system is projected to reach the CWL regardless of
whether or not mining continues.
Ifmining doesn't cease in 2006. there should be a plan to adjust to this to
maintain the Pit level below the eM... Alternative 6/7 uses mining procedures
in its treatmem of Horseshoe Bend water umilthese waters are rOUted to
primary treatment in the post-mining stage (FS, 1994). /fmining continues
longer than expected. will the reroute of the Horseshoe Bend water to primary
treatmenr still take place in 2006 or is it dependant upon mining activities? If
mining does continue and Horseshoe Bend water isn't divened to primary
treatment as per the plan, the final stabilized Pit water level could change.
This should be evaluated and described before a plan is picked and initiated
so thaI target water levels can be set and success measured appropriately.
(14)
If mining doesn't cease in 2006, the ROD dictates that conttol of Horseshoe
" Bend water must continue and the construction of a tteatment facility, capable
of maintaining the water level below the CWL, must be completed four years
prior to the water level in the East Camp System reaching the CWL.
The role of the existing mining operations should be completely clear. They
should not be allowed to follow any practices thaI worsen the condition or
delay the cleanup. Currently, the MR Concentrator overflow ditch is
-------
Response:
4.12
PART n . TECHNICAL COMMENTS
contributing O. J 4 million gallons of water per day to the Berkeley Pit. This is
an unnecessary accelerator to Pit filling that must be stopped. Any water used
by the existing mining operation should be trealed at their expense at the
treatment plant at the concentrator and discharged into the Metro Storm Drain
or Silver Bow Creek. (1 4)
The ROD requires that Horseshoe Bend flow be controlled. There will be
allowances for upset conditions or overflows. This wil1 be limited however to
fairly limited flows and circumstances. EPA and the State expect all costs
associated with treatment of waters associated with the MFOU to be paid
collectively by the PRPs. The arrangements between these parties for costs,
including the costs of treatment for contributions to the Pit during these upset
conditions, will be left up to the PRPs to decide.
HUMAN HEALTII
Comment 12-1:
Response:
Comment 12-2:
Response:
Comment 12-3:
'"
Perhaps on issues that have perpetual implications, you should give grealer
weight to opinions of parents than you do to intimidated shon-term public
officials, because when it comes to hWTUln health and the environment,
mothers and fathers know what is best for their kids and future generations.
(1 30)
The CERCLA process requires that any citizen, whether a private citizen or a
public official, has the right to voice their opinion and concerns regarding the
proposed remedy. This is the purpose of the required public comment period
for the Proposed Plan. One of the nine criteria which EPA uses to evaluate
proposed remedies is Community Act;eptance, which requires EPA to evaluate
the issues and concerns the public may have regarding each of the
alternatives. Therefore., EPA is required to consider and respond to all
comments received from all parties during the public comment period.
We are writing in opposition to the current EPA-ARCO remedy plan for the
Berkeley Pit for the following reasons. We are concerned regarding the
danger to public health due to the risk of contaminants getting into the
aquifer. We do not feel our children should inherit our problems - such a
legacy as the problem of the Pit is too drastic to pass on to a future
generation (s). (119)
EP A and the State believe that the remedy outlined in the ROD is protective
of human health and the environment and contaminants will not migrate into
the alluvial aquifer. We also believe that treatment will be required in
perpetuity regardless of the type of treatment employed or the level at which
the Pit is maintained.
Have the synergistic effects of pollutants been considered with the RI, FS, and
Proposed Plan? (143)
-------
Response:
Comment 12-4:
Response:
Comment 12-5:
Response:
Comment 12-6:
PART II - TECHNICAL COMMENTS
The MFOU risk assessment examined the potential affects on human health
and the environment from exposure to aluminum, arsenic, cadmium, copper,
iron, lead, sulfate, and zinc and in the absence of any remedial response
action. Each contaminant was evaluated separately since a reliable method for
evaluating the synergistic health risks from exposure to these contaminants is
not currently available.
More emphJJsis. should be on the "wor~r" scenario because mining operations
are still continuing. A chart Sum17Ulrizing risks would be helpful. Was arsenic
the only contamination that exceeded the carcinogenic range? /fnot, describe
others. (137)
Direct contact to the Pit water or the Horseshoe Bend water poses
insignificant risks to workers. This water would have to be ingested to pose a
significant risk. We believe that ingestion of this water by workers is an
impossibility, hence it was not evaluated. Mine worker safety falls under the
authority of such regulations as the Occupational Safety and Health Act
(OSHA) and the Montana Safety and Health Act (MSHA); therefore, a "mine
worker" scenario was not evaluated by EP A during the MFOU risk
assessment. During the construction of any water conveyance or treaunent
facility pursuant to the MFOU ROD, worker safety from exposure to the
contaminants of concern will be ensured through adherence to health and
safety procedures. These procedures will be documented in the remedial
design/action work plans.
Arsenic and cadmium are the contaminants of concern with respect to
potential carcinogenic risks. Based on the risk assessment, only arsenic would
present a potential future threat to human health. This risk, however, will not
occur since EPA has an agreement with the PRPs (AO - Docket No.
CERCLA Vill-90-10) that requires the PRPs to maintain the elevation of the
Pit water below 5,410 ft. This provision ensures that contaminated Pit water
will not be released to the alluvial aquifer or Silver Bow Creek.
One cornmenter said if the Berkeley Pit water is contaminated, whal about the
miners who worked there. He wants to know whal is being done for former
copper wor~rs. (BSB 4-L)
Regulations set forth under the NCP do not address past occupational health
issues; therefore, these issues were not considered during the conduct of the
MFOU RIIFS. Since contaminated water is only a threat to human health if
its ingested, it is unlikely that' a mine worker would have been exposed to
these metals.
17te primary concern is not who pays and how much, but is rather the 1u!alth
of our citizenry and of the waters1u!d, which are inextricably intertWined.
(BSB 15, 136)
-------
Response:
Comment 12-7:
Response:
Commenr12-8:
Response:
Comment 12-9:
PART n - TECHNICAL COMMENTS
The ROD dictates that the East Camp /Berkeley Pit be kept below the S,41O-ft
elevation and in the West Camp System below the 5,435-ft elevation. Water
from the system must be treated to State discharge standards. This action
precludes any direct impact to the alluvial aquifer or Silver Bow Creek from
contamination in the Pit System. This remedial response , action also includes
institutional controls restricting the use of contaminated groundwater.
Together these actions will protect human health and the environment.
A summarization of chemical analysis should be included - state maximum
peaks, etc. (I 37)
Complete chemical analysis of groundwater samples are shown in the RI
repon. The complete <.nalysis of potential human and environmental health
threats is presented in the Baseline Risk Assessment. These documents are
available at the Superfund information centers in Helena, the Butte Superfund
Community Involvement office, the Montana Tech library, and the BSB
library .
According to the NCP, the purpose of a Baseline Risk Assessment is -to
characterize cu"enr and potential threats to human health and the
environmenr that may be posed by contaminanrs migrating to ground water or
surface water, releasing to the air, leaching through the soil, remaining in the
soil, and bioaccumulating in the food chain. - The Baseline Risk Assessment
that was completed by the EPA and MDHES addressed the risks posed by
ingesting contaminated surface or groundwater. However, it does not address
the risk to human health from dust blowing off of the ba"en, exposed walls of
the Berkeley Pit. In fact, the Pit walls have been placed with the Active
Mining Operable Unit. This operable unit will not be addressed until mining
operations have discontinued.
A study by Luoma and Moore (1990) discovered a higher incidence of disease
in Butte than in comparable cities. This was found in both men and women
indicating that the exposure route was environmental rather that occupational.
It is likely that windblown dust may be a contributing factor. Stabilizing the
Pit walls should be addressed in the MFOU, not in the Active Mining
Operable Unit. This unhealthful situation must not be ignored until active
mining ceases. (1 5)
The MFOU action addresses only the problems related with contaminated
groundwater associated with the flooding underground workings and the Pit.
Reclamation and blowing dust is addressed by the DSL operating permit and
the future RIIFS activities for other operable units.
Moore and Luoma (1990) compiled several studies on disease-related monality
in the Dark Fork Basin. including Butte. They found that Butte, compared to
cities of similar population, ranked highest in all disease related deaths for
-------
Response:
Ccmment 12-10:
Response:
Ccmment 12-11:
Response:
PART D - TECiL'lCAL COMMENTS
1945-51 and 1959-61 and was first among -other diseases than hean and
kidney- for the periods 1959-61 and 1969-71. Great Falls and Billings,for
comparison, ranked betWeen 350-450 in all categories.
Trachea, bronchial, and lung cancer from 1970-79 were especially high in
"rcas of -primary contamination. - Silver Bow Counry had a monality rate
from lung, trachea, and bronchial cancer per 100,()()() of 55.3 compared to
Montana's 31.1, Nonh Dalwta's 20.5,/daho's 22.9, wyoming's 26.7 (Data
from Riggan, et al., 1983 in Moore and Luoma, 1990). Moore and Luoma
(1990) also found that by looking atfemale monaliry rates thai the cancer
deaths did not appear to be solely from occupational sources. They found thai
during the same 1970-79 period that overall cancer rates for Silver Bow
Ccunry women fell withir: t.ie highest four percent for all U.!. ~unties (Data
from Riggan, et al., 1983 in Moore and Luoma, 1990).
The work plan assumes that the only threat to humans is from drinking
contaminated waster from groundwater. Since past/nstitutional Controls have
stopped the citizens of Butte from drinking the groundwater, yet these
abnonnally high cancer rates persist, it can be assumed that other
environmental factors are putting people at risk. The work plan should have
commissioned a more comprehensive RIfFS thai addresses the other hazards to
human health including airborne contaminants. (14)
See response to Comment 12-8, Section 4.12.
Please see the attached by Luoma and Moore on health hazards in the Upper
Qark Fork due to mining. Please advise how this Preferred Plan addresses
air contaminants, given the high incidence of lung disease, even among
women, recorded for this area. Will the Agency for Toxic Substances Disease
Registry review this research to attempt to identify long-tenn causes of the
utremely high rates per capita for all diseases. hean disease, etc. (G 2)
See response to Comment 12-8, Section 4.12.
The commenter includes a paper entitled, -Hazardous Wastes from Large-
scale Metal Exlraction: The Qark Fork Waste Ccmplex, Mr- by Johnnie
Moore and Samuel Luoma (BSB 6)
The paper is include in the Administrative Record for this operable unit.
RS4-37
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COALITION COMMENTS 6/30/94
5.0 RESPO~SES TO COALITIO~ CO~fMENTS
This section provides EP A and MDHES responses to comments by the Clark Fork River - Pend
Oreille Coalition on June 30, 1994 in a document entitled Alternate Plan and Rationale for Berk£ley
Pit and Mine Flooding Operable Unit. EPA and MDHES have broken the responses to issues in this
document into 2 parts. First, we respond to the "big picture" as presented by the Alternative Plan
presented in the "General Response" Section. We then respond to the individual points in the
document.
GENERAL RESPONSE:
EPA and the State appreciate the comments received from the Clark Fork - Pend Oreille Coalition
(CFC) and recognize the large amount of thought and work that went into this document. Even
though we do nu. agree with all the points made in the document, this document, along with other
comments we have received, has impacted our decision in numerous ways. Our response to the
major points of the plan and the impacts on the original proposed plan are outlined in this section.
Major Points of Proposal:
1. Project Structure and Schedule
2. Need for additional data
3. Inflow Control
4. More Protective Critical Water Level
5. Treatment technology to Drive Final Pit Level
6. West Camp
7. Financing
1.
Proiect Structure and Schedule
The CFC plan calls for an interim ROD produced now with a final ROD produced after funher data
gathering and treatment technology development. EP A and the State see no major benefit in .
producing an interim ROD. Additional data will be gathered in the future through the post ROD
monitoring program, additional studies, and technology development programs. EPA and the State
will amend the ROD (or issue an ESD) if this information causes significant differences in elements
of the ROD (e.g., alternate treatment tectmology, alternate CWL).
2.
Additional Data
The CFC plan calls for a large data gathering effort. Many of the proposed studies and data
gathering efforts have valid scientific merit and provide additional assurances of the protectiveness of
the remedy. After reviewing public comment, we recognize that additional analysis of the impact of
placing sludge in the Pit is necessary as well as some additional groundwater monitoring. We
believe, however, that much of the data gathering effort is unnecessary for making this remedial
decision.
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3.
COALITION COMMENTS 6/30/94
Inflow Control
The CFC plan calls for maximum inflow control. The Proposed plan emphasized Inflow Control and
the ROD continues to emphasize this element. To strengthen this component of the remedy the ROD
requires that subsurface flow in the Horseshoe Bend area be collected and treated and that, after
mining is suspended or the mine is closed, upgradient diversion of all major surface flows presently
used in the mining operation be divened.
4.
More Protective Water Level
EPA and the State strongly believe that the CWL is a safe water level and protects human health and
the environment. We understand the uncertainties expressed and the anxiety that the public has
concerning this issue. We have responded to these uncertainties in the following ways:
5.
a.
i-be ROD requires that the critical water level of 5,410 ft apply to the entire East.
Camp system, not just the Pit. The water level in the Anselmo Mine is currently
about 40 feet above the Pit water level. Therefore, if this gradient remains there
would be a buffer of 90 feet between the Pit and the level at which Pit water can
discharge into the alluvial system (5,460 ft). A buffer of at least 50 ft is guaranteed
even if this gradient between the Pit and the Anselmo shaft is reduced.
b.
The ROD requires that the inflow of water be reduced significantly to allow a much
slower rise in the system water level. This allows much more time to react to any
unanticipated impacts.
c.
The ROD requires that a comprehensive monitoring program be employed to
thoroughly monitor the system and act as an early warning system.
d.
The ROD has a requirement to have construction of a final treatment plant completed
4 years prior to when the water in the East Camp system reaches the CWL. This
allows for early stan-up if necessary.
e.
EP A and the State retain authority identified under Federal and State law to establish a
lower CWL or take alternative action ii necessary to address unanticipated threats to
human health or the environment.
Treatment technolo~ to Drive Final Pit Level
Tbe CFC plan calls for a specific schedule to develop and implement innovative treatment technology
which would drive the final Pit level. EP A and the State do not believe that treatment technology
should drive ~e final mandatory maximum Pit level. We do believe however that innovative
treatment/metals recovery technology development is important. We received considerable comment
from the public concerning the volume of sludge that will be generated by the aerationlbydroxide
precipitation technology proposed and the public's view that a technology that would recover metals is
much preferable. We believe that these are valid points and have sought to address these issues in the
ROD in the following ways:
RS5-2
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6. West Camo .
COALITION COMMENTS 6/30/94
a.
EP A and the State are actively involved in an advisory role with the DOE resource
recovery project which is actively pursuing demonstration of or acting as a testing
ground for both treatment and metals recovery technologies using the Berkeley Pit
waters.
b.
EPA and the State remain flexible in the implementation of alternate treatment/metals
recovery technology proposed jointly by the developers of that technology and the
PRPs, if that technology meets the performance (discharge) standards established for
this action.
c.
The ROD requires that a reevaluation of treatment technology be conducted when the
water level of the Pit reaches the 5,260-ft level (presently projected in 2009).
d.
EPA Region vm and the State will actively pursue federal monies fe,. :-esearch and
development of innovative treatment/metals recovery technology for Berkeley Pit
water.
The basic recommendations from the CFC plan calls for: a) lowering the CWL for the West Camp to
5,410-ft level; b) evaluation of the bulkhead integrity; and c) construction of a treatment facility for
the West Camp water.
a.
EPA and MDHES believe that the S,43S-ft CWL for the West Camp is appropriate.
We have not observed any impact in Silver Bow Creek in this area which would
indicate significant seepage. We will be installing four additional wells, however, to
better define the bedrock water levels immediately adjacent to the southern boundary
of the West camp system. The CWL will be adjusted, if necessary, based on the
information generated from the installation of these wells and subsequent monitoring.
b.
EP A and the State do not believe that the integrity of the bulkheads needs to be
evaluated. The failure of the bulkheads would actually lower the level in the West
Camp to the lower East Camp level and would make a discharge to Silver Bow Creek
even less likely.
c.
The commenter indicates that the PRPs benefit by their contract with Butte Silver Bow
by diluting the arsenic in the West Camp water (the majority of the iron is removed
by the treatment process) with sewage to meet discharge standards. This situation is
correct. The "I" classification allows this flexibility for existing permits (as opposed
to new permits). The requirements for the Metro Plant discharge are set by the
MDHES Water Quality Bureau, not the EPA or State Superfund programs. The BSB
. Metro Sewer discharge is regulated and must meet Silver Bow Creek discharge limits.
At present the plant meetS the State's discharge limits. As the cleanup of Silver Bow
Creek continues, BSB may no longer be able to accept this mine pump water and still
meet discharge limits. Existing orders establish that if BSB cannot or will not accept
these mine waters, a treatment facility will be constructed that will meet Silver Bow
Creek discharge standards. EPA and the State do not believe that building a treatment
plant at this time is a wise decision. We believe that construction of a treatment
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COALITION COMMENTS 6/30/94
facility for the West Camp water should be coordinated with Lower Area I treatment
plant construction.
7.
Financin2
The CFC plan calls for additionaJ assurances for the long-term financing of this action in the form of
bonding. The evaluation of the mechanism for financing this project is not part of the ROD, but
rather it is closely tied to the enforcem~nt of the decision. The ROD, therefore, does not directly
address this issue. Regardless, EPA and the State received considerable comment concerning the
fmancing of this project. Many parties indicated that, because of the length of time until a final
treatment plant may be necessary and the fact that this treatment plant will need to be run in
perpetuity, additional financial assurrance is necessary. We understand this issue and the public
concern and wt: are presently evaJuating our options concerning bonding or other financial assurance
possibilities. -
PLAN AND RATIONALE FOR
BERKELEY PIT AND MINE FLOODING OPERABLE UNIT
FROM THE CLARK FORK - PEND OREILLE COALITION
PresenJed to: U.S. EnvironmenlDl Protection Agency
DaJe: lulU! 30,1994
Introduction
EPA's Preferred Plan for remediation of the Berkeley Pit and Mine Flooding Operable Unit is
unacceptable to the people of Butte and to the Qark Fork-Pend Oreille Cotilition. Major points of
disagreement are the elevation at which the Pit would be allowed to remain in perperuiry, and the
future unfriendly idea of waiting 30 more years to initiate an)' pumping and cleaning of toxic Pit
water. Disagreement emanates not just from uncertainties associated with the Plan, but also the
certainties- certainty that the perperualelevation for toxic Pit water would leave a heritage of
impending crisis to all future residents.
In consultation with residents who are knowledgeable about the Hill, the econo,,;, and the
social syStem of Burte. Coalition scientists and technical people have prepared the following
Communiry-Based Alternative to the EPA Preferred Plan. It combines much of Burte-Silver Bow
County's recommendations, with revised elevations and time schedules. 1'he Plan groW! OUI o/the
need for new treatment technology now, and it relies on the proven impetus of deadJiMs, AlMriam
know-how, and market/orces to bringfonh that technology. It allows EPA to moveforward with
most of the work suggeSted in its Preferred Plan, but asks that this occur under an Interim Record of
Decision. In that way, the new monitoring wells and other needed investigative work am occur under
an Extended Remedial Investigation. 1'he new, effective technologies that everyone unanimously .
agrees are needed can be addressed under an Extended Feasibility Study. It allows that the Final
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COALITION COMMENTS 6/30/94
Preferred Plan and Record of Decision not be issued until after specific technical and legal data gaps
are filled-and thal the Pit be pumped and treated at the earliest possible time, considered to be the
year 2002.
Recognizing the EPA requires technical or legal reasons to deviate from its Preferred Plan,
the Coalition has documenred some of the inadequacies on which thai Plan is based. These are
sWTU1J(Jrized in an Appendix. "Reliance on Assumptions. 17zeories and Speculation, "for thai is the one
thread thai runs through all the complexities of the Preferred Plan and it is core to the public's
problem with the Plan. A tremendous number of unsupported assumptions. opinions, models and
estimates creales an unacceptable cumulative margin for error in Butte's one-and-on/y chance for
remedy of the Pit and Mine Flooding. Evidence is presented that the Preferred Plan disregards some
of EPA's own criteria for remedy selection (pg. 14. e.g., Toxic Volume Reduction, Short and Lbng
Tenn EffeCtiveness, Cost, some air and water ARAR's (Applicable Relevant and Appropriale
Regulations) an'" OJmmunity Acceptance). Questions and concerns presented here Wtrefilteredfrom
those of Coali.. .'4-scientists and staff. Butte's EPA grant-funded CTEC (Qtizens' Technical
Environmental Committee), Butte-Silver Bow County scientists. plus students and others who have
followed this issue closely.
It is also significant (0 note that a 3D-year postponement causes a great deal of current on-
the-ground and underground expertise and undemanding of the situation to be lost (dealh, relocation,
etc.), resulting in reliance on documenration as opposed to first hand experience. Because future
generalions may have less understanding than we have al present, today's generation is in a better
position to move forward with a solution.
The Coalition believes thai, through a thoughtful review of the Appendix, EPA will become
convinced of the validity of the community outpouring thai the Preferred Plan is unacceptable. The
OJalition proposes the following Plan that combines the best aspects of the EPA Plan, plus removes
some of the uncertainties to which citizens object.
A COMMUNITY-BASED ALTERNA11VE
The OJalition believes thai it is in the long-term best interesr of the citizens of Butte-Silver
Bow and all its downstream neighbors, as well as the environmental health of the Qark Fork River
Basin thai contaminated Waler in the Berkeley Pit begin to be pumped and trealed as soon as
technically possible, utilizing treatment that minimizes waste sludges while freeing clean waler for
permanent, beneficial uses. It is hoped this can evenrually include decreasing the volume of toxic
17UJlerials currently in the Pit to provide a grealer margin of safety to future generations. The need
for decreasing toxic volume from today's levels could be detennined based on any increase in
confidence from the community after data gaps (discussed below and in Appendix) are filled.
The following alternative plan, like the EPA alternative 18/19, holds the Pillevel at its
elevation at the.time the remedy is implemented. The plan agrees with many of the Butte-Silver Bow
OJunry recommendations, but employs a lower protective Pit waler level based on earliest possible
implementation, which is considered to be the year 2002. This allows some time to develop more
effeCtive treatment technology. The plan also emphasizes management of water inflows.
The process for implementation of an alternative plan would include:
RSS-S
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COALITION COMMENTS 6/30/94
.
An Interim ROD now (Record of Decision) specifying need for additional information
which would be accomplished under an
.
Exlended RJ.FS (Remedial Investigation-Feasibility Study),' then a
.
Final Preferred Plan and
.
Firwl ROD could be issued as soon as an adequare treatment technology is
found.
The Coalition recommends that implementation not be tied to any specific Pit water elevation,
bur to the need for soonest possible implementation of treatment, recognizing the need for responsible
aCtion from today's generation.
The folloWing paper outlines the important components of this community-based alternative.
A. Additional Dara
J. Data GaDs Must be Eliminated to the Extent Possible: A SensitivitV Analvsis is requested Ql all the
"sQft" dara and assummions (see ArwendixJ that have ~one into the RJ-FS and on which the Preferred
Plan is based. While normally associared with economic projections for decision-making, this type of
exercise would be valuable to both the community and to EPA injustif)'ing w/wtever decision is finally
deemed appropriare. This QNl/ysis should be accomplished first: then this year's Interim ROD would
delineate w/wt new dara must be generated over the ne:a year to fill-in the most critical dara gaps.
Areas which appear to require new dara immediarely include:
.
Immediare implementation of monitoring wells southeast of the Berkeley Pit and in the West
Camp as specified in the Butte-Silver Bow recommendations and by Rowling Technical
Services, plus consideration of a deep quality well al Rocker.
Response:
EPA and MDHES believe that the wells and monitoring points shown in the
monitoring plan attached to the ROD are adequate to monitor the bedrock
aquifer. This includes three new wells in the East Camp and four new wells in
the West Camp. The County has worked with EPA and MDHES and bas
contributed to the siting of the additional East Camp wells. EPA and MDHES
do not believe that an additional bedrock monitoring well at Rocker will
provide useful data. EP A and the State will install wells and monitoring points
as necessary in the future based on the ongoing evaluation of the monitoring
program. Also see responses to comments in Sections 3.4.3.161-4 and 4.2.
.
A more accurare water budget and thorough analysis of potentially slowing inflows. From
these. the volume of water necessary to pump in the year 2002 can be more reliably projeCted.
A total water budget must include municipal leakage and, importantly. fate of ourjlow
(including ar the Colorado Tailings). If the warer level stops rising, incoming water is going
somewhere. If less water needs to be pumped in succeeding years, PRP's (potentially
Responsible Parties) must prove it is not leaving the Pit to creare a new problem.
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COALITIO~ COMMENTS 6/30/94
Response:
The water budget for the Berkeley PitfEast Camp and West Camp Systems was
thoroughly studied during the RI. All projections are' made on a very
conservative basis. We believe that further fine tuning of the water balance is
more of a an academic exercise and that monitoring the rise of water levels
over time will provide better information for future projections and decisions.
The current data indicate that all water is being contained within these systems.
The bedrock monitoring system ensures that contaminated water will be
detected before it could exit the ~~drock systems. Also, see responses to
comments in Sections 3.16C, 3.16G. 3.161-4, and 4.10-B.
.
More definitive ground water modeling to include:
-"
-"
thermal influences
conservative expectations of cone of depression influence on Pit and tunnels
-"
potential East Continental Pit influences on contamination migration
-"
determination of exact locations of ground water divides: possibilities of flow
reversals. '
Response:
EPA and MDHES believe that the thorough groundwater modeling conducted
as part of the RIIFS was adequate to characterize the location of the
groundwater divides. Additional groundwater modeling will be conducted if
EPA and MDHES feel that it is warranted. EPA and MDHES acknowledge
that contaminated groundwater may migrate eastWard toward the Continental
Pit if dewatering in that Pit lowers the surrounding groundwater such that the
cone of influence reaches the Berkeley PitlEast Camp System water. However,
groundwater will still be contained within the Berkeley PitlEast Camp System.
See responses to comments in Section 4.10D.
.
Quality of inflow and outflow due to mine flooding must be stated in the Mine Flooding DIU
(Operable Unit) to assure that all contamination releases are addressed. This should include
characterization of sources of bedrock aquifer contamination releases at the end of the Colorado
Tailings with remedy for same addressed under this DIU.
Response:
The quality of all sources of groundwater in the MFOU are adequately
characterlZec:1 in the RI/FS. The bedrock groundwater entering Silver Bow
Creek in Lower Area One is from shallow sources not connected or related to
the, bedrock aquifers within the Berkeley PitlEast Camp System. See responses
to comments in Sections 3.16B and 4.10B.
.
Pit microbiological and geochemical studies.
Response:
Additional evaluation concerning the geochemical impact of sludge disposal in
the Pit are deemed necessary before approval of sludge disposal in the Pit will
be approved. Additional micr9biological and geochemical studies may be
considered in the future if deemed necessary by the Agencies to make
decisions. See also responses to comments in Sections 4.2 and 4.6.
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COALITION COMMENTS 6/30/94
.
Pit bonom sediments srudies to determine Geochemistry of sedime1l1s and whether sedime1l1s could
be sealing the Pit bonom.
Response:
A complete examination of Berkeley Pit sediments may be a worthwhile
exercise but is beyond the objectives and scope of this decision. Additional
evaluation associated with the disposal of sludge in the Pit are necessary. The
scope of this evaluation has not been determined. See also responses to
comments in Sections 3.14, 4.4, 4.5C, 4.6 and 4.8.
...
Development of downstream landowner program for monitoring of "new springs" between Butte
and Garrison Junction.
Response:
Several monitoring points in the Outer Camp are included in the post-ROD
monitoring program. This area will also be evaluated in the Non-Priority Soils
Operable Unit RIIFS. EPA and MDHES believe that there is presently no
necessity to make provisions for the monitoring of potential "new springs"
between Bune and Garrison as part of this RIIFS. This issue will be
reevaluated upon completion of the Outer Camp studies in future RI/FS work.
.
Studies of relationship between saturated bedrock and potential rise of alluvial Qljuifer.
Response:
The RI modeled the potential impact of the rising bedrock aquifer on the
alluvial aquifer and we believe that impact will be relatively minor.
Regardless, the monitoring program has been set up to monitor the future
impact. We have included numerous monitoring points in the areas where the
largest and earliest impacts will occur if, in fact, any impacts can be observed.
.
A plan for preventing loss of the many bulkheads between East and West Camps and/or a
contingency plan for dealing with the loss ifit occurs. It would include analysis of East vs. West
hydraulic heads, relationship of locations/elevations of bulkheads to one another and possibly to
Orphan Girl area. Green Lake Seep, etc.
Response: .
EPA a..,d MDHES believf> ~~at the hydraulic relationships between the West
Camp System and the Berkeley PitlEast Camp System is well characterized for
this action. Tbe sening of the CWL at a higher elevation in the West Camp
compared to East Camp System is to ensure that the groundwater gradient is
toward the East Camp System. Failure of a East Camp /West Camp bulkhead
will lower the water in the West Camp posing no risk to human health and the
environment.
.
Identification of any a1ditionaJ cont:unina1l1s within the OU with risk analysis and public
infomuuion (e.g., organic c01l1aminams wirhin curre1l1 mining lands and leach pads).
Response':
Contaminants other than the arsenic and the metals are considered negligible
and are therefore not addressed by this RIIFS.
.
Initiation of air quality epidemiologic investigations (possibly by the Agency for Toxic Substance
Disease Registry) and ifnecessary, feasibility of srabilizing Pit walls.
RS5-8
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COALITION COMMENTS 6/30/94
Response:
Air quality was included in the human health risk assessment conducted for this
RIIFS and was not found to be a significant threat to human health. Stabilizing
the Pit walls is beyond the scope of this action which addresses only
groundwater issues. See also responses to comments in Section 4.12.
2. Public information Data GaDs: Bener public information and involvement is needed throughout the
process so new information (e.g.. risk assessment; epidemiologic study) is made available in a way that
is both accessible and understandable 1Jy the general public. Particular gaps would be filled:
. A public comme11l period on EPA proposal to "write off' the bedrock aquifer
. A published list of wells (private, public) affecred 1Jy mine flooding, with more open and proactive
EPA communication ofimplications~where well bans might occur, etc.
Response:
EPA and MDHES have gone well beyond the requirements of CERCLA to
keep the public informed and to listen and consider public comments. Please
see Sections 1.2, 1.3 and 3.91. We do not believe that a formal public
comment period associated with the waiver of ARARs for the bedrock aquifer
for the East and West Camps is appropriate. However, public involvement is
encouraged especially in the institutional controls development associated with
the waiver. We plan to initiate a formal public information and update
process, which includes involvement by the MBMG. We are hopeful to have
Butte-Silver Bow involved in this process to provide an additional avenue for
information dissemination.
B. Inflow Control
Interim ROD Must EmDhasize the Diversion of all Controllable Water from the Pit: Source control
and pollution prevention should always be the first steps in pollution control. In addition to Horseshoe
Bend water cu"e11lly planned for diversion, any increases to the Horseshoe Bend flow must be
diverted. Storm water entering mine shafts must be diverted. Leaks in the municipal water delivery
system must be repaired. Pit inflow from current mining operation spills and any possible from
planned expansion of the Yankee Doodle tailings dam must be more adequately addressed.
Response:
The objectives of the selected remedy are clear - maximize control of inflow to
the Berkeley Pit. See other responses to comments in Sections 3.8 and Section
4.4. The ROD spells out the additional requirements associated with the
Yankee Doodle Tailings Pond operation and expansion.
C. A More Protective Water Level
1. Potential Future Eve11ls-Effect on Pit Fillin/! Rate: EPA must identify the types of future eve11lS that
could cause either a shutdown of Pit pumping and treanne11l or a need for an increased rate of
pumping and treatment. A probability value could be assigned to each, including the number of same
occu"ences possible in perpetuity. Some of those eve11lS include:
. Earthquake effects on Yankee Doodle Tailings Dam at higher than 6.5 Richler, and re-evaluating
distance from Dam, depth, dispersal and anenuationfacrors
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COALITION COMMENTS 6/30/94
. Possible increased flow of Horseshoe Bend water as a result of adding 60 more feet of tailings to
the Yankee Doodle tailings pond
. Earthquake effeCts on operability of pumping and treatment plan
. Earthquake effeCts on Pit from collapse of Kelley Mine wall
. Earthquake effeCts on 17Ul1I/7JQ/Je diversion struetures designed to control Pit filling
. EffeCts on availability of funds for perpetual operation in event of depression
. Potential ARCO .bankruptcy effeCts 011 availability of funds for perpetual operation
. ACts of War t~ muy shutdown facilities
. Potential for changes in government negating maintenance contraCts with County
. Increased cost of pumping and/or treatment rnaimenance
. Availability of newer, more permanent treatment technology with higher costs.
Response:
EPA and MDHES believe that the selected CWL will allow ample time to
respond to any futuer event. Please refer to General Response Points number 4
and 7 in Section 5 for additional assurances provided in the ROD to address
such uncertainties as listed here.
2. Marpin fl.' safetY: A lower Pit level provides a larger buffer against disruption of treatment of
catastrophic events that muy cause a sudden rise in Pit level. In addition, the lowest Berkeley Pit
water level possible would be desired /7y future generations because if initial treatment becomes too
costly or ineffective, future generations will search for another solution, probably a more peT'7'f'Ul1Jent
solution that doesn't require perpetual care. The less Waler they are faced with cleaning up, the fewer
made to implement a non-treatment solution.
Response:
EPA and MDHES believe that there already is "a larger buffer" (see response
to Section 5. Section C, re~ponse to item 1 and responses to comments in
Section 3.1); and we have provided other assurances concerning the
construction of a facility well ahead of when the CWL is approached. EPA
and MDHES also believe that no valuable purpose will be served by lowering
the Pit water level at this time. See responses to comments throughout the
Responsiveness Summary, particularly in Sections 3.1, 3.5, 3.9, 3.15, 3.16,
and 4.10.
3. Obnration to Acc~pt Remonsibilitv: The Coalition believes that the present generation must
provide the best available treatment option and implement it as soon as possible. All 19 alter7Ul1tves
considered by EPA shift the burden of responsibility from the present generation to futurt generations.
This is not good public policy. Also cumulative effeCts may be untenable, economically and
environmentally, for continuation of the quality of life present generations enjoy. 1M present
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COALITION CO~IME!\'TS 6/30/94
generation should implement an effective solurion Qnd then not permit the Pit water level to rise
farther.
Response:
EPA and MDHES acknowledge this comment and would add that the Preferred
Alternative combines the best componentS of the evaluation criteria. In regard
to the Pit water level, see previous response.
4. Therefore. the present eeneration must imDlement an alternative that holds the Pit at the level it is
at when the soonest Dossible effective solution CQn be imDlemented. This option provides time for
testing and designating a more effective treatment technology than the currently specified method of
hydroxide precipitation.
Response:
EP A and the State do not believe that lowering the Pit to a lower level
significantly decreases threats to human health and the environment. See
response to comment in Section 5, section C, response to item 2.
D. Treatment Technology to Drive Final Pit Level
1. Deadlines to be SDecified in Interim ROD: Rather than ~'ait nearly 30 years hoping and wishing
for new, inexpensive technology for cleaning of Pit water, new technology can be encouraged now by
employing entrepreneurial American competitiveness, capitalism and market forces. Deadlines drive
action and innovation just as the)' did in the space race's moon landing. The race to restore and
conserve our planet needs deadlines, too. Waiting thirty years shows blatant disregard for our
children and grandchildren. An Imerim ROD issued in 1994 would require cleanup go forward today,
not backward from 2022.
Response:
EPA .and MDHES do not believe that an interim ROD will expedite remedial
activity in this operable unit. An amendment to the ROD (or an ESD) can be
done if changes are necessary. See responses to commentS in Section 3.11B,
3.2, and 3.3.
2. Soonest Operation date to be SDecified in Interim and FinQI Record of Decision: The imerim ROD
would specify that the pumping and treatment facility be designed, constructed and tested to accomplish
full operation by 2002. It allows that the pumping facility can be addressed first, i17ll7l£diately after a
water balance budget determines the maximum capacity for the facility, because a pumping pla1ll would
not have to change depending on the treatmem technology chosen. The /merim ROD would also
specify the schedule for the treatment facility in order to accomplish the fully operational end date of
2002.
Response:
EPA and MDHES believe that an interim ROD, which called for a treatment
far:iJity to be op~rational by the year 2002, would not be more protective than
the Preferred Alternative. See.responses to comments in Sections 3.5,3.9 and
4.9.
3. TechnolofV Develo])mem Process: The U.S. Depanment of Energy is curremly funding a public-
private partnership to test treatment technologies for remediation of Berkeley Pit water (plus other
applications). Efforts would be made immediately to obtain additional funding from EPA's SITE
program or other research gramors so more than the current tWo to three technologies per year can be
RS5-11
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COALITION COMMENTS 6/30/94
evaluared. 17u! 11Ilerim ROD issued in the fall of 1994 would specify that such a research group work
with EPA and an oversight council (or community working group) in the Extended FS stage:
. In late 1994, to call for new technologies internationally. Any organization interested in
benefitting from extracrion of metals from Bune's mine flooding:
,/ must come forward y,,'ith their bench-tested technology and results by a date no later than tWo
)'ears from date of the invitation (fall, 1994); or
,/ those who cannot afford to test and cannot find investors must quickly submit their technology
to the research organization(s) for possible evaluarion and testing (during the same tWo )'ears)
if the process shows pote1llial.
. By end of the third year, the top one, two or three treatme1ll technologies will have been selected
from all subrrzissions.
. By end of the fifth )'ear, these top entries will have been pilot tested and further cost analyzed, with
the most effective one technology selected and specified in the Final Preferred Plan and Final ROD
issued in 1999.
.
17u! Interim ROD will have' specified that by the end of the fifth year (1999), the pumping plant will
have been designed and constructed and that, in years six and seven (2()()()'2001), the treatmenl
facility is designed and constructed.
. In year eight (2002), pumping and treatment begin. By the end of that year, de-bugging is
completed and full pumping and treatment operations take place to hold the Pit water level at its
2002 elevation (or to reduce the elevation if that was required due to earlier sensitivity analyses).
Response:
EPA Region VITI and MDHES will be advocating additional Federal funding for
innovative treatment/metals recovery technology development and demonstratio~. The
ROD also calls for a reevaluation of treatment/metals recovery technology when the Pit
level reaches the 5,260-ft level. We also panicipate in a consultative role in the DOE
Resource Recovery Project, which is currently testing treatment technologies at MSE,
Inc. in Butte. We do not believe that a time line for forced implementation of
unspecified technology, as is suggested in the CFC plan, is appropriate.
E. West Camp
1. The Critical Water Level in the West Camp's 7ravona Shaft should be set lower than the Silver
Bow Oeek level of 5,410' whtre it exits tht Summit Valley. EPA's Prefe"ed Plan would make
pennane1ll the 7ravona shaft's 5,435' CWL (critical water level). 17u!refore, the conlaminated Waler
in this shaft would tend to flow toward Silver Bow Oeek because the creek is lower and there are no
bulkheads to preve1ll it from flowing there.
It may be importanl for water in the West camp to be kLpt al the same level as thal in the East
camp to preve1ll the Pit water level from rising in the future if water pressure deteriorales one of the
marry flooded concrete bulkheads dividing the camps. These bulkheads were designed to save pumping
costs by allowing West camp waters to rise while dewatering continued for operations in the East
camp. There may be no bulkheads on upper levels. On lower elevations, depending on hydraulic
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COALITION CO~fMEJ\TS 6/30/94
head. they may not be adequate to withstand a \l'afpr pressure reversal from rising of the more
voluminous East Camp warer.
Until the additional data is made available on locations of bulkheads and the stresses to them.
the Interim ROD should at least require that the Critical Water Level in the Travona shaft (presently
set by EPA at 5,435') be lowered to an elevation less than Silver Bow Creek's 5,410' elevation where
it leaves the Summit Valley. 'The Interim ROD should specify that, depending on new data to be
generared in the Extended RI, the Travona may immediarely be pumped down fanher and be
maintained ar the elevation ofwarer in the East Camp.
Response:
EPA and MDHES believe that the West Camp System CWI.. of 5,435 ft will
ensure that bedrock water in this system continues to flow toward the Travona
Shaft. This CWL establishes a gradient from the West Camp toward the
Berkeley PiuEast Camp System thereby ensuring that water from neither camp
exits the operable unit. See responses to comments in Section 4.10E.
2. Water Ouality: Treated mine warer must comply with warer qualiry regularions, Since 1989, EPA-
DHES (Montana's Depanment of Health and Envir?nmental Sciences) have allowed contaminated
warer to be pumped from the Travona to the Butte Metro Sewer (under a contract betWeen the County
and PRP's). Stare water qualiry exceedances for arsenic and iron are thereby diluted through mixing
with sewage. Under the Preferred Plan. the Agencies would continue this arrangement until the
County finds they cannot comply ""rith increasing standards for Silver Bow Creek and opts out of the
contract. The Coalition believes the Agencies must insist on compliance rather than setting a bad
precedent for potentially relaxing other water qualiry standards thaI may be imponanr to recovery of a
fishery. A treatment plant has already been designed as a contingency and should be put into
operation as a requirement of the Interim ROD.
Source of contaminared warer west of Butte in the Green Lake seep would be determined now.
Qualiry sampling immediately should determine if thaI wateT is from the East or the West Camp,
thereby helping to verify if East Camp water from the nonhwest portion of the Hill is, as the Agencies
hope, draining toward the Berkeley Pit. .
Response:
The Travona Shaft PRPs are required by past orders with EPA to build a
facility to treat West Camp water to water quality standards if it can no longer
be treated in the Metro Plant. We do not believe that construction of a
treatment facility at this time is appropriate. We believe that this construction
should be coordinated with the Lower Area One groundwater treatment plant
design and construction. Investigatory work on the Green Lake seep is beyond
the scope of the current RIIFS; this may be addressed in activities of the Non-
Priority Soils Operable Unit.
F. Financing
1. PRP's Must Provide Bonds Upfrontfor initial building costs, and to endow perpetual operation and
maintenance, plus a special fund for upgrading treatment facilities.
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COALmON COMMENTS 6/30/94
Response:
EPA and MDHES will use whatever enforcement authority is necessary to
ensure that the PRPs pay all the remediation costs. We are presently
evaluating whether or not such bonding is possible or practical.
2. Investme1'll Q.f Short-Term Savings in Treatment TechnoloflV Research and DeveloDme1'll: aean ups
should proceed immediately after issuance of the ROD. In some exrraordiTIQry cases like the Berkeley
Pit, it may be advisable to delay clean up for a reasoMble time to actively develop new technologies
(not wait hopefully for their development). When such a delay is deteaed, the savings on operating
and mai1'llaining a conventional treatment pla1'll, and the interest earned on what would have been
spe1'll on construaion, should be colleaed from the PRP and invested in developing new technology. If
a new technology is developed that is wholly or partially funded by the PRP, the PRP would benefit
from other applications.
~ mo "" that is saved annually from delay of clean up should be invested in reducing inflow
to the Pit and Ic.Searching and developing new technologies.
Response:
The idea of collecting monies from the PRPs as soon as a ROD is issued and
then investing it in developing new cleanup technologies is not possible under
current Superfund regulation.
......
The Coalition calls on M01l/QTIQ's legislative delegation and leaders to help convince EPA to look
seriously at this proposal. It refleas the thinking of dedicated engineers and scie1l1ists who have been
involved with the Mine Flooding OIU for years, plus the wishes of affeaed reside1l/s, as clearly
evidenced by over 10% of Bune citizens having signed a petition that EPA reduce the water in the
Berkeley Pit and clean it up now.
Document/Task
Compl~tion Dat~
Call for New Treatme1'll Research Funding
List of Private Wellsnmplications
Sensitivity Study of Existing Data by EPA
Issue Alte17UJJe Pum for Public Comment
Issue Interim ROD (required items below)
Call for New Treatme1'll Technologies
Comprehensive Monitoring Program
Impleme1l/ation Begins
AdditioTZQ/ Inflow Co1'llrols Implementation Begins
New Data Generated as in .A. above reo water
budget, modeling, sedi1ne1l/S, etc.
All Bench Tested Technologies Received
Top Treatme1'll(s) Seleaed for Pilot Testing
Pumping Facility Design and Construction Stans
One Treatme1l/ Selected for Prefe"ed Plan
Issue ExtelUWl Rl-FS
Issue FinIIl PrtJerrtd Plan
July, 1994
July, 1994
August, 1994
September, 1994
October, 1994
October, 1994
Oaober,l994
October, 1994
October, 1996
Oaober,I997
October, 1997
October, 1997
September, 1999
SepUmber, 1999
November, 1999
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COALITION COMMENTS 6/30/94
. Public Comment
Issue FilUll Record of Decision
December, 1999
Design and Construction Starts for
Treatment Facility
Completion of Pumping Facility begun in 1997
Completion of Treatment Facility
De-bugging of Pumping and Treatment Plant
Pump and Treal Planl Fully Operable
January, 2000
December, 2001
December, 2001
December, 2002
Appendix
EPA Reliance on Assum"tions. Theories and SpeculaJion
As EPA knows, the extreme complexity of the Butte Hill defies eary answers to remediation of
cOnlaminaJed waters flooding the underground mines and the Berk£ley Pit. EPA has investigated the
problem almost from the day ARCa discontin14ed the centuries-old pumping of the mine runnels on
Earth Day, 1982. However, .EPA's Rl-FS and Preferred Plan documenls unveiled January 27, 1994
lack community support. Volume of contamination allowed in the Berk£ley Pit in perperuity is lik£ly
the most serious issue to face Bune. People lack confidence in EPA's Plan because of Us
fundamenlal reliance on assumptions, theories and speculation, cumulaJive effeas of which could
be calastrophic to the communily and the headwalers of the Clark Fork IUver.
Response:
Tbe Preferred Alternative selected by EPA and MORES is based on thorough
studies in the areas of hydrogeology, geochemistry, geophysics, and process
engineering. The selection process also involved a detailed fiscal analysis of
all the potential alternatives. During the RIIFS, all site data were analyzed by
scientists and engineers working for EP A and MDRES in order to thoroughly
evaluate the known and potential environmental and human health problems.
All the ideas developed about groundwater contamination are based on the
available data and the use of state-of-the-art scientific and engineering
principles.
Some people fail to recognize the matrnitude of the groundwater contamination
problem and therefore still contend that the groundwater can be permanently
remediated. Uninformed individuals have not grasped the fact that the
bedrock aquifer in the Berkeley PitlEast Camp System will be contaminated
forever due to the impossibility of preventing groundwater from entering the
greater than 3,000 miles of tunnels and shafts (and the Pit) and contacting
sulfide- and metal-rich rock. This contaminated groundwater will never be
"cleaned up"; it will need to be treated in perpetuity. In fact, allowing the
highest water level possible in the System without allowing a discharges out of
the System will reduce the amount of acid mine drainage generated (see
Section 3.9). .
RSS-IS
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COALITION COMMENTS 6/30/94
A. BUlte's Concerns
The people of Bune assumed that designation as a Superfund clean up site meant EPA would
conduct a -clean up. to decrease volumes of toxic water and then discharge cleaned water in a timely
manner. While watching the elevation of the Pit water rise, the people criticized EPAfor taking ten
years for the studies. Th£y were amazed to learn in April 1994 ads by the Qark Fork Coalition that
EP A 's preferred remedy would allow the elevation of contaminated waler to rise to within feet of their
basements before any of it would begin to be cleaned and discharged - in the year 2022 - another 28
years off., The people of Butte assumed that EPA would take into consideration their concerns:
Response:
.
Decrease in values of homes near a 500 acre toxic lake,' inability to sell homes
.
Concern for purity of water from existing wells (without instituting well bans)
.
LOss of the economic benefits of drilling one's own well; loss of rights
.
Potential flooding of basements from possible saturation of alluvial aquifer
.
Hazard to car and plane passengers as fogs spill out from the Pit
.
Constant worry about land stability as the mines fill
.
By remedy time in 30 years, much current knowledge about the site will be gone as
old-timers die
.
Future-unfriendly decision to require the next generation to implement a remedy
.
Unfriendliness of saddling all future generations with a very short time in which to
react to potential operation stoppages, whether due to economic collapse, social
upheaval, war, weather, earthquake, etc.
.
Potential benefits of developing a holistic approach to Pit remediation
.
Loss of future minerals extraction opportunities as Pit floods
.
Possible adverse effect on ability to attract new industries and health, elC.
professionals
.
Perpetual worries of downstream folks that toxic ground waler will migrate there
.
,Downstream sites not cleaned up for over 30 years because of Pit delay.
The Coalition wrongly asserts that EPA has not taken citizen's concerns into
account in the selection of the Preferred Alternative. EPA and MDHES have
considered all public concerns and have used the commentS that are based on
sound scientific, engineering and fiscal principles in the screening and
selection processes. Many of the issues raised above are socioeconomic issues
which EP A cannot address under Superfund. Section 1.2 demonstrates how
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COALlTIO:"
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COALITION COMMENTS 6/30/94
L.
Groundwaler - Pit Dynamics
.
Modeling of ground waler flow assumes constant head pressure al depth, a possible
assumption given Bune's intricate 3.500 miles of tunnels extending over a mile down from
surface, along with elevated water temperatures at most deep levels, none at others
(Neversweat shaft), and Butte's surface seasonal temperature effeCts on Pit water. Hydrology
students employed by the Citizens' Technical Environmental Committee (CTEC) have
cautioned that EPA does not have adequate informo.lionfor modeling assumptions made.
They have also provided EPA with cautionary informlllion regarding limitations of models in
decision-making and degree of dependability of models. A better idea of what is occurring at
depth could have been obtained through computer modeling based on actual mine .stope.
books. Despite a 1D-year study that cost $10 million, these factual dllta wen not reviewed.
Response:
EPA and MDHES fully understand the limitations of the groundwater
modeling used in this RIIFS. The Agencies believe that the results of
groundwater modeling are reasonable and accurate for their intended uses.
EPA and MDHES are grateful to CTEC (and others) for providing valuable
input to the understanding of Pit dynamics.
.
WriJe-off of bedrock aquifer: Public information on the decision to write off the bedrock
aquifer has been inadequate. The intention not to clean up the water wasn't clearly conveyed
to the community; justifications have not been provided to the Coalition, CTEC or other
interested citizens. EPA evidently assumed that the public did not need to know aboUt this
loss in perpetuity of rights to aquifer water resources. The Coalition believes a public
commelll opportunity is necessary, especially since the decision originates from a new,
organic contaminant-based EPA guideline that the Surgeon General's ojJice indicated was to
be rarely used. It would set a precedent for mining-related waste remediation. Many Butte
people conjecture that this write-off is a critical link in ARCO's ability to allow the Berkeley
Pit to fill and remain full forever. Modeling of the deep bedrock water was not adequate
(assumed constant head pressure), and withoUt additional knowledge of the dynamics of that
aquifer, it is premature to write it off. Additionally, water in the Berkeley Pit portion is not
ground water, but an EPA creation of a surface water impoundment. As such, it may not be
subjeCt to the .ground water. write-off guideline.
Response:
EPA and MDHES have not .written-off"'the water in the Berkeley Pit. We
have determined that the bedrock aquifer waters will not meet State and
Federal regulations (MCLs). This is the case regardless of the CWL or the
technology employed. Remediating the bedrock aquifer is technically
impracticable. Bedrock groundwater is, and will always be, flowing intO the
more than 3,000 miles of tunnels and shafts and becoming contaminated with
arsenic and metals. We expect better water quality in the bedrock aquifer if
the Pit is allowed to approach the CWL than if it is stabilized at current levels
or lowered. This water is being addressed by the Preferred Alternative.
.
ConllDnilUllion mtllSts ignond by EPA in Rl-FS and Pnftmd Pliua: EPA negleCted to
inform the community in the Rl-FS or Prefe"ed Plan for this DIU that contaminated bedrock
water is exiting the Summit Valley via a .gaining. Stream at the end of the Colorado Tailings.
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COALITIO~ COMMENTS 6/30/94
EPA and DHES (MonraM Department of Health and Environmental Sciences) state that as
che Pit rises, water enters is more slowly. Inflow began at about 7,000 gpm, and is not at 5,000
gpm. But the agencies were unable to satisfactorily answer comment period questions about where
the other 2,000 gallons go. EPAIDHES stated, "water cannot leave the Berkeley Pit, " "water is
pulled in/o the Berkeley Pit cone of depression and cannot exit." However, they recen/ly
acknowledged to the Coalition, "yes, poor quality water is upwelling from bedrock below the
Colorado Tailings, but is probably not from the East Cmnp or the Pit In our opinion. "The Bureau
of Mines estimates that 95 % of the water entering Silver Bow Creek at the poin/ COT7U!S from the
bedrock aquifer. The Coalition estimates that the Pit/East Cmnp bedrock makes up 90% of the Mine
Flooding DIU. It includes a large cadmium plume according to data generated by the Natural
Resources Damage Program. .
The Silver Bow Creek Phase ll'Rl Work Plan of 3/31/89 for the Area One DIU states on page
5 that the bedrock ground water .~'stem at the Colorado Tailings would be evaluated n:ler Mine
Flooding studies~ This evaluation was not done. The Coalition was recently told that studies of water
qualit)' at the end of the Colorado Tailings are not thorough enough nor recent enough to determine
whether or not Pit s)'stem water is involved, or ifreleases might be related to increased
elevation/saturation of mine flooding. The Coalition is now told this mine flooding release does not
exit wiJhin the Mine Flooding DIU, so would not be addressed until some future time under both
Priority Soils and Streamside Tailings O/U's.
The Mine Flooding R1 states that alluvial contamination follows ground water flow patterns;
that ground water south of the Berkeley Pit flows toward Silver Bow Creek. The alluvial aquifer is
cOn/aminated along the length of the Metro Storm Drain and both nonh and south of it.
Contaminated ground water from mine flooding is, therefore, being released into Silver Bow Creek at
its confluence with Black/ail Creek. Releases due to mine flooding must be addressed under the Mine
Flooding DIU and must be completely researched.
Response:
The Coalition contention that contaminated bedrock aquifer water is exiting
the operable unit because Silver Bow Creek is a gaining stream is not
supported by the available data. Groundwater divides for both the bedrock
and alluvial aquifers exist between Silver Bow Creek and the MFOU.
Groundwater on the north side of the divide flow toward the Berkeley Pit/East
Camp System while groundwater on the south side flow in the direction of
Silver Bow Creek. Thus, groundwater contributions to Silver Bow Creek do
not come from the Pit System; they are from the aquifers to the south of the
groundwater divides.
.
Assumption tluU role of Pit filling is decreasing is not proven by data,. Equilibrium is not
evidenJ: Iftlu Pit does stop rising, then water is escaping somewhere. Datafrom the
Montana Bureau of Mines shows that water in the Berkeley Pit rose over tWO feet more during
the one year period May-April 1994 than it did during the s~ period ending a ytar earlier
(24.5'from 5/92 to 4/93 vs. 26.64'from 5/93 to 4/94). These numbers do not consider
widening of the Pit as water rises, so even more water actUally entered the Pit in the last
year. Pit filling is not decreasing and water in the Pit could require pumping in less than ten
years.
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COALITION COMMENTS 6/30/94
Response:
As the Pit level increases, groundwater inflow decreases because of a decrease
in hydraulic gradient and the increased storage volume in the Pit. The long-
term impact will be a slowing down in the rise rate of the Pit. This decrease
may vary depending on the precipitation for that year and the degree of inflow
control for that year. The higher more recent rise rate can be expected
because 1993 was a very wet year and Horseshoe Bend is not yet under
control.
.
Accuracy of Water BaIIlnce is questio1UJble: Use of averages in Rl-FS may cause
underestimation of true amounts of water necessary to be divened to control inflow. The 2.5
mgd (million gallons per day) from leaking municipal water supplies was not included in the
waler balance. Horseshoe Bend water was al a higher volume in 1989 than today (4 mgd
then: 2.4 mgd in Rl) and is said to have increased recently. The possibility of increased
waler ci!charge due to Planned expansion of the Yankee Doodle Tailings Dam another 60' in
height h7JS not been explored. The actual volume of water in the Berkeley Pi! is unknown,'
therefore, there is no check on what amflunt ofwaler is possibly leaving the Pit through
ground Waler. Unless an accurale wat~r balance is developed, leakage would go undetected.
/fwaler is escaping now, large volumes could escape before the stan of pumping. /fit is
impossible to develop a good water balance. it becomes critical that early precautions be
taken - pumping and treating Waler as soon as possible.
Response:
EPA and MDHES used conservatively high water inflow figures during the
FS. The Agencies believe that the water balance developed during the FS was
adequate to select the Preferred Alternative. Using higher inflow figures
would not have changed the treatment approach. Also, the PRPs are aware
that they will be held legally responsible under the ROD for treating the
volume of water necessary to stabilize the Pit level, even if this volume
increases significantly from the present estimates.
.
ArbiJrariness oflocolion of East vs. West Camp water divUlt: Without monitoring wells. the
localion of the water divide is unknown. For example, expens al the Bureau of Mines are not
convinced the Moose drainage concludes in the East Camp. Decisions based on location of
this divide should be questioned.
Response:
The ROD will contain a provision for the installation of new bedrock wells in
the West Camp, wbich will give us additional knowledge concerning the
divide. However, EP A and MDHES believe that the groundwater divide bas
been adequately located and that pin-pointing its exact location would not
cause the Agencies to alter the Preferred Alternative.
.
Condition of bulkheads between East and West Camp is not known: yet EPA Plans to rely
in perperuity on these concrete barriers to keep water al higher elevations in the West Camp
from breaking through to the East Camp and flowing into the Pit.
Response:
EPA and MDHES reaJize that the condition of the bulkheads may deteriorate
and bave purposely set the CWL in the West Camp System above that of the
Berkeley PitlEast Camp System so that the groundwater gradient will be
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COALITION COMMENTS 6/30/94
toward the Pit System. Failure of this bulkhead will lower the West Camp
and will not create at threat to human health and the environment.
.
Cone= ':j Depression influences nut projected: The Berkeley Pit cone of depression,
combined with the one being created by the East Continental Pit, may create an exponentially
larger cone of depression that can have enormous effects on ground water under
neighborhoods not yet affected by contamination or dewatering. Loss of stream water near
the Country Qub would affect landowners there. Owners of homes built on formerly swampy
land that dried after the Berkeley Pit began operating in the 1950s (e.g., St. Ann Street) fear
that saturation of the bedrock aquifer may bring an influx of alluvial water to flood
basements. Projected mining company Plans should be investigated to determine their
potential to affect Berkeley Pit contaminant ground water migration. Without contingency
Planning, at some point, control of Mine Flooding waters could be lost.
The '" .:I>l of inj/uence of the Berkeley Pit cone of depression is said to take in the entire East
Camp, or about 90% of the Mine Flooding OIU. The public was never given clear,
scientifically sound data to explain EPA's position that the cone of depression's influence
extends throughout mine tunnels that are lower than the surface elevation of the Pit water, let
alone beneath the bonom of the Pit. Infact, the gradient into the Pit is unknown below the
surface of Pit water.
Response:
EPA and MDHES believe that the cone of depression that currently exists in
the Pit System is adequately characterized. Estimating the potential impacts of
possible future mining operations on the cone of depression is beyond the
scope of the RIIFS.
The Coalition's contention that EPA did not provide the public with clear,
scientifically sound data regarding the fact that the cone of depression extends
to tunnels below the surface of the Pit is untrue. Discussions of these data
have been presented in the RIIFS documents and this information has been
present and discussed extensively during public meetings.
.
Impacts to alluvial aquifer IDrgely ignored: Other than concern for migration of
comaminanrsfrom the Pit, EPA/DHES have either assumed the alluvial aquifer will not be
impacted by rising ground water, or they do not feel it is relevant to the remedy. Ted Duaime
states that when the Bureau of Mines provided the Agencies with its opinion of the safety of
the bedrock aquifer for the Preferred Plan, they were not asked to give an opinion on
li}Jrologic impact to 1M alluvium. While they have no data to refute safety of the 5,410
elevation for the bedrock aquifer, they have no idea how the alluvial aquifer will react to
having a saturated bedrock aquifer. Again, there is a possibility of wet basements.
Response:
Modeling conducted during the RIIFS indicated only minor impacts on the
alluvial aquifer and we do not expect large impacts on alluvial water levels.
We do, however, understand the limitations on such modeling; and we are,
therefore, relying on a very comprehensive monitoring program to follow the
hydraulic impact of the rising bedrock aquifer on the alluvial aquifer. There
is high concentration of monitoring wells in the area (Upper Metro Storm
Drain) where the earliest impact (if any) would occur. The Priority Soils
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COALmON COMMENTS 6/30/94
operable unit RI/FS also will address this issue and the a!temative for
addressing contaminated alluvial groundwater in the Metro Storm Drain.
.
Induced injilJrotion potential is not adequalely addressed in the documents. Can
contaminated water from the hill or the cadmium plume beneath the old Silver Bow Creek bed
travel soUth and contaminate private wells? if a new industry requiring high volumes of
ground waler came to Butte, could it pull contaminated water toward other wells?
Response:
Contaminated water outSide the cone of influence of the Pit System will be
addressed during the conduct of the Priority Soils RIIFS. Such pumping as
described could not draw contaminated bedrock waters into the alluvial
aquifer.
.
PotentiIII Mine f1ooding-relOted well bans wert not clearly delinemed. 17wugh well bans
were allUded to in the FS, in meetings held prior to the end of the public comment period for
this OIU, there was no infonnation about where such bans might be enacted, nor abour any
privale wells possibly being closed. Consequently, affected residents could not comment on
potential wells bans. Some addresses of private wells tested are listed in RI. In May, after
close of the comment period, a GIS (Geographic Information Systems) map was shown to
members of the Count)' Water Quality Task Force, delineating contaminated alluvial aquifers.
Two addresses listed in the RI as having exceedances of cadmium, among other metals, are
outside the mapped boundary of alluvial contamination (1920 Elm, 1940 Oregon). It appears
that dala are still incomplete or inaccurale and, unless they are contacted ilidtvidually,
residents will remain unaware of any potential closure or ban on new wells.
EPA's Prefe"ed Plan either assumes community acceptance or, as implied in the FS, a
Count)' zoning ordinance may implement ARCO-initiated well bans on private propeny, An
ARCO-County contract calls for Institutional Controls such as Superfund-related well bans.
Under it, ARCO provided seed monies for the Counry to establish a task force to recommend
whether or not a Water Quality District should be formed to deal with post-Superfund well
bans among other issues. After close of the comment period, the taskforce was shown the
contamination map, bur it was staled that no residential wells were expected to be affected.
Wuhour site-specific information, the community could not possibly have commented on well
bans during the comment period for. community acceptance. criteria.
Response:
EPA and MDHES plan to fully discuss the ramifications of the ARARs waiver
for the bedrock aquifer with Butte-Silver Bow and the public. A full public
discussion of the institutional controls needed to protect human health and the
environment is necessary before any decisions on IC implementation can be
forthcoming.
.
NkqUDcy of studUs is questio1U!d by Dr. Bob Robins, an international expert on arsenic
chemistry and environmental impacts of mine wastes. Dr. Robins' major points are.'
,/
TM ComprtMnsil1t Monitoring Program .should have been in place before now... .
,/
Gtodumistry and hydrology are not completely underStood at prese1ll
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COALITION COMMENTS 6/30/94
./
SedimenJ study of the Pit is needed
./
Strong microbiological study should be included in comprehensive monitoring
program
./
A complete water balance on the whole Pit system is needed.
Dr. Robins states that data are not available to show the influence of ground water on deep
ground water. He does not believe a suggested upflow of deep groundwater from the bedrock into the
Pit is realistic,' rather, he believes a downjIow of Pit water will be present.
Response:
L
This comment is addressed under the responses to Section A "Additional Data".
u,al- UnwarranJed Waivers of EPA's Own Remed.] Selection CriJeria
ShoTt-Tenn Effects
./ An increase in conJaminanon volume, toxicity and mobility from today's 25 billion
gallons to 56 billion in 2022 is certainly notable.
Response:
'"
./
Impounding between 25 and 56 billion gallons of surface water in a toxic state over
the next 30 years adversely affects in-stream flow.
./
Massive impoundment may adversely effect potential uses by water rights holders.
The Qark Fork River Basin is closed to new water rights because it is 50 shorr of
water; yet, here water would be impounded and made severely contaminated.
./
Berkeley PiJ water impoundmenJ created by the Preferred Plan should hDve G
beruficiol use. None is evident. Pit water is not used by the active mining operation.
It is surface .waters of the State of Montana. and should not be allowed to become
more contaminated. .
./
Technical expertise and sue-specific knowledge would now be unavailable at remedy
time 30 years from now (due to human life span), requiring high cost of educating
new players and higher potential for error.
./
Short-tenn disregard for inJenJ and meaning of the tenn "dean up, . as in
.Superfund Qean up. vs. generation of a 56 billion gallon toxic lake. Preferred Plan
is a postponement, not a clean up.
./
Nothing is deaned for 30 years.
We believe that reduction of the AMD generation rate and the concentration
of metals in the AMD will be reduced by allowing the water level in the
System to :.pproach the CWL. We believe that these reductions are more
important than reducing the volume stored in the System Many of these
commentS are related to water rightS issues and not related to protection of
human health and the environment. EPA and MDHES believe that these
-------
COALITION COMMENTS 6/30/94
issues should be addressed as Natural Resource Damage issue and not a
remediation issue. See Section 3.9.
Long-Tenn Effectiveness
./
Perpetual ejfectiveness of a 10weredPiJ le~'el was not adequalely researched due to
assumption of excess cost (statement in Preferred Plan document).
./
Cost of Preferred PUln 11Uly be underesti11Ulted: At under $60 million, it is less than
the reponed cost in 1973 of the pumping Plant in the Kelley Shaft which is now
underwater.
./
None of the alternatives address whal will occur after 30 years.
./
None of the alternatives discuss life span of the pumping and treating system and
Aas of God, etc. thai might interfere with operation in perpetuity.
./
Use of the metro sewage Plan/ to treal con/aminated waler from West Camp Mine
nooding disregards Long-term effectiveness requirements.
Response:
EPA and MDHES believe that a lower Pit water level will not significantly
decrease risks to human health or the environment; therefore, lowering the Pit
water level is not recommended.
The costs presented in the FS were thoroughly reviewed by independent
contractors for EP A and MDHES with expenise in constructing and operating
these types of water treatment facilities. EPA and MDHES believe that these
costs are within the accuracy for their intended purposes. Costs were
projected for a 30-year period as specified in Superfund guidance for cost
comparison purposes. The actual cost for running a treatment facility in
perpetuity will be more than the cost stated in the FS.
The -reponed- cost of the Kelley Shaft pumps is irrelevant to the cost of the
alternative. EPA and the State question the validity of the 1973 $60,000,000
figure. Costs developed by the Agencies to install pump(s) and piping in the
Kelley Shaft is approximately $16,000,000, in 1994 dollars. The cost of
remedy is considerably more than the costs of the pumps in the Kelley.
Regardless, we believe the costs of pumps are irrelevant as, compared to the
cost of the remedy.
West Camp Sy\:tem water will be treated in perpetuity in the Metro Plant and
a subsequently constructed plant. See responses to comments in Section
6.161.
.
Welter QUDlity AllAR's (AppliClJble RelevanJ and Appropriate Regulations) for 7Tavona Mine
exceedances and for bedrock aquifer discharges to Silver Bow Creek al't not met.
-------
COALITION COMMENTS 6/30/94
Response:
Travona water is treated in the Metro Plant and when the Metro Plant
discharges water to Silver Bow Creek it meets State water quality regulations.
.
Reduction of Volume, Torici/y and MobiJi/y is ignored lJy allowing the doubling of Pit water
volume, increasing toxic contamination and allowing water to reach the 5,410' elevation.
Response:
See responses to comments in Section 3.9.
.
Threat of ConJtunination Release is increased, not reduced, at 5,410' level through potential
energy of that volume, and weight of contaminated water seeking lower pressure outlets.
Response:
EPA and MDHES believe that the threat of release will not be increased by
allowing the Pit level to rise to below the S,410-ft level.
.
VisibiJiJjstandards of the Clean Air Act were not investigated for fog emanating from the Pit
and its effea on safety of auto and air traffic.
Response:
See responses to comments in Section 3.121.
.
Assessment of negligible impact of water fowl resting on the PiJ water relies on inadequate
amount of research data and does not projea impaa when Pit is 500 acres and near surface
level.
Response:
See responses to comments in Section 3.12C.
.
New remedy selection criJeriD developed: Avoidance of litigation with PRP's joins cost 10
drive dean up decisions. EPA representatives have stated that ARCO threats of litigation
prohibited them from changing their prefe"ed remedy.
Response:
This statement is untrue. The Preferred Remedy was selected by EP A and
MDHES and will be modified by the Agencies based on important new
information or comments received during the public comment period. Threats
of litigation will not influence the Agencies' decision. The decision must Dot
be, however, arbitrary and capricious.
.
CommuniJy Acceptance -Inadequate communication ~1th the public: EPA assumed that
citizens would spend whole evenings at technical meetings to learn aboUt the Pit clean up
Prefe"ed Remedy. They assumed the media would accurately present the story to the public
even though KXLF-TV reporters immediately complained (January 27 presentation to Bune-
Silver Bow County Commissioners) that the)' did not know how to report on the Pit flooding
when they were unable to understand it themselves.
EPA meetings emphasized diversion of Horseshoe Bend water, which is only a small part of
clean up. They down played Pit water rising for 30 more years - the only thing most folks
really care aboUl. It took two of the three months of the comment period for CIEC and
Coalition mt:llwers to attain a fair understanding of the phenomenal amount of data released
simultaneousl)' on January 27 for public comment, and questions continue to be asked. The
Coalition wrote EP A asking that they communicate on the few areas of greatest concern to the
-------
COALmON COMMENTS 6/30/94
community, using prepared television messages and talk show appearances. EPA used the no
COSI shows, but the message continued to divert anention away from delayed clean up of the
rising Pit. People were surprised 10 learn the truth aboul the Pit from Coalition and CTEC
media interviews andfrom Coalition telephone polls, ads. handouts, posters, speeches and
events. A petition circulated by the Coalition was signed by over 10% of County residents
through linle more lhan Ihree days effort. Whatever comment EPA received prior to the end
of the official public comment period is undoubtedly slight compared to what it could have
been if EPA had truly valued public input. EPA stated at the outset that they would not
change Iheir Preferred Plan without solid technical or legal reasons to do so; therel1y shutting
our comment from all but a small elite group of engineers and mining professionals. Affected
residents' opinions were not considered worthy by EPA. EPA wrongly assumes the public
has the time, money and expertise to technically c1UJJlenge a Preferred Pli1.n tMY do not
accept.
Response:
EP A and MDHES provided the public with numerous opponunities to ask
questions regarding any aspect of the Mine Flooding RIIFS process (see
Section 1.2 and 1.3). Because of the tremendous size of this contamination
problem and the importance of it to the Butte community, EPA and MDHES
went far beyond their legal requirements for public participation - which
requires only one public meeting during an RIIFS. One of the most
significant examples of this was the creation of CTEC and issuance of a TAG
grant from EP A to disseminate technical information to the public.
:L.
lnadequaJe Treatment TechnoloFv
.
17u! Coalition believes that hydroxide precipitation should be eliminated from considerarion
immediarely for lack of effectiveness. It would either inefficiently re-treal tM SlUM minerals
perpetuolly (pit disposal) or generate a new Superfund toxic waste sile with only 5% to 7%
less waste volume than the original volume before treatment. Inadequare consideration was
given in the screening phase to other effective treatment technolorks, apparemly because
cost was given predominance over effeCtiveness. 17u! cost estimating process relied on one
individual's -best guesses, - some of which have been challenged as artificially high. 1he
review did not comprehensively evaluare alternate combinations of treatment phases. ARCO
stares new technologies are welcome only if they cost less than the 1800s-era lime treanntm,
lending the impression that EPA weights cost more than other criteria. Ultimately, the people
of Suite must toke on tIu burden of finding the most effective, cost-sensitive technology.
EPA must rescind their choice of lime treatment and insist that ARCO and Montana Resources
accommodare public and private research b)' provitJjng on-sile access to Pit and Mine
Flooding warers and intkmnih tJaose pursuing solutions todDy.
~esponse:
Costs were not given dominance over effectiveness. EPA and MDHES
believe that hydroxide precipitation is currently the most effective primary
treatment. The best potential innovative technologies for water
treatment/metal recovery are being tested by MSE, Inc. in Butte. A treatment
technology other than that identified in the ROD may be used if a subsequent
evaluation finds that it is significantly more effective and/or cost less then
hydroxide precipitation. See also respoDSes to comments in Sections 3.2, 3.3,
3.9,3.15,4.7, and 4.9.
-------
COALITION COMMENTS 6/30/94
4.
Inflow Con/rol
.
I1UJdequaJe Plan for diverting clean waler inflow from Mine Flooding and Pil: Horseshoe
Bend's 2.4 mgd of acidic waler is the only inflow to be diverted from the Pit and Mine
Flooding in the Preferred Plan. Approximately 2.5 mgd of clean water is leaking from the
municipal warer system. but was ignored in percolation assessments and remediarion Plans.
Precipitation runoff from tM Butte Hill is being diverted to tM East Camp/Pit under
Expedited Response ACtion by EPA. Water presently runs down the Moose drainage and
settles on top of the Green Mountain mine shaft which is inadequately covered. While storm
warer runoff is part of another O/U. the above named warers are part of, or are purposely
being diverted to, tM Mine Flooding O/U by EPA. These and any other controllable inflows
should be cleaned and discharged under tM Mine Flooding O/U rarher than waiting many
additional }'ears to be addressed under Priority Soils.
Response:
EPA and MDHES agree that all significant inflows to the Pit should be
diverted if possible. It is unknown what portion of the water leaking from the
municipal water system is entering either the West Camp or Berkeley Pit/East
Camp System. The Agencies will encourage Butte-Silver Bow to make
improvements to their water distribution system. Water in the Moose area
does collect near the Green Mountain Shaft but it is unclear if any runoff
water enters to the shaft. This issue will be investigated during the Priority
Soils RIIFS. The amount of water that could enter the shaft is considered
negligible compared to the 2.4 mgd entering the Pit at Horseshoe Bend. The
Agencies appreciate these comments and will consider them further during the
completion of the ROD.
~
Human Health Concerns
.
Organic conJaminants under leach pads not addressed in RI-FS or Plan: FOrrrler Anaconda
Company employees have indicared that the dumping grounds for Company-generared
contaminants are now covered by leach pads in tM aCtive mining operation. These
contaminants include solvents. acids. used grease and oil. and other organics. Given the
gradient toward the Berkeley Pit from the leach pads, these contaminants are likely to be
entering the Mine Flooding system, yet. have not been investigated in the Rl-FS. The
Agencies have assumed thm the contaminants are diluted and, therefore, not significant.
More likely, they are DNAPL (dense, non-aqueous phase liquids), seek low elevations, and
have sunk to the bottom of the Pit.
Response:
EPA and MDHES are aware of the presence of cenain organic compounds at
the MFOU. The Agencies made a decision to exclude organic contamination
from the risk assessment after a preliminary examination of data revealed very
low concentrations. See responses to comments in Section 4.12.
.
Air Quality investigations were not conducted in the RI. Studies in the larer part of this
century have shown that human health in tM headwarers of the Dark Fork River has suffered
from long-term disease designations of "highest in the narion per capita" for "all diseases, "
-------
COALmON COMMENTS 6/30/94
-lung disease - and -heart disease - as cited in Luoma and Moore's 1990 paper. A high
incidence of lung disease was found in women as well as men, indicating air quality problems
outside of the mines. There are no very recenr studies, so it is not know ifhigh incidence of
disease continues. If disease is related to metals particulate, should sources of dust, such as
Pit walls, be sealed or capped? Regardless of the water level ultimately left in the Pit, there
would still be bare soil. EPA's R1 also did not address citizen inquiries listed in a 1990 Mine
Flooding Responsiveness Summary concerning possibility of toxic gas emafUllingjrom rising
toxic mine and Pit water.
Response:
Previous air quality studies of the Butte area indicated that air quality
exceedances ~ere caused by wood smoke and dust caused by trucks during the
mining in the Berkeley Pit. Based on the available air quality data, the
Agencies do not feel that the air associated with this operable unit presents a
potential health hazard to the public. There is no indication that -toxic- gas is
emanating from the Pit.
£.
Future DiscounJed
.
11141leqUDJe consideration for perpetual technology requiremenJs, operation and
mainJenance: Given the comparatively short 200-)'ear history of the United States and the
burden of pumping and treating water forever, EPA's Preferred Remedy appears not to have
sufficiently weighed the following assumptions:
,/
Assumes money will be available for perpetual operation and maintenance by allowing
ARCO to self-insure forever; assumes this relatively young corporation will exist
forever.
,/
In selecting the remedy, EPA considers only the first 30 years' costs; yet. the remedy
would not be implemenred until after that 30 )'ears. EPA assumes that dollars will be
adequale for perpetual operation.
,/
Assumes no earthquake impacts to the perpetually operation treatmenJ PlDnJ.
,/
Qaiming to protect human health. this remedy makes iJ undesirable for hll11Ulns to
continue to live in their tradiJional homes within blocks of the nation's largest body of
toxic water.
Response:
EPA is evaluating whether or not alternative financial assuredness (e.g.,
bonding) is appropriate and practical because of the many comments received
concerning long-term financial assurances and the fact that this remedy will
require significant funding in the future. We acknowledge that the Preferred
Alternative assumes that the current PRPs, or their successors, will be
I-Hazardous Wastes From Large-scale Metal ExtractiOD: The Clark Fork Waste Complex, Mt: JohDDie
Moore, Dept, of Geology, UDiv. of MODtaD8, Missoula and Samuel N. Luoma, U.S. Geological Survey, Memo
Park, CA; V J. WatsoD (ed.) - Proc. 1990 Clark Fork River Symposium, MODtaDa Academy of ScieDcea, PII. 163-
188.
-------
COALITION COMMENTS 6/30/94
financially able to pay for the perpetual treatment of contaminated water. See
responses to comments in Section 3.18.
The costing procedures used were consistent with Superfund guidance and the
Agencies believe that they were adequate to select the most appropriate
remedial alternative. The total (or actual) cost of each alternative was not
nearly as important as the relative costs. The FS was adequate in this regard.
See responses to comments in Sections 3.7 and 4.3.
The Coalition suggests that it is dangerous to live near the Berkeley Pit; this
statement is without merit. The Risk Assessment found that there would be a
health threat if persons ingested Pit or contaminated groundwater. The
Preferred Alternative will ensure the protection of those persons living
adjacent to the Pit. See responses to comments in Section 4.12.
.
VarWbles thot could cause unconJrolled filling of the Pit in the future:
./
Assumes thot mainJaining the Pit at 5,410 feet, only 50 feet below the problem level, is
an adeqUlJle margin of safety. This allows onl)' tWO )'ears (at the cu"ent fill rare) for
future generations to recover from Acts of War, Acts of God, economic, or other
disasters before toxic water reached rhe alluvium.
Response:
See responses to comments in Section 3.1.
./
AsSumlS negligible eal1hquake impact on Yankee Doodle Tailings Dam from a 6.5
Richter nuuimum earthquake. Wirh three faults passing under this Dam, and EPA
reliance on a questionable dam safery study, this assumption is considered foolhardy I1y
many observers who believe it is more responsible to assure future residents that Pit void
space is not displaced lTy tailings from a hig~r than average earrhquah.
Response: See responses to comments in Secticn 3.17.
RSS-29
-------
-
IDENTrnCATION OF COMMENTS RECEIVED
APPENDIX 4, ATTACHMENT 1
BUTTE MINE FLOODING OPERABLE UNIT
RECORD OF DECISION
-------
The comments made in the non-technical (Section 3.0) and technical sections (Section 4.0) of this
Responsiveness Summary were summarized based on all the comments received. The commenters
were identified with a note in the parentheses at the end of each comment. The following identifies
the sources used in this Responsiveness Summary.
The Transcript or the Proceedings from the public meeting for MFOU RIfFS held on
April 26, 1994. The commenter and the number identifying each commenter listed in this
Responsiveness Summary are listed below:
1.
T1
T2
T3
T4
TS
T6
T7
T8
T9
T 10
Tll
T 12
T13
2.
John Ray
Alben Molignoni
Dan Harrington
Sandy Stash, ARCO
Fritz Daily
Dr. Richard Hammen
Dr. I.W. DeVoe
Jack Lynch
Mary Kay Craig
Bill MacGregor
Edus Giavomin
John Resing
Jim Keane
Group Comments
G 1
G2
G3
3.
CTEC comments regarding MFOU RIfFS and Proposed Plan. These consist
of letters dated February 24, 1994, April 29, 1994, May 13, 1994, and EPA
responses to comments dated April 19, 1994.
Clark Fork Pend Oreille Coalition public comments 0 Berkeley Pit and
MFOU RIIFS Preferred Plan prepared by Mary Kay Craig, Upper River Field
Representative, on April 29, 1994.
Robertson Technologies Corporation Public Comment to Preliminary Draft
feasibility Study Repon submitted by Andy MacG. Robertson, Cbairman on
April 27, 1994.
PRP Comments
PRP 1
ARCO comments regarding the Proposed Plan prepared by S.M. Stasb,
Montana Facilities Manager, on April 29, 1994.
-------
4.
Government Agency Comments
GOV 1
Fish and Wildlire Sen:ce comments on the MFOU RIIFS and Proposed
Plan, prepared by Kemper McMaster, Field Supervisor, on February 23,
1994.
Butte Silver Bow (BSB) submitted several documents which they marked Exhibit A I, A2,
and BI-BI2. These documents and comments are listed separately, but retain BSB's markings
for clarity.
s.
BSB 1
BSB 2
BSB 3 .
BSB 4
BSBS
DSB6
Council Resolution No. 1635.
BSB Local Government Comments on Berkeley Pit RI/FS and Proposed Plan
(AI).
BSB Technical Comments on Berkeley Pit Mine Flooding RIIFS, which
includes letter from Dr. Robert G. Robins dated February 25, 1994 (A2).
Excerpts of Council of Commissioners Regular Meeting April 26, 1994 (81).
Individuals providing input are identified as follows:
BSB 4-A
BSB 4-B
BSB 4-C
BSB 4-D
BSB 4-E
BSB 4-F
BSB 4-G
BSB 4-H
BSB 4-1
BSB 4-J
BSB 4-K
BSB 4-L
BSB 4-M
BSB 4-N
BSB 4-0
BSB 4-P
BSB 4-Q
BSB 4-R
BSB 4-S
Jack Lynch
Fritz Daily
Dr. Irving DeVoe, Metanetix
Joe Quilici
Dr. George Waring
Rose Brock
Albert Molignoni
Bob Pavlovich
Barbara Archer
Mary Kay Craig, Clark Fork Pend Oreille Coalition
Sandy Stash, ARCO
James Riley
Eileen LaBreche
Dave Curry
Mike Thatcher
Charlie O'Leary
Mike Kerns
Ms. DeVoe
Tom Brophy
Written comments from Dr. John Ray to BSB (82).
3erkeley Fit C ..nty Rc~olution from the Clark Fork Pend Orei1le Coalition
dated April 11, 1994 (83).
-------
BSB 7
BSB 8
BSB 9
BSB 10
BSB 11
BSB 12
BSB 13
BSB 14
BSB 15
Written comments from Fritz Daily dated April 6, 1994 (B4).
Berkeley Pit Comments from Ray Tilman (Montana Resources) March 25,
1994 (B5).
Written comments from Dr. Irving DeVoe (Metanetix) dated November 1993
(B6).
Written comments from Alben Molignoni dated February 11, 1994 (B7).
ARCO's response to BSB's draft comments on MFOU RIfFS dated April 6, .
1994. (B8)
Excerpts of Council of Commissioners Regular Meeting April 20, 1994 (B9).
Individuals providing input are identified as follows:
BSB 12-A
BSB 12-B
BSB 12-C
BSB 12-D
BSB 12-E
BSB 12-F
BSB 12-G
BSB 12-H
BSB 12-1
BSB 12-J
BSB 12-K
Fritz Daily
Mark Kay Craig, Clark Fork Pend Oreille Coalition
Frank Quilici
Dr. John Ray
Dr. George Waring
Matt Casick
Tom Brophy
Mike Kerns
Mike Thatcher
Anie Laramie
Jack Lynch
Written comments from Fritz Daily dated April 19, 1994 (BI0).
Written comments from Clark Fork Pend Oreille Coalition dated April 20,
1994 (Bl1).
Written comments from Barbara Archer dated april 10, 1994 (B12).
6.
Individual Comments
I 1
12
13
14
15
16
17
18
19
Carla Abrams, Missoula, Montana, May 4, 1994
Elaine Roberts, Missoula, Montana, April 29, 1994
Vicki Watson, Missoula, Montana, April 29, 1994
Steve Mietz, Missoula, Montana, March 30, 1994
Bonnie Gestting, Missoula, Montana, March 25, 1994
Gary Murphy, Ramsay, Montana, April 21, 1994
Maureen Markovich, Butte, Montana, April 29, 1994
Mary Duran, Butte, Montana, April 29, 1994
John and Shirley Walsh, Bune, Montana, April 29, 1994
A-3
-------
110
1 11
I 12
I 13
1 14
1 15
I 16
117
I 18
I 19
120
121
122
123
124
125
126
127
128
129
130
I 31
132
133
134
135
136
137
138
139
140
141
142
143
144.
14S
146
147
148
149
Steve Schombel, Missoula, Montana, May 2, 1994
Pia Gregan, Butte, Montana, April 29, 1994
Theresa Marie Craig, Butte, Montana, April 29, 1994
George Waring, Butte, Montana, April 29, 1994
Marian Conklin, Butte, Montana, April 29, 1994
Colette Cook, Butte, Montana, April 29, 1994
Lou Eveland, Rocker, Montana, April 29, 1994
Esme LaBauhe & James R. LaBreche, Butte, Montana, April 29, 1994
Kevin and Cindy McGreevy, Butte, Montana, April 28, 1994
Clifford and Rita Bradley, Butte, Montana, April 28, 1994
Margaret Small, Butte, Montana, April 28, 1994
Mickey Boysza, Butte, Montana, April 29, 1994
Frank Moriarty, Deer Lodge, Montana, April 29, 1994
Rose Brock, Butte, Montana, April 23,1994
Gray Davis, Butte, Montana, April 29, 1994
Bonnie and Walter Immonen, Walkerville, Montana, April 29, 1994
Audrey Daly, Butte, ~fontana, April 29, 1994
Roben and Dorothy Forsell, Butte, Montana, April 29, 1994
Walter and Barbara Kelley, Butte, Montana, April 29, 1994
Catherine Couture, Butte, Montana, April 29, 1994
Sue Gassenberg, Butte, Montana, April 29, 1994
Dan O'Neill, Harrison Avenue,Butte, Montana, March 10, 1994
Lynda Hill, Butte, Montana, April 29, 1994
Kenneth P. Cunningham, Butte, Montana, April 8, 1994
Dan O'Neill, Monroe Avenue, Butte, March 28, 1994
Mary Mulcaire-Jones, Butte, Montana, April 29, 1994
Barbara Archer and Tom Tully, Butte, Montana, April 26, 1994
Amy Lientz, Rigby, Idaho, May 2, 1994
Mike and Debra Evankovich, Butte, Montana, April 27, 1994
Kay Joslyn, Butte, Montana, April 27, 1994
Lola Evidi, Butte, Montana, April 29, 1994
Frank and Ruth Rosch, Butte, Montana, April 27, 1994
Annette Gustafson, Butte, Montana, April 26, 1994
Mary Miller, Missoula, Montana, April IS, 1994
Patricia and Bruce von Alten, Butte, Montana, April 2S, 1994
June Corbitt, Butte, Montana, April 14, 1994
Frank Green, Butte, Montana, April 11, 1994
Herbert James Ellenburg, Butte, Montana, April 7, 1994
Michael and Hia Chapin, Butte, Montana, April 8, 1994
W.T., Butte, Montana, April 8, 1994
-------
ISO
Alben Molignoni, Rocker, ~1ontana, February 11, 1994 (includes 50A
through SOG) .
John Ray, Butte, ~fontana, April 26, 1994
Dan Battleson, Butte, Montana, March 25, 1994
Dr. Roben Robins, Australia, February 25, 1994
Me} Rowling, Butte, ~ontana
I 51
152
153
154
7.
Petition from Clark Fork Pend Oreille Coalition submitted with a letter dated April 28,
1994. Several individuals also sent petitions directly to EPA and are listed below.
P 1
P2
P3
P4
PS
P6
P7
P8
P9
PIO
Pll
P 12
Petition and letter dated April 28, 1994.
Francis & Caroline Peterson
Ruth B. Cooney
Kenneth R. DeBue
Sue and Joe Toth
Gary and Janet Beals
Pete Yerkich
Mike Muzzolini
Marie Martin
Carol Junken
Mary S. Beer
Mary J. Kahn
-------
Respoases to Commmt.~ rrom Transcript or Puhlic Meeting, Groups, PH'" " GOYel1lDlmt
Part I - Non-technical Commmts
Idmtilier Section Number
3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 .J.II 3.11 3.13 .J.14 3.15 3.16 3.17 3.18 3.19
Tnll!Crtpt
TI John RIY 8 8 ,. 8 8
T1 Albel1 Molignoni 8
T3 Din Hlrrington 8 8
T4 Sindy S'lIh, ARCa 8 8 8 8
TS Fritz Daily 8 8
T6 Dr. Richlrd IIlmmen 8 8 8
T7 Dr. tW. DeVoe
TK .hclr. Lynch 8 8 8 8 8
T9 Miry Kay Cmig 8 8 8 8 8 8 8 8 8
T 10 Bill MlcO""or 8 8
TII Edul Oilvomini 8
T 12 John Ruing 8 8 8 8
TJ3 Jim Kelne 8
C;roupl
01 CTEC 8 8 8 8 8 8 8 8 8 8
. 01 Cllrk Fork Pend Oreille Coalition 8 8 8 8 8 8 8 8 8 8 8
03 Robel1lOn T,chnolo,iu
PH'"
PRPI ARCO 8 8 8
Goyenmml
OOV I Filh 1& Wildlife Service 8 8
-------
/
RespolL'lfS to Comments from DuU~SiI.er Bow
rart I - Non-technical Comments
ldelmfier Section Number
3.1 3.1 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.11 3.13 3.14 3.15 3.16 3.17 3.18 3.19
BSB 1 Council RelOlution No. 1635
BSB1 BSB Local Government Commenta . . . 8 8 8 8 8
BSB3 BSB Technical Commenta on RIIFS 8 8 8 8
BSB4 Excerpta of Council of 8
Commi..ionel'8 meeti." 4/6/94
BSB 4-A luk Lynch 8
BSB 4-B Fril7. Daily 8 8
BSB 4-C Dr. I.W. DeVoe 8
BSB 4-D loe Quilici 8
BSB 4-E George Warin, 8
BSB 4-F Rose Brock 8 8
BSB 4-0 Alhert Moli,noni 8
BSB 4-" Bob P8Vlovich 8
BSB 4-1 B8lba,. Archer 8
BSB 4-1 Mary K8y Cr8i,. Coalition . 8
BSB 4-K Sandy St8lh, ARCO 8 8 8 8 8
BSB 4-L lamea Riley
BSB 4-M Eileen LeBreche 8
BSB 4-N Dave Curry 8 . 8 8 8 8
BSB 4-0 Mike Thatcher
BSB 4-P Charlie O'Lary .
BSB 4-Q Mike Kerna 8
BSB 4.R MI. DeVoe .
BSB 4.S Tom Brophy 8
-------
Respon.- to Comments from Butte-SiIYer Bow
Part I - Non-tlll:hnic:aI Comments
Idmtilier Section Number
3.1 3.1 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.11 3.13 3.14 3.15 3.16 3.17 3.18 3.19
BSB6 Miry Kay C...i" Cllrt Fort Pend 8 8 8 8 8
Greille C,..lition
BSB? Fritz D.il, 8 8 8 8 8 8 8 8 . . .
BSO I RIY Tilm~n . . . . .
BS09 Irvin, DeVoe
BSO 10 Albert Mnlignoni
BSO II Sindy StlSh, ARCO
BSO 11 Excerpt from Council of
ComrnissioRe'" Meetin, 4n0194
BSO 12-A Fritz Dlily . .
BSO 11-B Miry Kay C...ig, CI8r1t Fork Pend .
Greille COilition
BSO 11-C F"'M Quilici 8
BSO 11-0 lohn Ray 8
BSO 12-E George Wari. .
BSO 12-F Mill Cisick
BSB 11-0 Tom Orophy .
BSO 12-H Mike KerR8 .
BSB 12-1 Mike Thatcher .
BSB 12-1 Artie u...mie
BSB 12-K lack Lynch 8
BSO 13 Fritz Dlily 8 . .
BSO 14 Clark Fort Pend Oreille Coalition 8 .
BSBU Barbl... Archer 8
-------
Respoases to Commmb rrom ladiriduab and Petition Supporters. J
Pert I - Non-terlmiul Commmb
IcleDtifier Section Number I
3.1 3.2 3.3 3.4 3.5 3.6 3.1 3.8 3.9 3.10 3.11 3.12
3.13 3.14 3.15 3.16 3.11 3.18 3.19 i
IDdiYiduels
II Ciril "bnml . . . . . . . . . .
12 Elline Rohertl .
13 Vickie Wilson . . . . . . .
14 SIeve MielZ . . . . .. . .
IS Bonnie Oeslrin, . . . .
16 Ouy Murphy .
J7 Millreen Mlrkovich .
18 Miry Dunn . . . .
19 lohn " Shelly Wllsh .
110 SIeve Schnmbel . .
I " Pil Ore,an .
112 Thereu Crai, . . . .
113 Oeorse WlriD, . . . . . . .
,
114 Mlriln Conklin . . I
lIS Colelte Conk . . .
116 Lou Evellnd . . .
117 &me 1A8Iuh-. llmea LcBreche .
III Kevin" Cindy McOreevy . . .
119 ClifT" Rill Brldley . .
120 MlrJlret Smell .
121 Mickey BoylZ8 . . .
121 Prenk Morilrty . .
113 ROle Brock . . . .
-------
Kepoases to Commmts from lodiYiduals 8Dd PeCitiou Sapportert
Part 1 - Noa-tedmic8J Commmts
Idmtifier Sec:tioa Nwnber
3.1 3.J 3..3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.12 3.13 3.14 3.15 3.16 3.11 3.18 3.19
115 Mr. & MI'1I. Wilier Immonen 8
126 Audrey Dlly 8 "
121 Bob & Dorothy Fonell 8
128 Wilier & Balblra Kelley 8 8
129 Cltherine Coulure 8 .
130 Sue Ollse nherB 8 8 .
131 Dan O'Neill (Hlrri81111 Avenue) 8 8 8
132 Lyndl Hill 8 8
I
133 Kenneth ( ,nninghlm 8 I
8 8
134 Din O'Neill (Monroe Avenue) 8 8 8
135 Miry Mul. eire-Jonel 8
136 Balbi,. An:herfrom Tully 8 8
131 Amy Uenlz 8 8 8 8 8 .
138 Mike & Debra EVlnkovich 8 8 8 8
139 Kay JOilin 8 8
140 Loll Evidi 8 8 8 8
141 Fl'1Ink & Ruth Kolich 8 8
142 Annette GustaflOn 8
143 Miry Miller 8 8 8 8 8 8
144 Palricia & Bruce ¥OR Ahen 8 8
145 June Colbi I 8 8
146 Fl'1Ink Ore. n 8
147 Jlmel EllelihurJ 8 8
148 Michlel &. Hil CIuIpin 8
-------
Responses to Comments rrom lodiYidu8Js IDd Petition Supporters
Part 1 - Nnn-tec:lmil:aI Comments
IcIeotir.er Section NumbK I
I I I I I I I I
3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.1% 3.13 3.14 3.15 3.16 3.17 3.18 3.19 I
1 50A through 50G Albert Molignoni . . .
151 John RIY . . ,. . . . 8 .
152 Din Battluon . 8 8
153 Dr. Robert Robin. 8 8 .
154 Mel Rowlin. 8
Petlti08 Supporters
PI leiter &; petition with 3.690 .i,Dlhlftl 8 .
P2 Fnnci. &; Clroline Pete non . :
I
P3 Ruth Cooney 8 ,
P4 Kenneth DeBue 8 !
P5 Sue &; Joe Toth 8
P6 airy Bell. . j
i
P7 Pete Yerkich .
8 !
P8 Mike Muzzolini
P9 Mlrie Mlrtin 8
P 10 Clrol Junlr:ery 8
PII Miry Beer 8
-------
Responses to Comments rrom Transcript or Public Meetin~, Groups, PHI's &: Government
Plft II - Technitll Comments
Identirlel' Section NlJlllbtt
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12
Transcript
TI John Ray 8
T2 Albert Molignoni 8
T3 Dan Harrington
T4 Sandy Stash, ARCO 8
TS Fritz Daily 8
T6 Dr. Richard Hammen 8
T7 Dr. I.W. DeVoe 8
T8 Jack Lynch 8
T9 Mary Kay Craig 8 8
T 10 Bill MacGregor
TII Edus Giavomini
T 12 John Resing 8
T 13 Jim Keane
Groups
G 1 CTEC 8 8 8 8 8
-
G2 Clark Pork Pend Oreille Coalition 8 8
G3 Robertlon Technologies 8
PRPs
PRP 1 ARCO 8 8 8 8
Goyernment
GOV I Fish & Wildlire Service
-------
Responst'5 10 Comment. rrom RuUe-Silver Bow
Part II - Techniul Commrn15
Idenlirlel' S«tion Number
4.1 4.1 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12
BSB I Council Resolution No. 1635 .
BSB 2 BSB Local Government Comments . . 8 8 8
-
,.
BSB 3 BSB Technical Comments on RIIFS 8 8 8
BSB 4 excerpts or Councilor
Commissionen meeting 4/6/94
BSB 4-A Jack Lynch
BSB 4-B Fritz Daily
BSB 4-C Dr. I.W. DeVoe
BSB 4-D Joe Quilici
BSB 4-E George Waring
BSB 4-F Rose Brock
BSB 4-G Albert Molignoni
BSB 4-H Bob Pavlovich
BSB 4-1 Barbara Archer
BSB 4-J Mary Kay Crail!. Coalition
BSB 4-K Sandy Stash. ARCO '
BSB 4-L James Riley 8
BSB 4-M Eileen LeBreche
BSB 4-N Dave Curry
BSB 4-0 Mike Thatcher
BSB 4-P Charlie O'Leary
BSB 4-Q Mike Kerns
BSB 4-R Ms. DeVoe
BSB 4-S Tom Brophy
-------
RespoosfS 10 Comments from RuUe-Silver Bow
rart II . Tec:hnial Comments
-
Idenlirler Sedion Numb«
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12
BSB6 Mary Kay Craig, Clark Fork Pend 8 8
Orcille Coalition
BSB 7 Fritz Daily '. 8
BSB 8 Ray Tilman 8
BSB9 Irving DeVoe 8
BSB 10 Albert Molignoni 8
BSB II Sandy Slash, ARCO
BSB 12 Excerpt from Council of
Commissionen Meeting 4/20/94
BSB 12-A Fritz Daily
BSB 12-B Mary Kay Craig, Clark Fork Pend
Orcille Coalition
BSB 12-C Frank Quilici
RSB 12-D lohn Ray
BSB 12-E GeorJ~e Waring
BSB 12-F Matt Casick
BSB 12-G Tom Brophy
BSB 12-" Mike Kerns
BSB 12-1 Mike Thatcher
BSB 12-1 Artie Laramie
BSB 12-K lack Lynch
BSB 13 Fritz Daily
BSB 14 Clark Fork Pend Orcille Coalition
asB 1 S Barbara Archer 8 .
-------
/'
Responses to Comment. rrom Indiyidulis Ind I'etitioo Supporters
Plrt II - Tfthnial Commmt5
Ideotireer SKtion NumMr
4.1 4.2 4.3 4.4 4.S 4.6 4.7 4.8 4.9 4.10 4.11 4.12
Indiyiduals
I I Carll Abrams
12 Elaine Roberts I.
13 Vickie Wltson
14 Steve Mictz 8 8 8 8 8
IS Bonnie Gcstring 8 8
16 Gary Murphy
17 Maureen Markovich -
18 Mary Duran 8
19 John It. Shelly Walsh
I 10 Steve Schombel
I II Pia Gregan
112 Theresa Cniig
I 13 George Waring 8
-
114 Marian Conklin ..-
liS Colette Cook -
116 Lou Eveland -
I 17 Esme LaBauhe, James LcBrcche -
I 18 Kevin It. Cindy McGreevy 8
-
119 Cliff &: Rita Bradley 8
-
120 Marglret Smlll
121 Mickey BoysZl
122 Frank Moriarty
123 Rose Brock
124 Gary Davis
-------
Responses to Comment" rrom Indiyiduab and Itetition Supporten
Part II - TKhnicai Comments
Identirlft' SKtion Number
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 ".12
125 Mr. &. MR.. Walter Immonen
126 Audrey Daly
,.
127 Bob &. Dorothy Ponell
128 Walter &. Barbara Kelley
129 Catherine Couture
130 Sue Ga..enberg 8
131 Dan O'Neill (Harrison Avenue)
132 Lynda Hill
133 Kenneth Cunningham
134 Dan O'Neill (Monroe Avenue)
135 Mary Mulcaire-Jones
136 Barbara Archerrrom Tully 8 8
137 Amy Lientz 8 8 8 8
138 Mike &. Debra Evankovich
139 Kay Jo.lin
140 Lola Evidi
141 Prank &. Ruth Ro.ich
142 Annette Gustar.on
143 Mary Miller 8 8 8 8
144 Patricia &. Bruce van Allen
145 June Corbitt
146 Prank Green
147 James EllenbufR
148 Michael &. Hia Chapin
-------
Responses 10 Comments rrom Individuals and Petition Supporters
Part II . T«hniul Comml'nts
Identifier Section Number
4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12
I 50A through 50G Albert Molignoni 8 8
151 John Ray 8 8
152 Dan Baltleson
153 Dr. Robert I'obins 8 8 . 8 8
154 Mel Rowling 8
Petition Supporters
P 1 Leiter &. petilion with 3,690 sien.tures
P2 Francis &. C"roline Petenon
P3 Ruth Cooney
P4 Kenneth DeBue
P5 Sue &. Joe Toth
P6 .Gary Beals
P7 Pete Yerkich
P8 Mike Muzzolini
P9 Marie Martin
P 10 Carol Junkery
PII Mary Beer
P 12 Mary Kahn
-------
RECORD OF DECISION
-
BUTrE MINE FLOODING OPERABLE UNIT
Sn. VER BOW CREEK/BUTrE AREA NPL SITE
BUTrE, MONTANA
September 29, 1994
United States Environmental Protection Agency
Region vrn - Montana Office
Federal Building, 301 South Park, Drawer 10096
Helena, MT 59626-0096
(Lead Agency)
Montana Department of Health and Environmental Sciences
Solid and Hazardous Waste Bureau
2209 Phoenix Avenue
P.O. Box 200901
Helena, MT 59620-090 1
(Suppon Agency)
VOLUME m OF m
1." I "J
.----
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RECORD OF DECISION COMPONENT LOCATOR PAGE
(Components in bold are in this volume)
vOLUME I of ill
Record of Decision
Appendix I - ARARs
Appendix 2 - Technical Impracticability Evaluation
Appendix 3 - Monitoring Program
VOLUME n of III
Appendix 4 - Responsiveness Summary (Agencies Responses to Comments)
Attachment 1 - Identification of Comments Received
VOLUME ill of ill
Appendix 4 - Responsiveness Summary
Attaclunent 2 - Transcript of Public Hearing
Attaclunent 3 - Written Comments
~
-------
TRANSCRIPI' OF PUBLIC HEARING
APPENDIX 4, AITACHMENT 2
BU1TE MINE FLOODING OPERABLE UNIT
RECORD OF DECISION
: !
-------
SILVER BOW CREEK/BUTTE AREA SITE
H EAR I N G
MINE FLOODING OPERABLE UNIT
REMEDIAL INVESTIGATION FEASIBILITY STUDY
PROPOSED PLAN
. .
. ,:' ..;: ".:: .:
TRANSCRIPT OF PROCEEDINGS
. .
Taken at:. .
Montana Tech Auditorium
. West Park Street
Butte, Montana
April. 26, 1994
ROBERT L. SOLOMON, presiding
NORDHAGEN COURT REPORTING
KIMBERLY JOHNSON
17J4 Ham- o4w","
Ilitu. MOtIIIWI J9701
(406) 4~~08J
Registered Professional Reporter
. C«tf.- ~
17J4 HIUf'Ul1It 04-
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I N D E X
STATEMENTS:
JOHN RAY
. . . . . .
. . .
. . . .
ALBERT MOLIGNONI
.........
DAN HARRINGTON
. . . .
. . .
. . .
SANDY STASH,
. . .
. . .
. . . . .
FRITZ DAILY
., . ........ .
. . . .
. . .
DR. RICHARD HAMMEN
DR. I.W. DEVOE'
'. -.' . . .
. . .
.. ...
. . . .
. . .
JACK LYNCH
. .'. .
. . . . .
. . .
-
MARY KAY CRAIG
. . .
. . .
. . . .
BILL MACGREGOR
. . . . . .
. . . .
ED US GIAVOMIN .
. . . . . .
. . . .
JOHN RESING
........
. . . .
JIM KEANE.
. . . . .
. . . .
. . .
Page:
6 T 1
13 T 2
15 T 3
17 T4
20 T!
25 T6
3 3 T 7'
36 TI
40 T9
49 T 10
54 T 11
55 TU
58 T 13
..
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
-------
~~
I
;
I
,..
3
1
EXPEDITED RESPONSE ACTION, PROPOSED PLAN
2
APRIL 26, 1994; BUTTE, MONTANA
3
- - -
4
CHAIRMAN SOLOMON:
At this time we will go on
5
the record.
My name is Robert L. Solomon.
I have been
6
retained as an independent party to conduct the public
7
hearing this evening.
For the record and to the best of
8
my knowledge, I am not an employee or member of any of the
9
governmental agencies, private companies, or public or
10
membership organizations involved in discussions or
i1
proposals related to the matter about to be heard.
12
At this time we will let the record show that
13
this is the time and place for the hearing to receive
14
public comment on the Proposed Plan of the Mine Flooding
15
Operable Unit (Berkeley pit and Underground Mine Workings)
16
at the Silver Bow Creek/Butte Area NPL Site located in
17
Butte and Walkerville, Montana.
The United States
18
Environmental Protection Agency (EPA) and the Montana
19
Department of Health and Environmental Sciences (MDHES)
20
published notice to hold a public comment period on the
21
Remedial Investigation/Feasibility Study (RI/FS) report
22
and the proposed Plan for the Mine Flooding Operable Unit.
The public comment period was to be a period of
23
24
90 days from January 27, 1994, to April 29, 1994.
The
25
public hearing for Mine Flooding was noticed to be held at
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
-------
J.
, .
!
. .
. .
4
1
this time and place to provide the public the opportunity
2
to give formal comments to EPA and MDHES.
3
In addition, anyone wishing to make oral public
4
comments was offered the opportunity to come into the
5
Butte EPA Office in the Silver Bow County Courthouse from
6
9:00 a.m. to 5:00 p.m. on Monday or Tuesday, April 25 or
7
26, 1994, for the purpose of recording their comments into
8
a ta~ recorder.
The comments received in this manner
9
will be transcribed, will become a part of the official
10
record, and will be responded to in the Responsiveness
11
Summary.
Officials of the EPA were available to answer
12
questions during that two-day period.
Written comments
13
may be submitted to Russ Forba, Remedial project Manager,
14
US-EPA, 310 South Park, Drawer 10096, Helena, Montana,
15
59626, until the close of the comment period on April 29,
16
1994.
17
The ground rules for this evening are as
18
follows:
This is a hearing to receive public comment and
19 information.
20 questioning
21 permitted.
It is not adversarial in nature, and
or cross-examination by the public will not be
The presidingoffi~ei may ask questions in
22
order to clarify statements or information being
23
presented.
Persons making presentations may submit
24
comments orally or in writing.
The name of the person to
25
speak and the person to make the next presentation will be
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
-------
I~
5
1
announced by the presiding officer.
When you come to the
2
microphone, please begin by stating your name and then
3
spelling it, your address, and any organization or group
4
that you may be representing this evening.
5
Present your information in a manner that is
6
most comfortable for you.
You may speak extemporaneously,
7
you may summarize your comments, or you may read them into
8
the record.
If you have prepared a written statement, it
9
will be appreciated if a COPy can be given to the
10
presiding officer or the reporter to assist in the
11
preparation of the transcript of this hearing.
All
12
written materials received this evening will be given the
13
same consideration as oral comments and will be. responded
14
to in the Responsiveness Summary.
EPA has indicated to me
15
that this will be completed in late summer or early fall.
16
Due to the number of persons wishing to provide
17
comments this evening, limits will have to be imposed on
18
the length of time available to each speaker.
You will be
19
given an indication that your allotted amount of time is
20
nearing an end, and then you will be required to wrap up
21
your comments, and as discussed earlier before we went on
22
the record, we will look at a time of around 10 - 12
23
minutes, if that is agreed.
If you continue to speak
24
beyond the allotted time period, you will be asked to
25
terminate your presentation.
Your cooperation in holding
NORDHAGEN COURT REPORTING
-------
6
1
to the time constraints will offer all those who wish to
2
speak the opportunity to do so.
Recesses will be called
3
by the presiding officer at appropriate intervals.
4
The record will show that the ground rules for
5
this hearing have been made part of the record.
The
6
Invitation for Public Comment on this matter has been made
7
part of the record as well.
All written documents and
8
oral .comments received prior to this evening are by this
9
reference made a part of this proceeding.
10
We will now begin the public comment portion of
11
this hearing, and at this time I will call upon John W.
12
Ray, and, Albert, you will be next up.
13
STATEMENTS
14
BY-MR. RAY:
Tl
15
My name is John W. Ray, R-A-Y, and I am a member
16
of the Board of Directors of the Montana Environmental
17
Information Center.
18
A major principal of Roman Law was that the
19
people's safety is the highest law.
The purpose of
20
Superfund is to protect the people's safety, particularly
21
the people's health, from dangers presented by hazardous
22
waste sites which must be cleaned up because they present
23
a major threat to human health and the environment.
24
Remedies under Superfund should provide a
25
permanent cleanup remedy, not temporary containment or
NORD HAGEN COURT REPORTING
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r;.
...
7
1
simply removal to another site.
Simply, "cleanup" is
2
defined as the act of cleaning up, and the term "clean"
3
means to. make pure, free from dirt, and free from
4
contamination, free from impurities.
5
According to the EPA Publication Superfund
6
Environmental Progress, the purpose of Superfund is to
7
achieve, and I quote: "Long-term cleanup goals for sites
8
to £e~ove contamination from the environment."
9
The document further states that the law, and I
10
"directs EPA to protect public health by meeting
quote:
11
strict cleanup standards at each site."
And again
12
quoting, "Reduced to its environmental essence, the new
13
Superfund mission is to make sites safe, make sites clean,
14
and bring new technology to bear upon the problem."
15
According to Superfund law, any remedy for the
16
Pit must be a cleanup remedy.
If one examines the major
17
Superfund laws, CERCLA, SARA, and the NCP, one finds that
18
they all emphasize.the following:
First, cleanup is the
19
primary goal of any Superfund activity; two, the reduction
20
of toxicity, volume, and mobility of hazardous s~bstances,
21
pollutants, and contaminants at a site is another
22
important criteria; third, cleanup remedies must be
23
permanent.
24
Senator George Mitchell, Democrat of Maine, has
25
argued that "permanent treatment" means the EPA cleanup
NORDHAGEN COURT REPORTING
-------
. .
I .
r
t
. .
".'.
8
1
plans must result in a permanent and major reduction in
2
the toxicity, volume, and mobility of hazardous
3
substances, pollutants and contaminants at a site, and
4
that this reduction must be to the lowest achievable
5
levels.
"In addition to the
Senator Mitchell stated:
6
quantitative reduction implied, significant reduction in
7
this context also means the minimization of volume,
8
toxi~ity, and mobility of such substances to the lowest
levels achievable with available technologies."
9
10
Four, Superfund law discourages EPA from simply
11
moving waste from one spot to another.
For example, is
12
this what would be done with the sludge which will result
13
from treating Pit water?
Fifth, cost is not the major
14
factor in Superfund decisions.
Cost is secondary to
15
protecting human health and the environment.
Under
16
Superfund, human health must be protected froa potential
17
threats regardless of cost.
18
Any solution, then, to the problem of the
19 Berkeley Pit must emphasize the above criteria. It is in
20 light of the above five criteria that the solution to the
21 problem of the Berkeley Pit has to be evaluated. If we
22
examine these criteria, should we be comfortable with a
23
proposed plan that would allow the volume of toxic
24
contaminated water in the Pit to more than double before
25
anything is done from the present 2S billion gallons of
NORDHAGEN COURT REPORTING
-------
L
r
9
, "
1 tox~c water to 56 billion gallons?
Should we be
2
comfortable with a proposed plan that leaves a Berkeley
3
Pit filled with toxic water to exist and be treated in
4
perpetuity?
This proposed plan would allow a surface area
5
of contaminated water of approximately 500 acres.
6
Is this a cleanup remedy?
Is this a remedy that
7" reduces the toxicity, mobility, and volume of haz~rdous
8
waste?.:
Is this a permanent remedy or a remedy that will
9
leave us with a perpetual environmental crisis?
10
All too often in the past, Superfund has not
11
cleaned up sites it was supposed to.
Superfund activities
12
have not met the goals of permanent cleanup.
The Office
13
of Technology Asses~ment has concluded that Superfund
remains largely ineffective and inefficient, and "is not
14
15
working environmentally."
The Office of Technology
16
Assessment has concluded that the Superfund program has
17
too often settled for remedy technologies that do not
18
reduce toxicity, mobility and volume of hazardous waste.
19
All too often, Superfund has settled for remedies short of
20
cleanup.
Given the serious nature of the contaminants of
21
the Berkeley Pit, we can not allow any remedy short of
22
cleanup.
We must clean up the problem of the Berkeley Pit
23
so that future generations don't have to deal with it.
24
Now I would like to offer a few specific
25
comments on the EPA proposed plan.
First, I think it
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
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9
f. 10
11
12
13
14
IS
.0'.
.23
10
1
needs to have stronger emphasis on eventual permanent
2
cleanup.
Second, it needs to express in unequivocal terms
3
that appropriate, new technologies will be used as they
4
become available in the cleanup of the Pit.
Third, since
5 so much of the proposed plan is based on predictive
6 models, the plan must clearly provide a definite safety
7 factor. Human error of calculation Qr operation must not
8
pro~~~e an environmental catastrophe.
Fourth, the cost
factor needs careful consideration and reevaluation.
There are two ways of calculating cost:
You can do what
is cheapest; or two, you can set the goals that you are
trying to achieve and after the goals have been
established, decide what is the most cost-effective way of
achieving those goals.
According to S~perfund law, we are not looking
16
for the cheapest remedy, but once we have decided on the
17
plan we want to implement, .to protect human health and the
18
environment in a permanent way, we have to decide what is
19
the most cost-effective way to accomplish that plan.
Under Superfund, cost does not determine which plan is
20
21
accepted or the end result desired of a cleanup plan. . The
cleanup plan and its end result should be simply
22
protecting human health, and that should determine cost,
24
not the other way around.
25
Senator John H. Chafee, Republican of Rhode
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1
Island, has commented on the Superfund's consideration of
2
cost, and I quote:
3
"The extent to which a particular
4
technology or solution is feasible or
5
practicable is not a function of cost.
A
6
determination," he says, "that a particular
7
solution is not practicable because it is
8
too expensive would be unlawful."
9
So in devising a remedy for the Berkeley Pit, we must not
10
select the cheapest solution but the solution which will
11
maximize the protection of human health and the
12
environment.
We need to protect a -- we need to adopt a
13
14
15
16
17
18
19
20
21
22
23
24
cleanup solution and then find the most cost-effective way
of achieving that.
Fifth and my final comment, the solution to the
Pit problem must show sensitivity to public input.
As
processed, democracy demands that the public participate
in the formulation and execution of public policy.
This
is particularly true in the case of each of agency
rule-making such as is exemplified by the decision-making
processes related to the Berkeley Pit.
Such agency
rule-making is inherently undemocratic because the people
who are making the rules were not elected by the people,
and they are only very indirectly accountable to the
2S
people.
Rule-making is only legitimate in a democracy if
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the public has ample opportunities for meaningful
2
participation in the decision-making process, and
3
"meaningful participation" means that the public really
has an efficacious impact on the content of a Superfund
4
5
decision.
6
It is contrary to democratic practice to seek to
7
substitute the opinions of a few so-called "experts" for
8 publi~ decision-making. The best environmental policy
9 decisions and outcomes are achieved through public
10 discussion and through public debate. The reason for this
11 conclusion is that the answers to most environmental
12
policy questions, as to most public policy questions in
13
general, cannot be determined with the exactitude and the
14
certainty of a mathematical or scientific theorem.
15
Rather, the answer to public policy questions exists in
16
the realm of the probable or the contigent.
Given the
17
complexity of society and the complicated nature of most
18
environmental issues, no one individual, not even a
19
scientific expert, knows with absolute certainty what is
20
the best public policy.
And, of course, there are
21
numerous examples of where the experts have been just
22
plain wrong.
Because of this contingency and complexity, the
23
24
best environmental policy answers are found through public
25
discussion and by having the so-called "expert" submit his
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1
or her conclusions to critical public scrutiny and
2
approval.
The public has a right and a duty to subject
3
the opinions of so-called "experts" to intense criticism.
4
If an attempt is made to substitute completely the
5
opinions of the technical person for the opinions of the
6
public, neither the public interest nor the demands of
7
good public policy-making are being served.
The final
Berkeley pit decision must clearly demonstrate and show
not only that public input was heard but that it was
listened to, and that public input had some impact, that
it had some efficaciousness in arriving at the final
12
decision about how to deal with the Berkeley Pit.
Thank
13
you.
14
CHAIRMAN SOLOMON:
Thank you.
Albert Molignoni
15
and to be followed by Mr. Harrington.
16
17
BY-MR. MOLIGNONI:
T2
18
Good evening, ladies and gentlemen.
My name is
19
Albert Molignoni.
That's spelled M-O-L-I-G-N-O-N-I.
I am
20
here this evening representing myself and also the County
21
Water and Sewer District of Rocker, Montana.
I have
22
several questions here I would like to read into the
23
record, and I will give a copy of my questions to the
24
reporter.
25
My issue has to do with the water rights of the
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State of Montana.
Was a water
My first question is:
2
right given to the PRPs to take over 5.5 cubic feet of
3
water per second or 2,468.4 gallons per minute of the
4
State of Montana's ground water with or without the
5
approval of the state legislature?
6
Number 2:
If the PRPs have the approval of the
7
state legislature for over this amount of ground water,
8
what was the beneficial use described to the state
9
legislature in order to obtain this permit?
10
Number 3:
The Metal Mine Reclamation Act
11
(82-4-30 MCA) states:
12
"Recovery of damages for a water loss in
13
quantity and quality is provided for if an
14
investigation establishes that a hard rock
15
mining operation is responsible for the
16
loss."
17
What I would like to know is:
Is this a lump sum fine or
18
payment on the total amount of water that is being
19
contaminated or on the amount of water per year that is
20
being contaminated?
Also, what would the amount of
21
damages be for 2S billion gallons' or 50 b~llion gallons?
22
Number 4:
How many years will the State of
23
Montana and the people of Butte-Silver Bow have to live
24
with this very large amount of toxic water, 100 years,
25
1,000 years or forever?
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Five:
How is this solution of creating a 50
2
billion gallon plus body of toxic water good for the State
3
of Montana or the people of Butte-Silver Bow?
Is it only
4
the PRPs that will benefit from this solution?
5
Six:
Is the State of Montana, the EPA, and the
6
PRPs aware of the fact that keeping the volume of toxic
7
water to 5 billion gallons in the Berkeley Pit, over 42
8
billi~n kilowatt hours of electric power per year could be
9
generated?
This water could also irrigate over 6,000
10
acres of land with 12 inches of water per year.
11
The attached documents might show a better way
12
to solve the problem with the Berkeley Pit.
Please enter
13
my questions and statements and documents into the record.
14
Thank you very much.
15
CHAIRMAN SOLOMON:
Thank you.
We will
16
acknowledge receipt of a packet of materials and they will
17
be entered into the record at this time.
18
Mr. Harrington to be followed by Ron Pelzmen.
19
20
BY-MR. HARRINGTON:
T3
21
Thank you.
Dan Harrington,
22
H-A-R-R-I-N-G-T-O-N.
State Representative, District 68,
23
Butte.
24
To speak to the record, it has been 12 years
25
since the pumps were shut off that have started this
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emotion, the fact that the problems that are going to be
2
facing this county.
We are faced with many serious
3
problems, and I hope that the plan that is being put forth
4
will take into account not only the health and welfare of
5
the community, but also the economic development of the
6
community.
I think all of these things are so very, very
7
important that we have to recognize the fact.
8
There's been many meetings held, there's been
9
much said concerning what problems we are going to be
10
faced with.
There have been many different theories that
11 have been put forward over this period of time. I feel
12 that it is very, very important that this plan that is
13 being put forWard and that it is studied very carefully
14 that each and every one of these groups, ARCO, and the
15
EPA, all of these people take into account the very
16
important facts as to what direction because the fate of
17
this community is at stake in this, and I would hope that
18
the study will continue on and that we will move for newer
19
and better ways in which we could implement the plan.
20
Thank you very much.
21
CHAIRMAN SOLOMON:
Ron Pelzmen,
Thank you, sir.
22
to be followed by Sandy "Trash".
23
Ron Pelzmen?
Sandy, would you like to speak at
24
this time?
Mr. Daily, you will be next.
Sandy?
25
MS. STASH:
My name is Sandy Stash.
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14
15
16
17
18
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-
20
21
22
23
24
25
17
1
CHAIRMAN SOLOMON:
I am sorry, I beg your
2
pardon.
3
SANDY STASH:
It was a good slip, though.
4
5
BY-MS. STASH:
T4
6
ARCO is one of the potential
I represe~t ARCO.
7
responsi~le parties, the address is 307 East Park,
8
Anaconda, Montana.
I am here this evening to speak in
9
support of the EPA proposed remedy, that being Alternative
10
ARCO believes that this remedy as chosen by EPA and
67.
11
the State of Montanta best represents the balance between
the Superfund criteria; namely, effectiveness, permanence,
and cost-effectiveness.
Something else I think that is noteworthy that
seems to be somewhat lost in the debate that's gone on for
the last couple of months is that it's perhaps the first
time in this community on the Superfund issues that you
see such agreement between all of the players:
The
Environmental Protection Agency, the State of Montanta,
the Bureau of Mines, and two companies that will be asked
to pay for ~his cleanup, namely ARCO and Montana
Resources.
This is very noteworthy and I think very key
when you get that much expertise and that many parties in
total agreement on the remedy.
Never before has this type
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1 , of agreement been reached.
On the specifics o~ the plan,
2
ARC a specifically supports the critical water level as
3
determined by the EPA and the State of Montana.
Again, an
4
important factor I think sometimes lost in this discussion
5
is the critical water level includes ample design factors
6
to assure the people who live here that something will be
7
done at the Pit long before it is absolutely necessary.
8
In ad?ition, this will be assured in that commitments will
be made and have been made to the agencies that the
9
10
situation at the Berkeley Pit will continue to be
11
monitored very aggressively as it has been for the last
12
couple of years.
In that any changes that would determine
13 a different critical water level-being necessary could be
14 made.
15 Thirdly, there's been much discussion and debate
16 on the use of technologies for the Berkeley Pit treatment.
17
There again, ARCO is in total agreement with the remedy as
18
specified by EPA and the State of Montana.
Again, I think
19
something is lost in these discussions.
The lime aeration
20
technology that was chosen for this remedy is indee~ an
21
innovative technology and is an innovative technology
22
developed here in Butte, Montana, at Montana Tech.
Never
23 before has lime aeration been used in a cleanup treatment
24 with the types of volumes you are looking at.
25 I think secondly and very importantly for those
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who feel that other technologies would be more
2
appropriate, we suggest again as one of the parties who
3
will be asked to pay for this cleanup that those folks
4
need to provide to the responsible parties and to the
5
agencies proof, credible, scientific facts that show that
6
the technology they are purporting is both scientifically
7
sound and at least as equally as cost-effective if not
8
more ~ost-effective than what is currently on the table.
9
We believe that in ten to twenty years that will
10
ensue before the large 8erkeley Pit treatment plant needs
11
to be built, there will be ample time for additional
12
technology development.
We look forward to the work of
13
the Resources Recovery ?roject located here in Butte,
14
Montana, to help us to develop a better or a modification
15
to the remedy that's been chosen.
16
Fourthly and finally gets to the issue of sludge
17
disposal.
Again, much debate on the subject.
We would
18
suggest to EPA and the State of Montana in their final
19
decision-making that the question of sludge disposal is
20
best left until the final design is done for the
21
technology for the final treatment and not try to be
22
determined right now.
Thank you.
23
CHAIRMAN SOLOMON:
Thank you very much, and
24
again, my apologies.
25
Mr. Daily to be followed by Dr. Hammen, next
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speaker.
2
TS
3
BY-MR. DAILY:
4
My name is Fritz Daily, D-A-I-L-Y, and I am a
5
state representative representing Butte in House District
6
On May 30, 1990, I presented testimony on the
No. 69.
7
work plan that led up to this RIfFS that has now just been
8 'comp~eted.
The testimony I gave back then, I think, is
9
even more pertinent today than it was back then.
After'
10
carefully studying the RIfFS, attending numerous meetings,
11
making numerous presentations, the only thing that I see"
12
different today on this very date is the fact that the
13
water is now 110 feet deeper, and there is an additional 9
14
billion gallons of poison in the Berkeley Pit.
That's the
15
only difference.
16
The issue back then was the establishment of the
17
critical water level.
The issue today is the
18
establishment of the critical water level.
As is stated
19
in the work plan, the primary objective of the entire
20
RIfFS was to establish the critical Pit water l$vel.
21
That's the primary objective of the entire RIfFS.
22
However, that critical water level was established and, I
23
might add, in closed-door negotiations between ARCO, EPA,
24
and the State of Montana before the RIfFS even started.
25
They established the critical water level without the
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benefit of the RIjFS.
That's unbelievable to me.
2
The critical water level was wrong then and it's
3
wrong now, and as Sandy just stated, it's the first time
4
really that all of the groups have agreed with this RIjFS,
but if you look back on the establishment of that critical
5
6
water level, all of the groups agreed then, too; and again
7
it was wrong then, it's wrong now.
8
As most of you know that have heard people --
9
that have heard me make a presentation, I like to use
10
analogies when I try t= ~ake a point or try to explain a
11
point.
And a good analogy to use in this situation goes
12
back to our budget deficit, the budget deficit that this
13
country is now facing.
And in 1963, John F. Kennedy
14
presented a budget to Congress that was out of balance by
15
only $10 million.
Today, that budget -- we now have a
16
budget deficit of over $300 trillion and each and every
17
one of us in this .room owes $17,000 toward that budget
18
deficit.
19
When you deal with the Berkeley Pit and the
20
Butte mine flooding issue, as I stated a few minutes ago,
21
the water is now 110 feet deeper"and it now contains 9
22
billion gallons more and that's since May of 1990.
The
23
Berkeley Pit actually, today, is 807 feet deep and it
contains 22 billion gallons of water, or the 22 billion
24
25
gallons of poison, however you want to look at it.
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1
I would like to place in the record two
2
resolutions that were introduced in the 1993 legislature.
3
The first resolution is a resolution which was drafted by
4
a committee, an environmental committee, in the Montana
5
legislature and does not contain one name of a
6
representative from Butte.
The resolution was drafted
7
because of legislation that I presented that was supported
8
by th~ rest of the members of my delegation.
And the
9
resolution deals with what we are talking about here
10
tonight.
It deals with the flooding of the Berkeley Pit
11
and it deals with the actions that were taken up to that
12
point by the Environmental Protection Agency.
And if you
13
read this resolution, you can see that they were not very
14
happy with the actions of the Environmental Protection
15
Agency.
16
The other resolution is a resolution which I
17
sponsored which was cosponsored by all of the members of
18
the Butte/Anaconda Legislative Delegation or the entire
19
Southwestern Montana Legislative Delegation, and it
20
supports the new Waste Tech Center that has now been
21
located in Butte, M~ntana.
I think that the only way this
22
problem is ever going to be solved is by some independent
23
third agency or some independent third body.
I have
24
finally reached that conclusion.
I do not believe that
25
ARCO and EPA are going to solve this problem.
This
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problem is going to be solved by Metanetix, Montana
2
Technologies Company, or some other similar company.
3
That's how it's going to be solved.
4
We as a community, we as a state, have to
5
encourage as strongly as we possibly can that we support
6
new and innovative technologies and that we encourage
7
thes~ people to continue working to solve this problem
8
because, ladies and gentlemen, believe me, that's the only
9
way the problem is going to be solved.
And I will offer
10
these two resolutions.
I also have three other documents
11
that I would like to present and offer for the record, and
12
let me just first of all maybe just go over one of these.
13
And these are the problems that I see with the RI/FS as it
14
has been presented.
15
First of all, I think that the Record of
16
Decision, the decision that's going to be made from this
17
information, is one of the very most important decisions
18
that will ever be made in Butte-Silver Bow.
It may be the
19
very most important decision.
The fate of our community,
20
as Representative Harrington has stated, the fate of our
21
community is at stake and it's important that we. get. a
22
responsible solution to this problem.
As I stated
23
earlier, the critical water level is too high and it was
24
not properly established.
The solution that's been
25
proposed no matter what anyone says is the cheapest and
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20
21
24
1
not the best.
There are way better technologies out there
2
if we would look at those technologies and try to use some
3
of those technologies.
The best thing we can do as a
4
community without question is to figure out a way to mine
5
that water, take the resources from that water and, most
6
importantly, turn the water back to water.
The most
7
valuable asset in the Berkeley Pit today, I believe, is
8
the water.
The bedrock aquifer has been abandoned in this
9
That is not a good decision.
That's a decision
RIfFS.
10
that's going to affect us for many years to come.
11
The fate of the community, as I have stated here
12
tonight, as Representative Harrington has stated here
13
tonight, is truly placed in jeopardy as a result of this
14
I appreciate the opportunity to be here tonight.
RIfFS.
15
I realize this is probably the"last hearing that we'll
16
have, I guess, on this critical important issue, and I
17
guess I would hope that as many people as possible would
18
step forward.
And I know it's difficult to do sometimes,
and I have a difficult time myself doing it, but it's
really important that the EPA and ARca and Montana
Resources and the Montana Department of Health, it's
22
really important that they know how we, as a community,
23
feel.
And I guess I would ask everyone to step forward
24
if they could.
I think that would be very beneficial.
25
Thank you.
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15
16
17
18
19
... 20
21
22
23
24
25
1
CHAIRMAN SOLOMON:
Thank you and we will
2
acknowledge those materials and place them in the record,
please.
3
4
Dr. Hammen to be followed by John Resing.
5
6
T6
BY-MR. HAMMEN:
7
Thank you.
My name is Dr. Richard F. Ha~en,
8
H-A-M~M-E-N.
I am the President of Chromatochem Inc.,
9
C-H-R-O-M-A-T-O-C-H-E-M, Incorporated.
The address is
10
2837 Fort Missoula Road, Missoula, Montana, 59801.
11
Thank you for the chance, Mr. Chairman, of being
12
able to present or speak at this meeting.
I" represent a
company which has developed a technology that is
applicable to the cleanup of the Berkeley Pit.
I would
like to talk a little bit about that technology. and how it
interacts with respect to the Proposed Record of Decision
which will go down here this evening.
First of all, I would like to just state my
qualifications because I will make a couple of exceptions
to some of the scientific conclusions that are presented
in the RI/FS that I have read." I .was a boy from Montana,
Southern University of Montana Professor, but I have been
educated at Stanford University, PhD at the University of
Wisconsin, post-doctorai scholarship at UCLA, employment
25
at Stanford Research Institute and California Institute of
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18
19
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20
21
22
23
24
25
26
1
Technology Jet Propulsion Laboratory.
After that, I
2
founded Chromatochem and moved the company to Montana with
3
encouragement from funding by the State of Montanta
4
Science and Technology, Montana State Science and
5
Technology Alliance, which is in the business of investing
6
in and encouraging the development of new high-technology
7
companies.
8
In January of 1991, Chromatochem submitted a
9
proposal to EPA to use our technology for a study of
10
treatment of Berkeley Pit water with the objective of
11
recovering the water with purity that exceed Rule Book
12
Standards and recovering the metals in a form that is
13
applicable or appropriate for processing and selling these
14
metals into the commercial marketplace and not presenting
IS
the metals as a-sludge.
This project was funded by the
EPA, and I would like to enter into the record a paper
titled, "Acid Mine Water Processing and Metal Recovery by
Fast Solid Phase Extraction", that was published in
January of 1993, Mine Engineering Research.
In addition to that paper which has been
published, I have given numerous talks nationally and also
in Butte regarding this technology and its application to
acid mine water treatment, and this fall I will be
chairing a session at the National American Chemical
Society meeting -- the American Chemical Society meeting
NORDHAGEN COURT REPORTING
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27
1
in Atlanta, discussing innovative technologies for
2
hazardous waste treatment.
This technology has been
3
granted a US patent which was issued in August of 1993, so
4
the technology has been acknowledged by the federal patent
5
offices as being good.
6
At present, the company has made a proposal to
7
the P~source Recovery Project that MSE is sponsoring under
8
Department of Energy dollars.
We have done this proposal
9
or made this proposal in conjunction with a company called
10
the International Technology Corporation which is one of
11
the leading hazardous waste cleanup technology companies
12
in the country and is presently involved in some rather
13
large contracts at Hanford Superfund site totaling 200
14
million and another one for 400 million.
They are
15 partners in this program and we have recently been
16 notified by the Department of Energy that we are still in
17 the running or we are among the finalists in this
18 competition for a technology demonstration project that
19
will take Berkeley Pit water, extract the metals, present
20
them as concentrate in forms appropriate for sale into the
21
commercial market, and have an objective of having water
22
which will exceed drinking water standards.
That's a bit of the background of what we have
23
24
done with Chromatochem.
What I would like to do is turn
25
to a section of the RI/FS and it is Section 5.1.10 titled,
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28
1
"Chelation Chromatography".
In this review, the PRPs
2
sponsored an analysis of technologies which are available
3
for treatment of acid mine water.
Chelation
4 Chromatography is a phrase which I developed and I first
5 coined and brought into the world, but it describes the
6 type of separations process which is also being sold in
7 the marketplace by ~ompetitors of Chromatochem Company
8
such as Dow and Roman Hause.
It is a recognized
9
technology, generically, and Chromatochem's patent is
10
recognition of-an improvement of this technology in its
11
cost-effectiveness and the cleanliness of the water it
12
produces.
I would like to read some lines from this
13
statement in the RI/FS and enter into the record of this
14
meeting some corrections that I would like to make in it.
15
Paragraph 2 of Section 5.1.10 states:
"Recent
16
research efforts have successfully conducted labo!atory
scales tests on new synthetic resins to improve the
17
18
selectivity of the resins."
Jones and Grinstead, 1977.
19
These are not recent results which
1977 was 27 years ago.
20
were reported or discussed in this analysis of new
21
technology.
22
The statement goes on:
"However, the new
23
process has not been demonstrated successfully on a pilot
24
or full-scale basis."
Roman
That sentence is incorrect.
25
Hause and Dow chelating resins are deployed for treating
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13
14
15
16
17
18
19
. . 20
21
29
1
millions of gallons of water everyday as a well-known
2
process.
3
Now, it goes on.
Let me draw your attention to
4 Paragraph 3. It says: "=:ffectiveness, Chelation
5 Chromatography has been tested in limited pilot skill
6 applications." prel~minary data indicate that this method
7
of ion absorption is not quantitative, i.e., repeatable
8
over time.
9
I refer to the paper I have submitted to the
10
record that shows this process was demonstrated to be
11
repeatable over time of 1500 cycles of use.
Development
subsequent to the publication of that paper have increased
the stability and ~eproduced stability in that product and
that process.
The second sentence of Paragraph 3 states:
"Preliminary data also appeared to indicate a degradation
6f a thin film of chelating aging over time."
That
sentence is incorrect in that we demonstrate that after
this 1500 cycles of use, that over 80 percent of the
original material's capacity still remains, so that the
Chelation Chromatography is not miiterial or process which.
22
is sensitive to changes or process variations.
It goes on
23 to state: "Therefore, based on its early phase of
24 development, Chelation Chromatography has been removed
25 from further consideration." And that is the conclusion.
NORD HAGEN COURT REPORTING
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...
30
1
Now it says:
"Chelation Chromatography is
2
implementable on a technical basis using conventional
3
construsion methods."
"It has not been proven
Correct.
4
on large scale operation and is not technically feasible
5
for treating 1.5 to 2.3 million gallons per day of waste
6
water during remedial action."
Incorrect.
Chelation
7
Chromatography is in use with other commercial re~ins on
8
project of that scale and we have proposals outstanding
9
for treatment processes that are in the tens of millions
10
of gallons per day in size.
It is a scalable technology.
11
Those are the changes that I would like -- excuse me.
I
12
have other corrections, too, and I am not done on this.
13
The final paragraph titled "Cost" says:
14
"Implementation of this process technology would require
15
relatively moderate to high capital costs."
That is
16
incorrect.
The capital costs of Chelation Chromatography
17
system deployed for Berkeley Pit water cleanup to the
18
drinking water stage of recovery of the metals is less
19
than any of the capital costs in any of the plans
20
presented in the RIfFS except for the No Action Plan.
I
21
don't know what the cost of the No Action Plan is.
ONM
22
costs are not estimated because reliability and durability
23
of this technology has not been established.
24
I would like to annotate that by saying that
25
although our papers, our work, has been presented and is
NORDHAGEN COURT REPORTING
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31
1
known and published, we were not contacted by any of the
2
PRPs or by the consulting groups for questioning or
3
further information with respect to this.
I would like to
4 ; :urther ~emark, again, that this technology was
5
demonstrated with the use of Environmental Protection
6
Agency funds, and apparently the EPA has not used its own
7
internal data or even noticed its own internal data in its
8
recommendations.
9
That ends my comments with respect to the
10
written remarks about technology that our company has
11
developed.
In approximately 6 months this technology will
12
be demonstrated on a pilot scale and I think that, again,
13
I would like to state that there are two issues that are
14
important:
One is the issue that industry's remarks are
15
that treatment to high standards of purity in water to the
16
levels of low parts per billion is exceedingly expensive
17
and therefore cost-prohibitive.
18
Being in industry, I agree that no
19
cost-prohibitive measures should be included or should be
20
considered seriously.
This technology is capable of
21
treating water to nondetectable levels of copper,
22
manganese, zinc, and arsenic.
I therefore ask that the
23
proposed plan be rejected at this time because it has not
considered adequately this new technology and it is quite
24
25
likely that it has not appropriately or adequately
NORDHAGEN COURT REPORTING
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1
considered other technologies which would work in
2
conjunction with any modern process that would treat this
3
water.
The process of precipitation and aeration is very,
4 i very old technology and I think that some changes have
5
been made, . and the city of Butte deserves better treatment
6
of its water and its resources in its future.
7
I request that the EPA consider the data that
8
nave corne from our sponsor grants -- three more minutes --
9
and I request that in light of the new data which is being
10
entered into the record at this hearing that the proposed
11
plan of action be reconsidered.
12
I have some questions to enter into the record.
13
The first question is:
Did the Environmental Protection
14
Agency in any fashion review the accuracy or the validity
15
of the comments about modern water treatment technology
16
which were made in this report?
If it did, then what
17
happened to the analysis of Chelation Chromatography?
18
The second question that I have is, relates to
19
the issue of costs on this matter:
Chelation
20
Chromatography is a low-cost solution because it provides
marketable metals, it provides drinking quality or better
21
22
water.
Will ARCO accept or entertain a zero cost
23
treatment for cleanup alternative?
24
Thank you very much.
25
CHAIRMAN SOLOMON:
Thank you, sir.
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33
1
John Resing?
2
You will submit written materials.
Thank you.
3
I.W. Devoe to be followed by Jon Sesso.
4 I
5
BY-DR. DEVOE:
T7
6 My name is Dr. Irving W. Devoe. I live at 1104
7 Broadway in Butte. .1, too, will state my qualifications.
8 I have a doctorate from the university of Oregon Medical
9 School, I have been an Associate Research Scientist at the
10 Atomic Energy Commissions Laboratories in Illinois, I was
11 Professor and Chaiman of the Department of Microbiology
12 and Immunology of Infectious Diseases at McGill University
13
in Montreal, and I have since been head of three
14
corporations, the current one being Metanetix Corporation,
15
headquartered here in Butte, Montana.
I am here to
16
protest and object to the accepted remedy for the Berkeley
17
Pit.
That is a precipitation technology for metals which
18
are sludged and put into landfills of one kind or another.
19
I have in my hand a paper entitled, "The
..
20
Precipitation of Copper from Mine Water in the Butte
21
District."
This is a paper from the office of william
22
Clark and it's dated 1902, and in fact this is the United
23 States patent on that process dated June 10, 1902. Now I
24 didn't bring the other one tonight which is also a paper
25 by the same company, this is the Anaconda Company, 1941,
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34
. I
Ii.
: ~n which it's suggested that the metals be sludged and
I
2 i converted into carbonates with lime.
I
This happens to be
3 i calcium hydroxide used here, a quicklime. The second one
I
i
4 : refers to liming the metals in the Pit and, of course,
5
these are for collections of metals commercially and they
6
are to go into the smelter.
7 But this is not a new technology, and in fact
8 I this paper has to skirt around some other patents prior to
9 this of the same technology. Dr. Hammen has just talked
10
about Chelation Chromatography.
I didn't coin that term,
11 but he knows that in this field I go back a ways myself.
12 But we don't -- neither one of us go back as far as
13 microbes do because all living cells use chelation
14
technology to handle metals.
And the Metanetix technology
15
is a technology that's been developing since 1980.
We
16
hold 19 patents in the chelation area, we hold 5 patents
17
in the engineering area, and we have 7 patents pending,
18
some of them that actually pertain to the Berkeley Pit
19
water.
20
This technology now has $35.5 million behind it
21
in its development. We are here ~n Butte on a commercial
22
operation to take metals from the mine water and the Pit
23
and convert these to metal products.
These products have
24
been developed since we have been here in Butte over the
25
last year, we have arrangements to move these products, we
NORDHAGEN COURT REPORTING
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35
1
have negotiated in the last or have started negotiations
2
in the last week for rail facilities to be available to
3
our company to ship the products.
We now, on our first
4 . scale of this operation, are processing more than 500,000
5
gallons a day, ,not too far from the million that has been
6
mentioned.
7
This technology has been tested by -- I should
8
say, tirst of all, the technology started using a clearing
9
radioactive metals from water, Cesium 137, Cobalt 60,
10
strontium 90, plutonium, uranium, and others.
It was
11
tested by the Batelle Laboratory for plutonium, it was
12
tested by the Dutch Independent Laboratories, it was
13
tested by Bateman Corporation, Edward L. Bateman from
14
South Africa.
It's been tested independently by the Nalco
15
Corporation, it just spent 10 and a half -- or 11 months
16
and $10.5 million being tested in Canada for cleaning of
17
harbor sediments.
The US-EPA came in, reviewed the study
18 and a publication is now out from the US-EPA, November
19 1993, saying that this technology successfully cleaned
".'." 20 contaminated soil from heavy metals, soil from a lead
21
23
smelter removing the lead, the harbor bottom sediments,
22
sewage sludge, and sewage sludge hash.
The technology is
now removing the metals from the Berkeley Pit water and
24
the mines.
We are pumping it out of the Kelley Mine at
25
the present time.
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36
1
It has been stated ~y the first speaker that the
2
best technology will not only clean up the water, it will
3
reduce the waste and be a permanent solution.
The
4
Metanetix technology has no waste.
It uses all of the
5
metals that it retrieves for products and it cleans the
6
water and puts out clean water.
This technology, as well
7
as that of Dr. Hammen's, was also not considered by ARCO
8
and i~ fact was rejected by ARCO.
9
In summary, I would like to protest as a citizen
10
and also as a resident of Butte and also as a head of a
11
company here in Butte that the wrong technology has been
12
chosen and the wrong solution has been chosen both by the
13
EPA and ARCO.
Thank you.
14
CHAIRMAN SOLOMON:
Jon Sesso to be followed by
15
Mary Kay Craig, next speaker.
16
MR. LYNCH:
I might begin by clarifying I am not
17
Jon Sesso.
18
CHAIRMAN SOLOMON:
And also, Mr. Lynch, would
19
you please spell your name for the court reporter.
20
T8
21
BY-MR. LYNCH:
22
I will.
My name is Jack Lynch, L-Y-N-C-H, and I
23
am Chief Executive of Butte-Silver Bow.
Mr. Sesso signed
24
in as I was unavailable at the time this hearing started,
~~
--
and again I wouldn't be here.
NORDHAGEN COURT REPORTING
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, 6
"
18
19
,. 20
21
22
23
24
25
37
'I
Basically, I would like to go over three
2
positions that the local government has taken relative to
3
the preferred alternative being proposed by, the EPA for
4
the Berkeley Pit and ~ine of Flooding Operable Units.
5
What we undertook to do in this instance had a unique
approach to it that we scheduled our own public hearings
7
on this preferred alternative and we conducted those
8
publiG hearings with the Council of Commissioners over the
9
past several weeks and concluded in a formal public
10
hearing last week.
And what the local government has done
11
as a result of that public input, and we did receive a
12
great deal of public input that covers all of the
13
possibilities of the spectrum, is that the local
14
government has gone on record, I guess, with a lot of
15
reservation and concern about the preferred alternative,
16
but also in support of some modifications to the preferred
17
alternative that the local government might find more
acceptable as they relate to the preferred alternatives as
it addresses the problem with the Berkeley Pit.
I think that this is the first time in a '
preferred alternative when the local government has gone
to the extent of conducting our own public hearings to
receive input to forward to the EPA, and I think it's the
first time in any of the Superfund-related items that ,we
have dealt with in this community that the local
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21
22
23
24
25
...
38
1
government has formally gone on record and has drafted a
2
resolution that sets forth their comments relative to the
3
preferred alternative.
4
There are four main issues that the local
5
government would like to address.
First of all, the
6
Berkeley Pit mine flooding is a unique problem that will
7
require unique and c'reative solutions both in technology
8
and i~ the implementation of the administrative processes.
Business as usual will not solve the problem and. to render
9
10
in the innovative solutions is the critical community
11
problem.
Butte-Silver Bow local government, through its
12
Chief Executive and Council of Commissioners, have
13
submitted the following comments on the Berkeley Pit
Remedial Investigation/Feasibility Study and the proposed
14
15
plan in the hopes of fostering the motivation and
16
creativity needed to meet the concerns of the citizens of
17
Butte-Silver Bow.
18
Number 1:
Assurances on the scheduling of the
19
construction of the plant.
The proposed plans should
document a firm schedule about the conservative trigger
point to plant cons~ruction to provide greater assurances
that the critical water level is never approached.
Second, enhanced monitoring in public education.
The County proposes the immediate installation of two. new
wells southeast of the Berkeley Pit and one of the
NORDHAGEN COURT REPORTING
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1
monitoring wells will function near the east Continental
21 P.i t, coupled with the com-prehensi ve education program,
3 I will ensure that information is disseminated regularly
in
4 i terms clearly understood by the average citizen.
Also
5
needed is a clear process on how the data from this RIfFS
6
will be updated, particularly if any new data indicates
7
any impact on the environment or human health thus
8
triggering changes in the preferred plan.
9
Number 3 relates to innovative technology which
10
the county has termed "Call to Action".
The Record of
11
Decision should require the use of innovative technologies
12
to supplement or replace the hydroxide plans and ensure
13
that the best available proven technology is used at the
14
time of implementation, thus avoiding problems with
15
hydroxide precipitation such as the sludge disposal at the
16
Pit or at a newly created depository that the future
17
contamination that could result from leaving billions of
18
gallons of contaminated water in the Pit, the loss of the
19
ore body, an enormous economic resource made in the
20
long-term community liability if the sludg~ is. redeposited
21
in that ore body.
The EPA should create a partnership with the
22
23
PRPs and set the county and the county -- to set a firm
24
goal to develop a comparable remedy with equal
25
effectiveness that is sensitive to cost.
We also make
NORDHAGEN COURT REPORTING
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40
1
note to waive the requirement to restore the bedrock
2
aquifer.
Butte-Silver Bow must be ensured that there is
3
no linkage between ~ai~c or righting of this contaminated
4
bedrock aquifer of the Pit and other aquifers along the
5
Clark Fork Basin.
6
We will, before the prior deadline, submit both
7 the four
8
9
10
11
12
13
14
15
16
17
18
19
priority points to the government along with
docum~nts in detail why this position was implemented
along with.the formal resolution from the Council of
Commissioners to our Congressional Delegation and to the
Environmental Protection Agency.
And we will see that.
these are available for credit.
We have gone to great extremes, the Government
has found themselves in a very difficult position.
We
have to balance both the criteria under which the EPA must
operate along with what we consider an extreme social and
economical impact that this might have on the community.
with all formal documentation and comments of the
government resolution will be submitted and admitted in
20 written form. Thank you.
21 CHAIRMAN SOLOMON: Mary. Kay Craig to be followed
22 by Bill Macgregor.
23
24 BY-MARY KAY CRAIG: T9
25
My name is Mary Kay Craig, C-R-A-I-G.
1 live at
NqRDHAGEN COURT REPORTING
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41
1
715 West Park in Butte.
My qualifications are that I am a
2
Butte kid and I am a Butte native.
I live here and I
3
expect to live here for the rest of my life.
I am the
4
upper river field representative for the Clark Fork Pend
5
areille Coalition.
The coalition is a nonprofit,
6
nonpartisan membership-supported public interest group
7
with a mission to protect and restore the water quality in
8
the C!ark Fork River watershed.
9
My dad taught me that the headwaters of the
10
Clark Fork River was here in Butte, Silver Bow Creek, not
11
at Warm Springs Ponds.
Silver Bow Creek starts in the
12
mountains northeast of Butte and it runs through the
13
valley, at least it did until that portion of the creek
14
was renamed Metro Storm Drain, perhaps for those who hope
15
not to have to clean it-.up.
16
Nonetheless, my dad said someday perhaps it
17
would be cleaned up so kids could play in it like kids do
18
in other towns that have creeks running through them.
19
Instead, Silver Bow creek now runs into the Yankee Doodle
20
Tailings Dam.
Water from there and from leach pads enters
21
the Berkeley Pit as aroundwater or as Horseshoe Bend.
22
EPA's preferred plan would divert the water from
water.
23
the Horshoe Bend away from the Pit, but that won't be
24
cleaned for our use for many, many years.
Once in the
25
Pit, EPA and ARca say the toxic water cannot leave.
It is
NORDHAGEN COURT REPORTING
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42
1
true Silver Bow Creek, Metro Storm Drain is mostly dry
2
through town, but that does not mean the water is not
3
leaving.
And
Berkeley Pit water can leave the Pit.
4
contrary to what EPA and ARC a tell us, there is strong
5
empirical evidence that it is leaving the Pit system.
You
6
don't need a hydrology degree to understand that it would
7
not have been possible for the Anaconda Company todewater
8
the mines and the Pit if water could not move through the
9
bedrock aquifer.
10
After a $10 million study done over 10 years,
11
ARca and EPA rely on theories and their opinions in
12 stating that water isn't leaving. They do not know what
13 is happening at depth, no one knows for sure. Their
14 preferred plan for the Pit and mine flooding is based on
IS
hydrology theory and guesses, not facts.
The fact is:
16
Bedrock aquifer water is entering Silver Bow Creek at the
17
west end of town where the bedrock rises to the surface.
18
We know this is true because Silver Bow Creek has a
19
gaining stream at that point.
The State Department of
20
Health and Environmental Science Superfund manager for the
21
Pit mine flooding operable unit said last Thursday night
22
at a meeting that the water entering the creek from the
23
bedrock is poor-quality water.
24
Why is that poor-quality water allowed to enter
25
the creek just below the Colorado tailings?
This is not
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1
even discussed in the mine flooding remedial
2
investigation.
It has surely contaminated mine flooding
3
operable unit waters, but appears to have been ignored.
4
If the Pit water is allowed to rise higher, we will see --
5
will we see~ question, will we see an increase in the
6
amount of water entering the creek from the bedrock
7
aquifer?
Obviously.,
Monitoring, wells should have been
8
part of the remedial investigation, not specified as part
9
of the remedy.
The remedy would address contamination
10
after the fact, not preventive.
11
The preferred ban allows the the travona water
12
to go as high as 5,435 feet in elevation.
It's at 5,427
13
now before it is pumped.
That water may also contribute
14 to the poor quality entering Silver Bow Creek from the
15 bedrock aquifer, particularly since where it is pumped is
16 25 feet higher than where the creek becomes a gaining
17 stream. EPA must lower the level at which that water is
18 pumped. Also regarding Silver Bow water, arsenic and iron
19 currently exceed water quality standards after dilution at
20 the Metro Sewer Plant. EPA and the State must insist in
21
the Record of Decision on meetinq the applicable standard
22
instead of creating early precedents for waiving legal
23
requirements.
24
Regarding the 25 billion gallons of toxic water
25
now captured in the Berkeley Pit which would be 56 billion
NORDHAGEN COURT REPORTING
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44
1
before any is cleaned and discharged to the creek about 28
2
years from now under the preferred plan, to what
3
beneficial use is that water being applied?
There is a
4
fixed amount of water on this earth.
Why could 56 billion
5
gallons be tied up in perpetuity?
That is what this
6
preferred remedy would do and that is unacceptable.
I
7
have heard many concerns of the community in attending
8
meeti~gs over the past couple of years, reasons that they
9
do not favor thiz plan including legal, technical, cost,
10
environmental, .economic, and social issues.
~1
Cost issues:
The people of Butte expected EPA
12
to require the water level in the Pit be lowered.
Because
13
of cost alone, EPA said they did not consider that a
14
potential remedy.
Where did EPA come up with the $60
15
million lid they have established for this cleanup?
A
16
cleanup for perpetuity.
Miners tell us that that is what
17
it cost to put pumps into the Kelley Mine Shaft twenty
18
years ago.
It just does not appear to be adequate.
19
People would have preferred EPA take a business approach
20
and ask:
What needs to be done and what is the most
21 efficient way to do it? Because of cost, EPA did not
22 consider condensation or other newer-technologies that
23 could be made available soon. People think that metals
24 recovery should be considered as an offset to the cost of
25
good cleanup.
Also, people wonder why ARCO should not be
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1
required to put up the money up front instead of relying
2
on their self-insurance status.
In this town we have
3
heard of perpetual care before and from a very trustworthy
4
and well-intentioned source, yet it fell through.
We
5
don't want to have to trust ARCO for perpetual cure of the
6
Berkeley Pit forever.
7
Legally, people aren't real happy that EPA is
8
getting rid of the threat of release of contamination from
9
the Pit -- EPA is not getting rid of the threat of release
10
of the contamination from the Pit.
That's what we thought
11
their job was.
Under this plan, the threat will remain in
12
perpetuity.
The law says EPA should reduce mobility,
13
toxicity, volume, of contamination.
Folks wonder, how
14
come the volume of contaminated water can be allowed to
15
double in the Pit before any is cleaned?
It creates more
16
toxicity as well and it increases probability of mobility
17
through fractures in the bedrock as it mobilizes upward
18
through this plan, all the way to 5,410 feet.
People
19
don't know why Butte should not be treated as well as
20
other towns where contaminated water is cleaned up for
21
their use.
The idea of writing off the bedrock aquifer,
22
setting a precedent for mining site, is not acceptable.
23
An aquifer is a vessel, a dish that holds water.
24
The water is the product.
We need more water in this
25
valley.
We could have it if the contaminated water were
NORDHAGEN COURT REPORTING.
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46
1
pumped and cleaned.
To come to its opinions and preferred
2
remedy, EPA and ARC a did what is called "modeling" of
3
underground water flows.
In these, they assume a constant
4
head pressure.
Scientists tell us that such an assumption
5
would allow one to create any result they desired.
EPA
6
must review their modeling and dismiss conclusions from
7
it.
8
People are worried about induced infiltration
9
where contaminated water from the Hill or in the Pit could
10
travel south and contaminate wells.
People hope that the
11
existence of contact between Butte-Silver Bow County and
12
ARCO for post Superfund well bans isn't being considered
13
by EPA and preferring to let the Pit fill.
People worry
14
that putting off cleaning Pit water for up to 28 years
15
doesn't affect the ability to get other sites cleaned up
16
soon; for example, s~ream bed sediments in Silver Bow
17
Creek.
Regarding innovative technology and timing, EPA
18
should go forward from today, not backward from the year
19
2022.
Here is a plan that most of Butte would likely find
20
acceptable. Butte-Silver Bow County has asked EPA to find.
21
research dollars in their S-I-T-E, Site Program, or
22
another of their research programs.
It could be used to
23
help come up with newer cost-effective technologies.
24
If these dollars could be added to those
25
provided by the Department of Energy in its funding of the
NORD HAGEN COURT REPORTING
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.-
.-
"'.,'
47
1
Resources Recovery Project of Montana Technologies Company
2
in Butte, it would mean more technologies could be tested
3
in a shorter period of time.
One idea is to have the
4
project send out a call internationally for new
S
technologies.
Let competition and market forces prevail.
6 Companies wanting a piece of the mineral's pie in Butte
7 could get investors "to help test their ideas. Others
8 could.:take a chance that MSE would choose their's to test.
9 Within two to three years MSE could specify 1, 2, or 3
10
cleanup processes and have them go into pilot runs.
EPA
11
could require that within the following five years, a
12
pumping plant be designed and constructed.
By the end of
13
the total of seven or eight years, we could have clean
14
water running down Silver Bow Creek.
15
Young people are wondering about future shock.
16
They are not happy to hear EPA and ARCO want to put off
17
cleanup of Pit water until it nears the full mark.
Future
18
generations are going to be saddled with maintaining a
19
pumping and treatment facility in perpetuity under any
20
plan.
The least we can do is get the remedy in place now,
21
not shove that off to them as well.
22
The EPA/ARCO plan doesn't adequately consider
23
the fact that this country has only been around 200 years.
24
It doesn't consider the possibility of a future economic
2S
depression that might take dollars away from maintaining
NORDHAGEN COURT REPORTING
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48
1
the Pit at its full sign.
It doesn't consider the
2
possibility of social upheaval or war.
It doesn't appear
3
to have adequate fail-s~fes built in case of a breakdown
4
of the nuts-and-bolts plants that would have to be
5
maintained forever.
6
It doesn't look at the worst case scenario, in
7
case of an earthquake.
It doesn't look at what it is
8
doiny to property values in Butte today, and especially
9
near the Pit.
It doesn't seem to care about short-term
10
adversities such as doubling contamination, and it doesn't
11
leave room for entertaining holistic approaches to Pit
12
cleanup, approaches that could provide many benefits to
13
the community.
What it does do is attempt to control'
14
contaminants, not clean them up.
What it ,does do is give
15
ARCO the least costly option, one that the next generation
16
of ARCO and EPA employees and Butte-Silver Bow citizens
17
would have to address, not today's folks who have studied
18
the site.
Butte folks just: don't think that's fair. The
people of Butte need to be heard by EPA, not ignored. We
19
2,0
21
obtained over 2,000 signatures in-just three days' effort
22
at K-Mart and others have come flying in. We have got
23
over 3,000 signatures on a petition where the Butte people
24
are asking EPA to lower the level of the Berkeley Pit and
25
take action now for cleaning it up.
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
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...
49
1
It is noteworthy that this is the first time
2
this community has come forward in great numbers and in
3
strong agreement on an environmental, social, economic
4
issue:
The Berkeley Pit and mine flooding preferred plan.
5
The people of Butte are saying that the preferred plan is
6
not acceptable and that it should be rejected.
Thank you.
7
CHAIRMAN SOLOMON:
Thank you.
8
Bill Macgregor and to be followed by Edus
9
Giavomin.
10
11
T 10
BY-MR. MACGREGOR:
12
My name is Bill Macgregor that is
13
M-A-C-G-R-E-G-O-R, and I am the Technical Assistance Grant
14
Coordinator for CTEC.
I would like to read this evening a
15
letter I have written to Russ Forba, Remedial prqject
16
Manager, as my official comments not on behalf of CTEC,
17
but on behalf of myself as someone who has followed this
18
process for the last five years as a citizen of Butte.
19
I run a small train of pedigrees as some of the
20
predecessors here.
My doctorate is in words, not in
21
science, and my view of the problem is as a semantics
22
problem at least as much as a technology problem.
At the
23 last meeting of the Citizens Technical Environmental
24 Committee on April 21, I eluded to a term that seems
25 appropriate to the situation we find ourselves in now. I
NORDHAGEN COURT REPORTING
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I
,.
50
1. would like to recapitulate that term and briefly explain
2
how it embodies the current predicament faced by all of us
3
involved in contributing our energies to helping solve the
4
problems of the Mine Flooding operable Unit at
5
Butte-Silver Bow Creek Superfund site.
6
The writer, Paul Dickson, coined the term, the
7
verb, lito Neckar", N-E-C-K-A-R, to identify a phenomenon
8
he says describes one aspect of life in the last quarter
9
of the 20th century.
To test or try something
To neckar:
10
in such a way as to invite disaster; as in, "He neckared
I-I
the brakes on his new Ford by racing up close to a brick
12
wall and then slamming down on the pedal at the last
13
moment. II
14
The term comes from the river of the same name
15
in West Germany where the prime example of modern
16
neckarism took place in 1979.
The US Army helped German
17
authorities test a new bridge spanning the river by
18
driving 34 of its heaviest fully manned M60 tanks onto the
19
It sagged, but did not collapse.
I have a
structure.
20
photo of 34 tanks on a bridge crossing the Nectar River.
21
They are still there.
The attached page shows the photo
22
of that moment which no doubt represents a moment of pride
23
for certain German civil engineers and immense relief for
24
the commander of that column of tanks.
25
Like Dickson, I am a student and an engineer of
NORDHAGEN COURT REPORTING
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..
..
Sl
1
words, not of concrete, stone, steel, water and
2
engineering.
The source of alarm I felt for the five
3
I
years I have followed EPA's work toward a solution of the
4
Berkeley Pit Mine Flooding Operable Unit is in the
5
semantics used by the agencies who are charged with
6
protection of the health of this community and its
7
environment.
8
EPA's definition of the problem and its solution
9
have always centered on the notion of a Critical Water
10
Level.
In fact, this assumption has become so ingrained
11
that it has received the great honor of being added to
12
EPA's list of acronyms, the Critical Water Level; that's
13
the CWL.
14
What's always bothered me about the CWL as it is
15
now known is not the precise level.
Representative Daily
16
and others have always argued about where ought to be, but
17
that's not my issue.
My issue has always been that EPA's
18
reliance on what it calls a "critical water level" is a
19
perfect case of neckaring Butte's future.
What I mean by
20
that is that the solution of the problem of the rising
21
water in the mine system beneath Butte has been to play
22
footsie with disaster, even at the semantic level.
23
The argument that EPA can't enforce control of
24
the water without showing probability of its release into
25
the environment is shallow at best, and at worst shows
NORDHAGEN COURT REPORTING
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..
.'
52
1
cynical disregard for the opposite argument which says
2
that without such control, the release of contaminated
3
water is certain to occur.
Both of those are admitted
4
positions but the second one is disregarded.
Facing the
5
absolute certainty of such eventual releases into the
6
environment if no action is taken, the community is left
7
to wonder what h~nd of solution is it that tells us to
8
wait .until the situation is approaching a crisis stage
9
that is in critical, crisis stage before action will be
10
taken.
And then the action proposed involves perpetual
11
effort and expense such that mining which has always been
12
Butte's pride is destined to become its curse.
13
I have two tangible requests to make at this
14
final moment in the public comment period at this
15
opportunity.
First is very simple:
A semantic request,
16
and it may sound trivial to some, but I am serious.
If
17
the water level EPA has set is indeed safe for Butte and
18 all the communities downstream, say that. Stop calling it
19 the "critical water level" and call it instead the "safe
20 water level" and we will hold you to that promise. That
21
way when somebody asks me about EPA's goal for Butte
22
cleanup operations, I can say, "To keep us safe,. instead
23
of, "To keep us in perpetual crisis."
24
Second, a common sense but technical request:
25
Beyond controlling Horseshoe Bend water as part of a
NORDHAGEN COURT REPORTING
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5
6
7
8
9
10
11
[ 12
r" 13
14
""
53
1
inflow control regime, please consider long-term options
2
for dewatering upstream of the contaminated ground water,
3
rerouting everything possible and reducing the need for
4
perpetual treatment.
If stasis in the mine flooding can
be achieved at an earlier date without the need for
long-term treatment and attendant sludge generation, or
any other expensive, long-term treatment needs, everyone
wins.~ Cleanup costs drop exponentially, water otherwise
destined to join the contaminated reservoir -- I should
say clean water is kept clean and usable -- and we will
all be able to point with pride to the solution when our
grandchildren and our great grandchildren ask us about the
world we have left them here in this area.
Intercept the water before it gets to the
15
contaminated areas on the hill.
Reduce its rate of
16
filling to next to nothing.
Avoid the need for treatment
17
altogether.
Is this too simple or too low-cost a solution
18
to be considered?
At the very least, avoid the kind of
19
disaster-orientation scenarios that seem to motivate so
20
much to have Federal Government's actions.
Don't let your
21
proposed plan -- don't let your proposed plan neckar
22
Butte's future.
Thank you.
23
CHAIRMAN SOLOMON:
Thank you, Dr. Macgregor.
24
Edus Giavomin, next speaker.
25
I think I made a mistake.
EDUS GIAVOMIN:
I
NORDHAGEN COURT REPORTING
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..
54
1
signed a paper that was out on the table, and is that
where we were to sign up to speak?
CHAIRMAN SOLOMON: That's what that was for.
2
3
4
EDUS GIAVOMIN:
I didn't know that.
I thought
5
it was was here attending this meeting.
I am sorry, but I
6
would like to say something.
7
8 BY-MS. GIAVOMIN: T 11.
9 I am a native of Portland, Oregon, and arrived
10 here in Butte in 1980, and I tend to stay here. My
11
children are here, my grandchildren are here, and I hope
12
my great grandchildren will be here.
And I remember my
13
grandmother in 1898 when she walked the streets of Butte
14
with her tambourine and she was a Salvation Army Lady and
she sang songs and she said you could make more money in
15
16
the bars singing because there were a lot of bars in
Butte, Montana, and you could fill your tambourine or
17
18
whatever to take it back to the Salvation Army.
She told
19
my mother and I remember stories about Montana and, of
20
course, this area of Butte and how beautiful it was, how
21
beautiful Montana was in the Deer.Lodge Valley and the
22
clean, clean water.
And I would like to thank everyone
23
who is here who has attended and the speakers have been
24
wonderful.
I hope that all of this attention will be --
25
somebody will listen and we will be able to do that for
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
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.
I
r
[
..
55
1
our future generations here in Butte, Montana.
Thank you.
2
CHAIRMAN SOLOMON:
Thank you.
Is there anyone
3
else who wishes to speak at this time?
4
MR. RESING:
Yes.
I am John Resing,
5
representing Chromatochem.
6
CHAIRMAN SOLOMON:
Spell your last name.
7
MR. RESING:
R-E-S-I-N-G, J-O-H-N.
8
9
T 12
BY-MR. RESING:
10
Chromatochem does not have the final draft of
11
the local government stating their position.
I am working
12
from a draft dated March 21, 1994, and I have no
13
information that there's any subsequent difference
14
included.
We specifically want to draw attention to the
15
Call for Action on innovative technologies in Paragraph
16
3.1 in which the local government takes a position that
17
the RIfFS is defective because the remedial technologies
18
were not considered in combinations.
It is a preordained
19
result for the analysis to have been made in the manner as
20
reflected in that draft document.
21
Nobody asserts that reverse osmosis technology
22
is an appropriate technology for the level of
23 contamination of the Berkeley Pit water as the first stage
24 of an overall treatment soluti~n; however, it might well
25 have a role to play in the final step of a process that
NORDHAGEN COURT REPORTING
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56
1
solves the problem~
2
Second paragraph, 3.2:
The selected technology
3
is at odds with metals recovery.
Again, what we see here
4
is the heavy metals being turned into a sludge which does
5
not solve the problem, it just relocates the problem to a
6
new location.
The hydroxide precipitation technology has
7
been described very eloquently as an old technology
8
notwithstanding any claims for newness that have been
9
made.
10
Paragraph 3.3:
The sludge disposal not in the
11
Pit, the County has accurately described in that paragraph
12
the chemistry that prevails; that chemistry should be
13
apparent.
Anybody that's had a couple of college level
14
classes in chemistry, it is ludicrous the position that is
15
being taken in the preferred alternative to perpetuate and
16
increase the problem instead of solving the problem.
And
17
I guess the question for the EPA is:
How can a solution
18
which increases the problem be lawful?
19
Paragraph 4:
A better analysis of the non-Pit
20
Sludge Repository Options.
We obviously acknowledge this
21
argument and want to point out that the technology
22
described by Dr. Devoe as well as the technology described
23
by Dr. Hammen produced no sludges.
It is not necessary to
24
think about sludges anymore, ladies and gentlemen.
25
3.5 deals with the loss of the ore body for
NORDHAGEN COURT REPORTING
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r- - 10
I
11
I[ 12
r 13
14
15
16
17
18
'"
57
1
future generations, the point that was made that this an
2
economic resources.
The phrase was used "to mine the
3
water".
That is what the technologies that have been
4
developed in the period in which the authors of this
5
study, I guess were absent without leave since they seem
6
to have quit in 1977.
The essential report to make is
7
that MSE and the Resources Recovery Program issued a
8
worldwide RFP, went out to more than 200 companies in -all
9
major industrial nations of the world.
There were over 32
responses to that RFP..
The decision process narrowed that
32 group down to 10.
The final selection process is
underway right now.
Those proof of technology on actual
Berkeley Pit water at treatment-scale levels could be
occurring as early as September of this year.
And I guess the question would be again:
Why is
this Record of Decision not defective if the authors of
the Record of Decision did not survey the same kinds of
available technologies and offer the opportunity to
19
demonstrate what really can be achieved?
What we see in
20
reading that study is a paper thinking, reading,
21
speculatin~, and re~lly, skewing the process to reach a
22
preordained solution as has been referred to many times.
23
Our previous speaker, Dr. Macgregor, 1 thought
24
was very noteworthy in pointing out that the semantic
25
analytical framework that has been adopted from Day One
NORDHAGEN COURT REPORTING
-------
58
1
apparently is there isn't any way to solve the problems,
2
so let's put it off at the least cost.
Again,
3
Chromatochem would challenge a decision to proceed with
4
the preferred technologies here in the absence of proof
5
that these alternative technologies here and now, not to
6
be developed in ten years, but here and now, are not
7
lesser cost that creates water, that could be used for
8
drinking purposes, let alone agricultural purposes or any
9
other community needs.
The Pit and the ore represents
10
there is an economic benefit and it can be mined.
Thank
11
you.
12
Thank you.
CHAIRMAN SOLOMON:
Is there anyone
13
else who wishes to comment at this time?
14
15
TO
BY-MR. KEANE:
16
My name is Jim Keane, K-E-A-N-E.
I live at 2131
17
Wall Street located south of the Berkeley pit.
It is
18
important to recognize the parties here, we have spent
19
years and years doing this.
On April 24, 1982, ARCO
20
committed the crime against this community of shutting off
21
the pumps in Butte.
"Each of us as citizens of the United
22
States are guaranteed to be held accountable for things we
do with malice and forethought if it causes a problem to
23
24
someone else.
25
In 1982, ARCO, with malice and forethought, shut
NORDHAGEN COURT REPORTING
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59
1
the pumps off.
What would have happened if they didn't do
2
that?
They could have been doing what these gentlemen are
3
talking about for the past twelve years by mining the
4
water which they have done from the early parts of this
5
But they chose to walk away from the underground
century.
6
mines by closing the pumps off.
7
After that' time, we got into the Superfund laws,
8
which~they were held accountable.
Our people, our judges
9
and protectors in this society are the agencies that
10
protect us from people who do deeds with malice and
11
forethought.
In this case, it's the EPA.
ARCO has
12
committed environmental murder to this community.
EPA is
13
responsible to this country to stop that.
The issue is:
14
Why should they be negotiating with ARCO to allow them the
15
least possible cost when'ARCO has chosen that course
16
itself?
It's time that the Environmental Protection
17
Agency turned to the opinions of the public, not take the
18
resources of ARCO studies and accept them, not negotiate
19
away our future, not negotiate away our environment, not
20
say that we are going to double what the Pit is,
21
everything is going to be okay.
The judge here is the EPA, the person who
22
23
committed the crime is ARCO, and we are the victims.
This
24
must be stopped and the resources available to correct
25
this.
why continue to harm the environment?
Let's get on
NORDHAGEN COURT REPORTING
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1
[-
60
i
I
1 ' with the problem of doing what our forefathers did and
2
mine millions and millions of dollars from this community
3
which raised our children, which built the schools, which
4
created a healthy working environment and good wages.
We
5
can go back to that, but we can't do it by dumping sludge
6
in the Pit.
Let's get
Let's protect the environment.
7 back to
8 done.
9
10
create good jobs and make ARCO pay for what it has
CHAIRMAN SOLOMON:
Thank you.
Is there anyone else who wishes to comment at
11
this time?
Once again, we will ask:
Is there anybody
12
else who wishes to comment at this time?
13
At this time let's have the record indicate that
14
there is no one else who has come forward to speak this
15
evening, and so before we call this hearing to, a close, I
16
will remind you once again that comments may be submitted
17
in writing and you can transmit them by the US mail or
18
electronic means to Russ Forba, Remedial Project Manager,
19
US-EPA, 310 South Park, Drawer 10096, Helena, Montana,
20
59626, until the close of the comment period on April 29,
21 1994.
22 Yes?
23 UNIDENTIFIED SPEAKER: It's 301, not 310. 301
24 South Park.
25
CHAIRMAN SOLOMON:
Okay.
For the record, there
NORDHAGEN COURT REPORTING
BUTTE, MT - (406) 494-2083
-------
61
1 i is an error in my material, and so that stands corrected.
2
There being no one else to come before this hearing this
3
evening, this portion of the proceeding is now closed.
4
(The hearing concluded at 9:00 p.m.)
,.
5
6 * * * * *
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
NORDHAGEN COURT REPORTING
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C E R T I F I CAT E
STATE OF MONTANA
SSe
County of Silver Bow
I, Kimberly Johnson, Registered Professional
Reporter for the County of Silver Bow, State of
Montana, and Notary Public, do hereby certify:
That the public hearing was taken before me at
the time and place herein named; that the hearing
1
f'
was reported by me in machine shorthand and later
transcribed by computer, and that the foregoing
sixty-one (61) pages contain a true record of
the testimony of the witnesses, 'all- dOne 'to' 'the -. "
best of my skill and ability.
i,
I.
IN WITNESS WHEREOF, I have hereunto set my hand
this ~ay of !J..~~, 1994.
,..
(NOTARIAL SEAL)
I
, \
-------
PUBLIC HEARING
MINE FLOODING OPERABLE UNIT
APRIL.26,1994
NAME
ADDRESS
PHONE
R~PRESENTING..
(NAME OF GROUP IF ANY)
- <;',LVVt- ~..".,} Lo {"~ P (;". I.t'-
I~ (:..~ct~:6 ~
""'-
\ ..
\
\
... ..__.. -- ...---.--....--.. --.-.
-------
OPE!'.1NG STATEME~'T BY PRESIDING OFFICER
My name is Robert L. Solomon. I have been retained as an independent party to conduct
the public hearing this evening. For the record and to the best of my knowledge, I am not an
employee or member of any of the governmental agencies, pri\'ate companies, or public or
membership organizations in\"olv~d in the discussions or proposals related to the matter about to
- .
be heard.
Let the record show that this is the time and place for a hearing to receive public com-
ment on the Proposed Plan of the Mine Flooding Operable Unit (Berkeley Pit and Underground
Mine Workings) at the Silver Bow Creek-Butte Area NPL Site located in Butte and Walkerville,
Montana. The United States Environmental Protection Agency (EPA) and the Montana Depart-
ment of Health and Environmental Sciences (fvIDHES) published notice to hold a public com-
ment period on the Remedial Im'estigation'Feasibility Study (RlIFS) report and the Proposed
Plan for the Mine Flooding Operable Unit. The Public Comment Period was to be a period of 90
days from January 27, 1994 to April 29, 1994. The public hearing for Mine Flooding was noticed
to be held at this time and place to provide the public the opportunity to give formal comments
to EP A and MDHES.
In addition, anyone \\ishing to make oral ,public comments was offered the opportwUty to
come into the Butte EPA Office in the Silver Bow County Courthouse from 9:00 am to 5:00 pm
on Monday or Tuesday April 25 or 26, 1994, for the purpose of recording their comments into a
tape recorder. The comments received in this manner \\ill be transcribed. \\ill become 'a part of
the official record, and \\ill be responded to in the Responsiveness Summary. Officials of the
-------
EPA were available to answer questions during that t\\'o day period. Wrinen comments may
3D\
~ubmined to Russ toriJa, Remedial Project Manager, CS EPA, )W S. Park, Drawer 10096,
Helena, MT 59626, until the close of the comment period on April 29, 1994.
The ground rules for this evening are as follows: This is a hearing to recei"e public
comment and information. It is not ad,'ersarial in nature, and questioning or cross examination
by the public will not be permined. The presiding officer may ask questions in I)rder to clarify
statements or information being presented. Persons making presentations may submit comments
orally, or in ,\-Titing. The name .of the person to speak and the person to make the next presenta-
tion \\ill be announced by the presiding officer. ~'hen you co~e to the microphone, please begin
by stating your name, address, and any organization or group that you may be representing this
evening. Present your information in a manner that is most comfortable for you. You may speak
extemporaneously, you may summarize your comments, or you may read them into the record. If
you have prepared a wrinen statement, it "ill be appreciated if a copy can be given to the
presiding officer or the reporter to assist in the preparation of the transcript of this hearing. All
,..Tinen materials received this evening "ill be given the same consideration as oral comments
and ,\-ill be responded to in the Responsiveness summary.( o.dcitt;L i0?fb )
Due to the number of persons wishing to provide comments this evening, limits \\ill have
to be imposed on the length of time available to each speaker. You \\ill be given an indication
that your alloned amount of time is nearing an end, and that you will be required to wrap up your '
comments. If you continue to speak beyond the alloned time period, you \\ill be asketi to termi-
nate your presentation. Your cooperation in holding to the time constraints will offer all who
-------
wish to speak the opportunity to do so. Recesses will be called by the presiding officer at appro-
priate intervals.
The record \\ill show that the ground rules for this hearing have been made part of the
the record. The 1m'itation for Public Comment on this maner has been made a part of the record
as well. All \\onnen documents and oral comments received prior to this evening are by this
reference made a part of the of this proceeding.
We \\ill now begin the public comment portion ofthe hearing.
3
~
-------
917 West Broadwav
Butte, !\.lontana 59701
April 26, 1994
Russ Forba, RPM
U.s. E.P.A.
301 South Park
Helena, !\lontana 59626
Dear Russ:
At the last meeting of the Citizens' Technical Environmental Committee (April 21), I alluded
to a term that seems appropriate to the situation we find ourselves in now. I'd like to
recapitulate that term, and briefly explain how it embodies the current predicament faced by
all of us involved in contributing our energies to helping solve the problem of the Mine
Flooding Operable Unit at the Silver Bow Creek / Butte Area Superfund Site. My statements
tonight, as always, are my own, and though I have actively followed developments
associated with this aspect of local Superfund issues (as part of crEC), I speak only for
myself, not crEC) in what follows.
Paul Dickson coined the verb "to Neckar" to identify a phenomenon he says describes one
aspect of life in the last quarter of the 20th century:
NECKAR. To test or try something in such a way as to invite disaster:
"He neckared the brakes on his new Ford by racing up close to a brick wall
and then slamming down on the pedal at the last momenL" The term comes
from a river of the same name in West Germany, where the prime example
of modern neckaring took place in 1979. The U.S. Army helped German
authorities test a new bridge spanning the river by driving 34 of its heaviest
fully manned M60 tanks onto the structure. It sagged but did not collapse.
The attached page shows a photo of that moment, which no doubt represents a moment of
pride for certain German Civil Engineers, and relief for the commander of that column of
tanks. .
Like Dickson, I am a student and an engineer of wurds, not of concrete, stone, or steel. And
the source of alarm I have felt for the five years I have followed EPA's work toward a
solution at the Berkeley Pit (the Mine Flooding Operable Unit) is in the semantics used by
the agencies who are charged with protection of the health of this community and its
environment. EP A's definition of the problem, and its solution, have always centered on the
notion of a Critical Water Level; in fact, this assumption has become so ingrained that it has
received the great honor of being added to EP A's list of acronyms. What has always
bothered me about the CWL, as it is now known, is not the precise level (5410' ... 5435'... the
arguments on both sides for different levels sound reasonable to me). What has bothered me
for five years of discussions about the Pit, and what bothers me now is that EP A's reliance
. ~
-------
on what it calls a Critical Water Level is a perfect case of neckaring Butte's future.
The solution to the problem of the rising water in the mine system beneath Butte has been to
play footsie with disaster, even at the semantic level. The argument that EP A can't enforce
control of the water \\;thout showing probability of its release into the environment is
shallow at best, and at worst shows cynical disregard for the opposite argument, which says
that, without such control, the release of contaminated water is certain to occur. Facing the
absolute certainty of such eventual releases into the environment if no action is taken, the
community is bound to wonder: "what kind of solution is it that tells us to wait until the
situation is approaching a crisis stage before action will be taken... and then the action
proposed involves perpetual effort and expense, such that mining, which has always been
Butte's pride, is destined to become i~ curse."
J have two tangible requests to make at this final moment in the public comment period for
this operable uni~
1)
a semantic issue: if the water level you have set is indeed safe for Butte, and all the
communities downstream, say that. Stop calling it the critical water level, and call it
instead the safe water !evel. That way, when someone asks me about EPA's goal for
Butte cleanup operations, J can say "to keep us safe," instead of "to keep us in
perpetual crisis."
2)
a commonsense, but technical request: Beyond controlling horseshoe bend water as
part of an inflow control regime, please consider long-term options for dewatering
upstream of the contaminated groundwater, rerouting everything possibl~, and reducing
the need for perpetual treatment. U stasis in the mine-flooding can be achieved at an
earlier date, without the need for long-tenn treatment and attendant sludge
generation, everyone wins: cleanup costs drop exponentially, water otherwise destined
to join the contaminated reservoir is kept clean and usable, and we will all be able to
point with pride to this solution when our grandchildren and great grandchildren ask
us about the world we've left them.
Intercept the water before it gets to the contaminated areas on the Hi1J; reduce the
Pit's rate of filling to n"ext to nothing; and avoid the need for treatment altogether. Is
this too simple or low-cost a solution to be considered?
At the very least, avoid the kind of disaster-orientation scenarios that seem to motivate so
much of the federal government's actions. Don't let your proposed plan neckar Butte's
future.
Sincerely, ""1 ."/ "
."~"(/ /iit t ~
.;.--:L{, I ;'t.4!' (.
Dr. William B. I.1.cgr go)
-------
U.S. AImy M50 Tanks testing the validity of German engineering calculations on the Neckar River, 1979.
Source: i':ords ty Paul Dickson. New York: Delacourte, 1982.
-------
Acid mine water processing
and metal recovery by fast
solid phase extraction
Richard F. Hammen, David C. Pang, Lori Stepan Van Der Sluys,
Ralph C. Judd and Eric Loftsgaarden.
\1ineral e\traction from sulfide ore
deposits usually leads to the combined
action of ox~ gen and water on the newly
exposed ore. The resull is acid mine
drainage. a low pH solution of various
metal sulfate salls and sulfuric acid.
Paradoxically. the valuable metals
dissolved in acid mine water are a liabil-
ity Oecause they are too toxic for dis-
charge but too dilute to recover eco-
nomically. The expense of compliance
with walerquality release standards has
reduced the profitability of many min-
ing o~rations.
Solid phase extraction (SPE) col-
umns have been develo~d to extract
metals from 3cid mine water. These
columns are designed to remove the
toxic elements from water and recover
Richard F. Hammen is president. David C.
Pang is manager of production development.
Lori Stepan Van Der Sluys is scientist and
Eric Lottsgaarden is laboratory technician.
all with Chromatochem.lnc.. 2837 Ft. Missoula
Road. Missoula. MT 59801. Ralph C. Judd
is professor of microbiology. University 01
Montana.
.~
COftt8fftift...d water
L
o
A
o
. St,O"; B;"~ "'9
"..0'
. ".Oiol.. b "0;"0
...tat
~.:ontamir..t8d
"".ter
4~
WeeklY bil'd."9
a.4.~.1
Fig. 1 - Displacement chromatography process.
Table 1 - Metal concentrations
Ion
Copper
Iron
Manganese
Aluminum
Cadmium
Zinc
SO,
Sodium
Calcium
Magnesium
ppm
174
437
202
277
2
543
7462
85
480
421
the metals as purified fractions. This
anicJe describes the results of a Phase I
. bench-scale project to test the perfor-
mance of the SPE columns. The tests
were conducted with water collected
from the abandoned Berkeley Pit cop-
per mine in Butte. MT.
Solid phase extraction and
displacement chromatography
The SPE columns contain large par-
ticle silica of 105 micron average diam-
eter. The silica surface is modified by
covalently bonding with a proprietary
long. hydrophilic. chemically stable
0.1" II 10
2 4
linker molecule. The terminus of the
linker is activated and then derivitized
with appropriate chelating groups. The
results described were obtained with
columns containing immobil ized
polyethylene imine (PEl).
Solid phase extraction and displace-
ment chromatography involves four
steps (Fig. I).
. Step I - Load. The acid mine
water is pumped through a column con-
taining a HiPAC-PEI silica. The chelat-
ing PEl molecules tightly bind the metal
ions by coordinate covalent bonds.
Because the binding constant for many
chelation reactions exceeds 10-9 Llmole.
the water exiting the column has levels
of metal with molar concentrations of
less than 10"9 moleslL (less than 10 ppb
for copper)". As the process continues.
the number of metal ions pumped into
the column approaches the number of
chelating groups a\'ailable to bind the
metal. and the co,lumn becomes satu-
rated.
. Step 2 - Displacement. When the
column becomes saturated with the
"'~':"O'" It'I;::-- 2 c'8CI'O~:'
:. '.'J
'10
Fig. 2 - Mine water fractionation.
...,... Z" Vn Zn...'
.'K!'O"'.
"'ec"'O"" ,
Z"" AI C~
I..t:.~.. t l.~-,. .-
-:.... r. S.. :att
~t
-------
:: ""'CII'..,." tI, ~ \10''''
! -
~
s
- -"
. ..
j
~.C\111'88
~WP\ ~z" _c.. _Ce ~.I
Fig 3 - Selective desorption of metals.
metals. continued pumping of the same
feed stream causes the more tightly bind..'
ing metals (iron) to displace the less
strongly bound manganese. zinc. alumi-
num and copper. This results in frac-
tions enriched for the less strongly bind-
ing metals. Depending on the nature of
the feed stream and the resulting dis-
placed metal concentrations in the frac-
tions. the metal fractions may be recov-
ered by electrowinning or precipitation.
Alternatively. the fractions may be
pumped through a second SPE column
for additional concentration and separa-
tion.
. Step 3 - Elute. The tightly bound
metals are stripped from the column by
pumping a dilute sulfuric acid solution
through it. The acid displaces the metal
ions. releasing them from the column as
a concentrate.
. Step 4 - Recycle. The column is
then regenerated for another use cycle
lei" ..1,.18 D, 8td VDI...
c
...
j
.
.
e.o vo'."...
lIDD....,z" .z"'.,
Fig. 5 - Metal purification ratios.
i -
:0.".1)'... D, Bees YO'1o
-------
Purity
100"
75..
50" -, '
ml
I
0"
F...
I ~
I E I -
? I
:.! w:
8
10.2
12.7
6.0 7.8
Bed Volume.
I ew. .z. mAl llllllleu 1IIIIII,.1
........, p" -.,. . fl .....
2.8
Fig. 7 - Metal purity by fraction.
the column. The first pan of the ~ln
fraction has very low concentrations of
other metals in it. It is therefore possible
to isolate a highly purified fraction of
~1n.
When the Zn begins to elute from the
SPE column. the column has no capac-
ity for Mn. The concentration of the Mn
in the eluate is close to the concentration
of \1n in the feed solution.
The purity of the Mn (the concentra-
tion of \In divided by the concentration
of the Mn plus Zn) in the eluate there-
fore begins to diminish. By the time the
Fe elutes from the column. the Mn pu-
rity has returned to the same level as in
the feed solution.
The metal purities are diagrammed
in Fig. 7. The data in the fraction analy-
ses for \1n and Zn are conservative
because the ICP instrument was satu-
rated at 1000 ppm Mn and 500 ppm Zn.
respectively. The actual purities of the
Mn and Zn fractions were greater than
indicated.
..."....1.'80 ..0 88Ct Yo'''''''
?
~ J ...
B
.'~
o
..
'"' "'0 I..,...
-. .
_"2
_2.
Fig. 9 - Pit metal capture vs. flow.
Co
-" 2
CIr"CII"" ..t...~ c:,...",..,.
.. .. .. ... J
1 /"~....
J
Fig. 8 - Pit metal capture vs. flow.
_2.
.
88a YO I wII88
-. .
-. 6 8""~ "
~Ietal adsorption capacity
and total capacity
The capacity of the SPE columns to
extract metals from solution was mea-
sured by pumping a solution of lOOppm
Cu sulfate at 9.6 BV/minute through a
column until Cu appeared in the effluent
(the breakthrough point). The concen-
tration of the metal in the column efflu-
ent was monitored by an ortical absor-
bance flow detector. When the copper
conceritration reached 5 ppm. the ex-
periment was terminated. .
The quantity of Cu adsorbed was 0.1
millimoles/ml of bed volume. The total
ion exchange capacity ofthe silica was
measured by acid-base titration to be 0.3
millimoles of base equivalents per ml.
The experiments described with Berke-
ley Pit mine' water were conducted with
silica of 0.1 millimole/ml Cu dynamic
adsorption capacity. Subsequent im-
provements in the silica manufacturing
process are now producing SPE col-
umns with O. 3 millimole/ml Cu adsorp-
tion capacity and 0.9 millimole/ml base
equivalents.
Adsorption kinetics
with acid mine "!'ater
To determine the operating flow rate
for a SPE process used for heavy metal
extraction. it is necessary 10 measure the
kinetics of metal adsorption. The ad-
sorption kinetics will determine the flow
rate or bed volumes per minute al which
the SPE column can be operated.
Earlierresults with copper and nickel
adsorption kinetics (unpublished)
showed the dynamic capacity of the
SPE column was unaffected by flow
rates from 1.2 - 9.6 BV/min. These
same experiments were conducted with
mine water to determine whether com-
plex solutions would behave the same
as simple metal solutions.
A 4.6- x 50-mm (0.18- x 2-in.) SPE
column was equilibrated and then loaded
with Berkeley Pit water at 1.2. 2.4. 4.8
and 9.6 BV/min. The column effluent
"'_818' Dt\ Wit..
~ ..
!
i
e
o
- .
~
C.
-' 6 IIV/.in
.... OrOI)!"' ..t.~,
Fig. 10 - Capacity vs. flow rate.
. 0
~ 108 "t. (IV/.''''
-------
...... .) ~.'t ..,...
3erkeley Pit Water
I
i i .
I ~ '
! .
~
~ .
. .
1 ,
,
,
. ,
"0- AIIte (8\/"',")
'......""'''' ::11"00'" '.".") s...c:.ocr\
Fig. 12 - Decrease in capacity from processing.
~=-C':)O' ......,.
Fig. 11 - Productivity vs~flow rate.
was monitored at 280 nm to detect the
breakthrough of metals. The digitized
data from the four chromatographic runs
were then normalized from absorbance
as a funclion of time to absorbance as a
function of Bed Volumes of acid mine
'" ater. The normalized data are shown
in Fig. 8.
The overlapping uptake curves
sho" n in Fig. 8. "hich show equivalent
performance from 1.2 to 9.6 BV/min.
were surprising in view of the usual
performance of chromatography media.
In general. the rate of extraction of sol-
utes by adsorption columns is limited by
the rate of diffusion of the solute mol-
ecules to the surface of the adsorption
media. "
For example. the metal chelating
resin manufactured by Rohm and Haas.
IRA 718. operates in a range of 0.13 -
0.5 BV/min. At flow rates above 0.5
BV Imino the metal extraction efficiency
will decrease. It can be seen from the
data in Fig. 8 that the kinetics of metal
ex traction by the SPE media are signifi-
cantly faster than with conventional
media.
To test whether the results in Fig. 8
were a" result of the proprietary linker
used to immobilize the chelating agent
to the silica suppon. a control experi-
ment was conducted by preparing a poly-
ethylene imine SPE medium. but with-
out the proprietary long linker. The
same experiments were performed with
the nonproprietary chemistry suppon.
The results are shown in Fig. 9.
In the case of the nonproprietary
chemistry. the dynamic capacity of the
SPE column decreased with increasing
flow rate. Such a result is consistent
. with conventional performance of chro-
Par Can' of Orlglna' Capaclt,
100'
..
~" .
~
= I
I
I
i
r."" "
............
'.
10'
o
200
matographic media. To compare the
proprietary and nonproprietary columns
more directly. the dynamic capacities
(BV to saturation) were ploned for the
two columns in Fig. 10. In Figure II.
the productivity (BV of water processed
per unit time) is graphed as a function of
flow rate. The productivity of the
nonproprietary SPE column did not in-
crease with increased flow. This was
due to the limitations of diffusion to the
adsorbing surface. On the other hand.
the productivity of the proprietary col-
umn did increase linearly with flow rate.
SPE column durabilit~. studies
Forthe SPE-displacement chromato-
graphic process to be profitable. it is
necessary for the value of the metals
recovered to exceed the incremental
costs of the SPE process. An SPE col-
umn was. therefore. subjected to re-
peated use cyc les to determine its opera-
tionallife under conditions of process-
ing Berkeley Pit water. The operational
cycle of the column was established to
take advantage of the metal separation
observed with the metal displacement
chromatography.
A fresh 4.6- x 50-mm (0.18- x Z-in.)
SPE column was packed with media
and its Cu adsorption capacity was mea-
sured. The processing cycles were then
initiated at 9.6 BV /min. After appropri-
ate periods of time. the process was
interrupted and the" Cu capacity was
measured again. The logarithm of the
Cu capacity data are ploned against num-
ber of cycles in Fig. 12.
The column lifetime data were plot-
ted semi logarithmically under the as-
sumption that the SPE column's capac-
ity would decrease by first order kinet-
"""""""""""""""""""
.00
1800
ics. Although more extensive data (more
cycles of operation) would be needed to
rigorously test this hypothesis. the re-
sults collected from 1500 cycles are
consistent with first order deterioration.
Based on these results. it is reason-
able to expect that an SPE unit will be
able to tolerate at least 1500 cycles of
use and will. therefore. be capable of
processing at least 22.500 BV of acid
mine water from the Berkeley Pit.
Summary
The technology of modifying silica
surfaces with hydrophilic linker mol-
ecules was developed to increase the
adsorption kinetics for the solid phase
extraction of metal ions from solutions
pumped through the column. Thesilica's
resistance to acid and base degradation
was increased by optimizing the tech-
nology. The high durability of the silica
media allows hundreds to thousands of
use cycles and improved economy of
operation. Thus. the linker technology
contributes several new dimensions to
conventional immobilized chelators
used in extractive metallurgy.
The SPE process accomplishes: .
a removal of heavy metals from acid
mine water streams and
. the separation of the metals into
fractions. allowing recovery of the met-
als by precipitation orelectrowinnning.
Work is in progress to determine the
economics of SPE and to extend its
applications to other metal-containing
solutions. -
Ackno\\'ledgment
This research was supponed in pan
by EPA SBIR Phase I Proposal No.
68D I 0038.
-------
Testimony on ProDosecLeJan. M~ng Operable Unit
Berkeley Pit 4/26/94
Submitted by: John W. Ray. 915 West Galena Si.. Butte. MT 59701
The purpose of Superfund is to cJean up hazardous waste sites which
are a threat to human heaIU'; and the environment. Remedies under
Superfund should provide a permanent cleanup remedy not temporary
containment or simply removal. to another site. Simply, cleanup is the
"act of cleaning up: and the term clean means "pure,free from dirt,
contamination,': impurities." According to the EPA publication entitled
SUDerfund: EnvironmentaLProgress the purpose of Superfund is to achieve
"long-term cleanup goals for sites" and to remove "contamination from the
envi ronment." (p. 1) The document further states that "the law directs EP A
to protect public health by meeting strict cleanup standards at each site."
and "Reduced to its environmental essence, the New Superfund mission is
'make sites safe, make sites clean, and bring new technology to bear on
the problem," (p, 3) According to the Superfund law, any remedy for the
Pit should be a cleanup remedy,
If one examines the major Superfund laws and regulations,
CERClA. SARA. and the NCP, one finds that they All emphasize:
1. Cleanup as the primary goal of any Superfund activity.
2. The reduction of of hazardous
substances. pollutants. and contaminants at a site.
3. Permanent cleanup remedies. Senator George Mitchell
(D-Maine) has argued that permanent treatment means that EPA
cleanup plans must result in a permanent and major reduction in
the toxicity. volume. and mobility of hazardous substances.
pollutants. and contaminants at a site and that this reduction
must be to the -lowest levels achievable: He stated: -In addition
to the quantitative reduction implied. significant reduction in
-------
2
this conlext means lhe minimization of volume. toxicity and
mobility of such substances to the lowest levels achievable
with available lechnologies.- 132 Congo Rec. S. 14914 (daily ed. Oct. 3.
1986)
4. Discourage EPA from simply moving wasle from one spot 10
another. For example. is 1r.is what will be done with 1he sludge
which will result from 1re_ling Pit wa1er?
5. ~ is n!'.t. the major factor. Cost is secondary to protecting
human health and the environment. Under Superfund. human
health must be protected from potential threats regardless of
cost.
o
i
t
In light of the above criteria. should we be comfortable with a proposed
plan which would allow the volume of toxic/contaminated water in the
Pit to more than double before anything is done? (From 25 billion gallons
to 56 billion gallons) Should we be comfortable with a proposed plan
which leaves a Berkeley Pit filled with toxic water to exist and be treated
in perpetuity? This proposed plan would allow a surface area of
contamination of 487 acres. Is this a cleanup remedy? Is this a remedy
which reduces the toxicity. mobility. and volume of hazardous waste? Is .
this a permanent remedy or a remedy which will leave us with a perpetual
environmental crisis?
Unfortunately. past Superfund efforts have not met these goals of
permanent cleanup. The Office of Techno logy Assessment (OT A) has
concluded that Superfund "remains largely ineffective and inefficient: and
. .
-------
3
program has too often settled for remedy technologies which would not
reduce the "toxicity. mobility or volume" of the the hazardous waste. All
too often Superfund has settled for remedies short of cleanup, Given the
serious nature of the contaminants in the Berkeley Pit. we cannot allow
any remedy short of cleanup. We must clean up the problem 50 that future
generations don't have to deal with it.
Seecinc comments on E.PA DroDosed clan:
1. Needs to ha~ a stronger emphasis on eventual permanent cleanup.
2, Needs to express in unequivocal terms that appropriate/new
technologies will be used. as they become available. in the cleanup of the
Berkeley Pit. The proposed plan's call for the use of innovative
technologies is too vague. This vagueness is particularly true wilh the
problem of sludge disposal. Either putting the sludge in the Pit or creating
a new tailings dump will have serious. polentially harmful effects on bolh
human health and the environment. The goal should be to keep the
producli on of sludge to a minimum.
3. Since so much of the proposed plan is based on predictive models. the
plan must clearly provide' a definite safety factor, Human error of
calculation or operalion musl not produce an environmental catastrophe.
4. The cost factor needs careful consideralion. There are two ways of
calculating cost: (1) What is the cheapesl plan of action or (2) Whal are
the goals we are trying lo achieve and. after the goals have been
established. whal is the most-cost effeclive way of achieving those goals.
According to Superfund. we are nollooking for the cheapest remedy but.
once we have decided on the plan we wanllo implementlo protect human
health and the environment in a permanenl way by reducing lhe loxicity.
mobilily. and volume of hazardous conlamination. what is Ute most
-------
4
does not determine which plan is accepted or the end result desired of a
cleanup plan, the cleanup plan and its end result, which should be
protecting health. determines cost. Senator John H. Chafee (R-RD has
commented on Superfund's consideration of cost: "The extent to which a
particular technology or solution is feasible or practicable is not a
function of cost. A determination that a particular solution is not
practicable because it is too expensive would be unlawful: 132 Congo Rec.
S. 14925 (daily ed. Oct. 3,1986) In devising a remedy for tht, Pit we
. ,
must not select the cheapest solution but the solution which
will maximize the protection of human health and the
environment. We must select a cleanup solution.
5. The solution to the Pit problem must show sensitivity to public input.
As process, democracy demands that the public participate in the
formulation and execution of publ ic po licy. This is particularly true in the
case of agency rulemak ing. as exemplified by the decision making
processes associated with the Berkeley Pit. Such rulemaking is inherently
undemocratic because the people male. ing the rules were not elected by the
people and are only very indirectly accountable to the people. Rulemaking
is only legitimate in a democracy if the public has ample opportunities for
meaningful participalion in lhe decision making process...Jjeaningful
It. is contrary to democratic practice to seek to substitute the opinions
of a few so called experts for public decision making. The best
environmental policy outcomes are achieved through pubHc discussion and
debate. The reason is that the answers to most environmental policy
Questions, as to most public policy questions in general, cannot be
determined with the exaclitude of a mathematical or scientific theorem
-------
5
of the probable or contingent. Given the complexity of society and the
complicated nature of most environmental issues, no one individual, not
even a scientific expert, knows with absolute certainty what is the best
publ ic po licy. (Of course, there are numerous examples of where the
experts were jus t p lain wrong.) Because of this contingency and
complexity, the best environmental policy answers are found through
pub lie discussion and by having the so-ca lied expert submit his or her
conclusions .0 critical public scrutiny and approval. The public has a right
and a duty to .subject the opinions of so-called experts to intense
criticism. If an attempt is made to substitute completely the opinions of
the technical person for the opinions of the public, neither, the public
interest nor the demands of good policy making are served. The final Pit
decision must clearly demonstrate and show how public input was
efficacious in influencin'g the final decision of the EPA.
John W. Ray 915 West Galena S1.
Butte. Montana 59701
-------
6
John w. Ray
Additional Questions about the ProDosed Plan-Mine Flooding Ocerable Unit:
1 . Superfund cans for the c1eanup of hazardous waste sites. The Pit is
certainly a hazardous waste site. Does the proposed plan really call for a
cleanup of the Pit. Is this a cleanup solution when it leaves in place a lake
of poison? Is lhis a cleanup solution when it leaves Butte in a state of
perpetual environmental crisis?
2. The Butte HiJl of which the Berkeley Pit is a part is very complex. Do we
really know what is going on? Are we relying excessive Iy on mode Is and
predictions which could be found to be inadequate?
3. The proposed cleanup plan sets a bad precedent. It writes off the
bedrock aquifer as permanently contaminated. No attempt is made to deal
wi th this significant contaminated area.
4. Will lhe conlaminated bedrock aquifer limit Butte's future growth by
limiting water supplies,
5, Will the proposed plan end mining in Butte?
6. What if the EPA/DHES predictions are faulty. Can remedial aclion be
undertaken Quickly enough to avert an environmental disaster?
7. What would be the effecl of an earthquake on the tailings pond and on
the Pit? Will the water treatment plant be so constructed so as to survive
a major earthquake?
-------
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-------
BERKELEY PIT QUESTIONS
1. Did the E.P.A., Montana Department of Health and Environmental
Sciences and the P.R.P's know beforehand that allowing the Berkeley
pit to fill up to the 5,410 elevation with toxic water - the
bedrock aquifer would also have to be written off? If so~ why
wasn't it explained much sooner to the people of Butte Silver Bow
and C.T.E.C?
2. What type of advertisement has the E.P.A., Montana Department
of Health and Environmental Sciences and the P.R.P's done so far
for the solicitation of innovated ideas for the Berkeley pit toxic
water issue - or was this solicitation process given to only a
select few for their .ideas?
3. What type of funding and inquiry mechanism for innovated ideas
will the E.P.A., Montana Department of Health and Environmental
Sciences and the P.R.P's put into place for the solicitation of
innovated ideas (if you can build a better mouse trap, I'll look at
it Russ Forba)?
4. If the answer to funding is yes, could a panel of experts as
well as people from the community, mining, timber, agricultural and
recreational industry sit on this panel for the adoption or the
declination of innovated ideas?
5. Finally, I can not believe at this point in time, that the
people of the United states, State of Montana, Butte Silver Bow and
the stock holders of the P.R.P's would allow such a catastrophe of
. a high degree and volume of toxic waste and water to be allowed in
! this area. This may be the point ~n time the community should seek
. national news coverage similar to the reporting on the oil spill in
Alaska some years ago. Believe me, this issue has for greater
effects to a natural resource than the oil spill did to Alaska.
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Albert Wolignoni
Rocker, liT 59701
February 11, 1994
1.
BERKELEY PIT WATER
Benefits for the Community from
Maintaining Water Levels at the Bottom 01 the ptt:
Very I..ge volumes of low-coat, dean, et1ntable water can be made
avajlable for the community of Butt..Silver Bow for both ita present
and futw'e needs.
2.
l..ge amounts of inexpen8ive elediicity can be utilized by the
community or 80Id at a profit to Montana Power ComPany.
- .. \
. \
Storm water run-off, a. well a. the aewage of the community. can
be proc:eaed into a d88n water Supply that meet. the Safe
Drinking Water Act requrement8.
3.
-t.
Yetals that now pose . health riat in our aquifer can be proceaaed
at a profit.
l..ge amounts of garbage can be processed, thereby reducing
demand on the current new landfill by aa much a. 8C)4I. :
!
5.
6.
It will apawn a system to provide a vast array of high-tecta. high-
paying jobs that will be .orely needed after EPA, MDHES and
ARCa leave the community.
The process can be utilized in other ..eas 01 the warid to benefit
mankind while practically eliminating the cover-up and InatiIudon8I
Control. that ..e some of the poaible '"remecies8 of present and
futw'e Superfund sites. . ,
7.
8.
It eliminates need for de9'edation of Big Hole River wat... .. ...
a. Silver Late water. that could instead be utilized for future .....
of the citizen. of the State of Montana.
Summary
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OFFICE OF THE GO\' I I~NOR
STATE OF MONTANA
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STATE CAPITOl.
Hfl I,~A, MONTANA 59620.0801
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:'~arch 3, 1994
Albert Molignon!
Rocker MT ~9701
,
Dear Mr. Molignoni:
i'hank for your information regarding the ~ituation at the Berkeley
Pit.
T agree that there are some exciting new technologies that can turn
il problem (degraded water in the pit) into a solution (not only
~Jean water, but min~ral extraction from the polluted water). In
r act, I have taken a tour of some of the facilities and been
~'riefed on the research involving the pit, and share your optimism
in the new and innovative solutions exp<1nded and applied on a
!i1rger scale.
The Department of Health and Environmental Sciences (DHES) has
state authority over this issue, ~nd I h~ve taken the liberty of
forwarding your information to them for their review and comment.
Thank you again for taking the time to send me your fact sheet. If
I can be of additional help in this or other issues, please don't
hesitate to contact me.
Sincerely,
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MARC RACICOT
Governor
cc: Bob Robinson, DHES
TEI.F.I'HONE: (406) 444.3111 FAX: 111;0;1 444-51129
"
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~IOLIGNONI NIANUFACTCRING, INC.
qOUTE 2. "cCKe" . 9uT1'£. MONTA"'A 59701
\1arch 15, 1994
"The Honaable Marc Racicot
Govemer of 'Montana
State Capitol
Helena, MT 59601
~e: Butte's Berte.!ey Pit
Dear Governer:
This replies to YOII letter of Mlrch 3. 1994 and ~ovides you with fU1her infcrmation
concerning the types of innovative techno/ages that might be employed at the Berkeley Pit in fieu
of !he EPA/State of Montana "Preferred Remedy" to allow the pit to fiU and remain fuU in perpetuity.
As an officer on the ~d of Drec1ers 01 CTEC (Butte's Citizen's Technical Envi'onmental
Committee funded by EPA g'2'1ts to help the community ey,;ress it's Superfund con~). lilce
you, I have been made 8Wa-e of a tremendous number of innovative ted'lnol~es that can be
r::Jnsidered fer reSOlJ'ce recovery (water and metals) at the pit. What has been missing until now is
fer anyone to come 1awa-d with a com~ehensive plan fer utiRzing the complex natlre of the
SerKeley Pit fa beneficial and jroctJctive ~ses.
. The attached document jresents the begnnings of what could be tenn~ a "holistic"
?D~oach to treating the interactive. multiple ills of the Beri:eIey Pit and mine floocing in Butte. This
means the legal mandate 9ven EPA to jrotect human heatth and the envi'onment need not be the
('nIl benefit to be derived from a' deanup plan. As in the unique alternative attached, the Remedy
c:)Uld be a seH-suppcrting Water Ptrification System that indudes aspects of eledrical generaticn,
referestation. water recyding, metals recovery, harnessing gc:rbage power - and at the same time
c-eate huncteds of screly needed jobs on a sustainable basis.
.I
The EPA/State of Montana. "Preferred Remedy" actually hcrms Butte's economy by fIoocing
off access of his1aic underg-ound re5Ol.rces. 191aing the reqJrement to .,.ectIce vaklme of
contamination." it does the opposite - doubling of the toxic pit wat.. and the amount of
contaminated bectodc aquifer eround the pit. The Remedy SC3'es the hell out of youngstn and
oldsters alike. Peopfe ima9ne a lot of terrible things that could befall them with a full pit - tom
houses sinking and basements floodng and well contamination to the possiblTrty thlt an eccnomic'
dep-ession 100 Ct' 1.000 yea-s from now could halt pumping and allow the pit to overflow. No ane
really Knows fer Stre what the con~ences of a full pit may be. That.s because the P'~
rem is based on ct' 'c theaies n f . It's as if the people of Butte ere ~ I.I11iI .
~ey jrove themselves innocent by coming up with techno/age data sufficient to tINI'f the State
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,!nd E?A tfflay from this ''remedf and the cisastrous economic and social consequences it ;8 are
:J c:~~se. We need reasons fer businesses and ~ofessionals to relocate here, not the wcrtd's
l~geS1 body 01 toxic li~jd to ciive the folks we have ~y. We don1 believe it is good policy to
pass Oll ~oblems on to 0lJ" ~ds and thers and thers. We need innovative thinking, not a
;::.emedy that fits the old adage of CJtting off one's nose to spite one's face. .
Why net go on recad as suppa1ing the rig.ts of the people to determine thei' own fate and
the fate of ther town? The EPAiState of Montana Remedy willlikefy put Butte rig,t out of business
a5 a livable community. Ideas sud'1 as the one attad'1ed deserve the lig,t of day.
I'm not the only affected resident who Icnows there's got to be a better way. We need pi
help to aSSl.l'e we don't loot only at the least expensive options and shcnchange OU' fuUe.
!~ea~ that i~c!ude social and economic isal~ must ~ !:!"C'J~t to Ii~t so !he Remedy doesn't
1~3ve fuhre generations with a perpetual unresolved a18is. .
-
Thank you fer yas sincere intereSt and C3'e fer the people of Butte-Silver Bow.
. YOU'Svery~,
4~UII~
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Molignoni Manufact\ling, Inc.
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Senatcr Max Baucus
Senater Cornd &rns
Rep. Pat Williams
Ms. Ca-of Brown.., EPA
M-. Bin YefJowtaiJ, EPA .
M-. Jade lynch, Butte-Silver Bow
Mo. John W8"deII, EPA
M-.' Bob Rot;Hnson, DHES
Mr. N~IM~,DHES. .
M-. Russ F crba. EPA
M'. Jim Scott, DHES
~. Fritz Daily "\ . . .
Members 01 Butte le9sfative DeltgItion ~"'. .
Butte-Silver Bow Council of Comil'uiann
Clark Fat Coafrtian
CrEC
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WATER PURIFICATION PROJECT
Qy
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TREES
Trees ~re one cf cb~ maln lngredients in the water purifica-
tion process. This natural phenomenon takes places allover the
.....orld's top soil. By looking at the area of Butte Silver Bow
County we can see vast tracts of land that can be utilized for a
large tree growing project. . The trees would add to the attractive-
ness of our area by covering up the baring soil left over from past
mining and smelting operations. The tree growing process has
several unique features when it is growing.
5.
1..
Supplies our planet oxygen.
2.
Takes moisture from the soil for the plants growth.
It also evaporates some of this moisture into the
atmosphere by the tree needles or leaves.
3.
The tree also helps purge 0l purify the soil by
absorbing the impurities llirough the tree root
system.
4.
The tree is a solar collector that absorbs solar
energy when the tree is growing. This solar energy
is converted into heat energy by burning the tree
after the tree is harvested. An interesting fact is
that every year many thousands of cords of wood are
burned in our forest from thj~ region in the form of
slash piles that are left over from logging opera-
tions.This is a waste of he~t energy that could be
utilized if burned efficiently.
The tree or wood from a tr~e has the ability to
absorb large amounts of water. For example, a piece
of wood 2" x 4" x 8' feet long may contain as much
as three gallons of water, or from 30 to 300 percen~
of moisture. This is a fact due to the cell
structure of wood like a Sponge. This same fact
also gives the wood the abil i ty to absorb impurities
in water.
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6.
The same wood product can be made into charcoal for
a water polishing agent to purify water to a higher
standard. (Example: a carbon filter). After the
carbon filters have served thp.ir usefulness and the
impurities in the water cannot be absorbed by the
f i 1 ters, they are removed [t-om the water system
operation and new ones installed to take their
place. The old filters, some of them, high metals,
are burned at very high temperature in ~ combustion
chamber where the metals are, melted and collected to
be sold. The residue left over from the combustion
process are mixed with other materials to make a
soil conditioner to help the trees grow. The hiqh
temperature gases from this burning process are used
~o heat impure water into a water vapor.
7.
The cost of tree planting and tree harvesting is
very low in man hours becauRP of the highly mecha-
nized machinery used in today:; planting and harvest
operation. This operation will create new employ-
ment in our area. Also, the type of tree used for
this operation can be of smaJ 1 diameter which will
shorten the time frame from tree planting to
harvest. The demand for this lree product will give
property owners, public or prjvate, an incentive to
grow this commodity to produce an income when the
trees are harvested.
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BERKELEY PIT
This enormous deep hole can be t.:: r.ed into one of the best
assets in our community. I will now :ry tQ describe in simple
terms its cycle of operation. The soon(r this project is put into
operation, the greater the benefits wi)] be for our community.
1.
Start a massive tree planting operation in our area
to supply the water purification plant with one of
the main ingredients for the water plant c"cle of
operation. After 25 years some of the trees can be
harvested on an annual basis to provide the water
~plant its energy and purific~tion material needed
for its operation cycle.
2.
Create a large water and ice storage reservoir above
the town of Walkerville. This high elevation
reservoir will supply our community with a cheap
abundant supply of clean high pressure water for
domestic and fire protection. Also some of this
water supply can be used for tree growing, 'agricul-
ture, mining, recreation, and industry.
., ,
Design and build a water pU1'i ficc?,tion plant that
will process fifty million gallons of water per day.
With over twenty billion gal I~ns j'urrently in the
Berkeley Pit, it will take c\!;()ut 2~) years to drain
the pit., The lowering of the I'i t water wi 11 improve
the water project.
4.
Take all of the water from thC' metro sewer plant as
,well as the storm water runoff that is now going
into Silver Bow creek. Instilll a water main from
this water supply over to and down the Berkeley Pit
wall to the present water elevation of the pit.
Because the pit water elevation at the present time
is much lower than the metro sewer plants water
outlet, the water will siphon into the pit. Put a
hydroelectric generator on a large barge, the reason
for thi~ is as the water table drops in the pit
additional water main can be ~dded thereby creating
a higher water pressure source to generate more
electric power to be used by the community or sold
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this water leaves the hydroelectric generator it is
captured in a large floating vessel and put through
the water purification plant. A note of interest
is the current cost of elect ricity to pump water
from the Big Hole River at Dj~ide, Montana into
Butte, Montana (about $150.(J(J per million gallons).
If we pump an average of eiq!"'. million gallons per
day, the cost is $1200. 00 pr~J :ay or $438,000.00 per
year. With the Berkeley pi t '.' "ter proj ect this cost
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WATER PURIFYING PLANT
A simple, very tall, highly insulated vessel like an immense
thermos bottle can be installed at an angle near the present water
elevation of the Berkeley Pit up to the highest point of the pit
~all. Wood chips or wood shavings are gravity fed by a hopper into
the vessel about one hundred feet from the bottom of the vessel.
~;ear this same pOint the contaminated ',':clter is inserted into the
'Jessel. Near the bottom of the vessel, hot clean gases from the
combustion process of dry wood chips und the air dried carbon
f i I ters that were removed from the \'.'.1 ter puri fying system are
.;.r.serted into this vessel. The combuslj un gases are kept below the
burning point of wood 0; about 250 degJ'ees Fahrenheit. Water is
preheater by the combustion process to J~cep the combustion gases at
~so deg:t. c~ Fahrenheit. This is the Sdme water that is inserted
into the 'l.essel. As the hot gases are nr iven up through the vessel
the high in moisture wood chips are s(.>parated from moisture by
evaporation. The hot gases and heated w~ter vapor will continue to
rise in the vessel to the top of the pi!. wall at its highest pOint
and i1t this point of discharge from: he vessel a condenser is
installed. This. condenser or heat exchanger has cold liquid
a1T1mon i a in it. The hot gases and vapnJ- heat the liquid ammonia
enclosed in pipes to a high pressure ~dS or vapor. This action
turns the hot gases to cold gases and hot water vapor to cold
~ater. The hot high pressure ammonia vapor is used to drive a
turbine or engine to generate electricity to pump the condensed
~ater to the high elevation reservoir, pump contaminated water into
the water purifying vessel and to run the air blowers of the water
plants system. At the very bottom of the vessel the hot dry wood
chips with the contaminate in them are taken to the combustion
chamber. .
Some of the water from the high elevation reservoir can be
brought by pipeline to and down a mine shaft close to the water
elevdtion in the mine shaft. A water turbine can be installed to
generate electricity because of the high pressure water from the
reservoir. If this water has oxygen put into it to produce acid
that will solubilize the metals in the ore body of our area. After
many years of this water mining the contamination of metals to our
ground water should be eliminated. If this water that is high in
metals goes into the Berkeley Pit it can be ~rocessed in the water
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THE USE OF SOLAR AND WYND ENERGY
1.
Trees can be planted around thC' 11erkeley Pi t walls at
each bench level. The trees wi It absorb solar energy
and moisture from the soils. ~fter many years of
growing, the trees can be harv~sted on an annual
basis in this area. This factor will reduce the
transportation cost from tree farm to water purify
ing plant. .
2.
Solar collectors and solar cells can also be used for
a heat enhancer and to generatp more electricity.
The glass products needed to make solar collectors
can be taken from the garbage waste that now gr.es to
the landfill. Thls glass product can be manufa~~ured
locally creating more jobs for this area. A note of
interest, large amounts of copper are used to make
solar collectors and arsenic is used in solar cell
construction.
3.
:
Because our area of this community is surrounded by
tall mountains, wind turbines can be installed on the
tops of these regions that can be used as an electri-
cal supply for the melting of glass and metals used
in the solar collector and solar cell manufacturing
process.
4.
i
:1any other combustible product[.; ~'an be taken from our
garbage waste stream such as piiper, tires and used
motor oil. Also, the many pla~;Lic products can be
'used for insulation products aml material products
for solar collectors construct! (In.
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EFFICIENCY CYCLE WINTEH AND SUMMER
By changing the flow path of the ;\rnmonia liquid and vapor this
~ater purifying plant will have an efficiency rating of over eighty
percent. The wood product will cost about fifty cents per one
hundred thousand B.T.U. This efficiency rating will give us 10,000
gallons of clean water at the high elevation reservoir for $ .50.
The people of the present water system pay close to $2.00 per
thousand gallons of water.
SUMMARY
t.-
,
,
The Sooner the E. P. A., MDHES, "J-co and the communi ties of
Anaconda and Butte Silver Bow accept lhe project design and ideas
I have described in this text the sor,ner the region can have the
vast array of high-tech, high paying job~ that are now need~d in
our area.
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POWERSHAFT
L I M lIED
?:-oposa J t.,:
Albert J.
MO.i i gnoni
I. Creation of Water Storage Systems
Creation 01 High Efficiency Electric Generation..
-
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I.
Creation of Water Storage Systems
.:"troduc! Ion
"'vhile living and traveling in the state of t.1o;'"';tana, I have witnessed
:,:-~e eXDIOltatlOn of the state's mlneral and fcssil fuel resources. From
')-:8se observations, I have concluded thaL to.e inevitable depletion of
lhese natural resources will result in a ccns:derable reduction in the
state's wealth. The following proposal has been educed as an
(il~ernative source of monetary and energy needs for the state of
~,1Jntana. Development of this concept was derived only after
extensive research on wind energy, solar energy, and
. : 1-,ermodynatnics.
-:-1 le project I propose is the creation of a waler storage system. This
<~yslem will utilize Montana's land, water, wInd, cold and heat, to
~ li:,imately provide a renewable energy sou~ ceo ILs success can be
.;chteved wlLh the combined efforts of the ff;.':eral. state, and local
:;cJ':ernm~nls Farmlng, ranching, timber, nl1.ning and recreational
(~:'8UpS will also be required to participate l!l r.he development of this
:-'r'0ject.
I. .?nd
'ihe stale of Montana has a very unusual land situation. Many of its
c::reas are mountainous terrain; therefore. t~ere are land sites in the
. state that are not suitable for agricultural production or recreational
purpose. Areas of non productive soils, such as those left over from
mHling, commonly take up one hundred acres or more in this state.
Tlmber areas and other smaller sites can also be ulilized for the
creation of this project.
11/ater
'Nater is a nalural resource that this state has a great abundance of in
certain times and very little of during a drought period. The
controlling of this resource in the past has been with the use of dams
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;'.reams, where water freezes from the top downward. When the.
':/ater 1S frozen from the bottom up, the ice structure created is one of
: he most stable forms for the storage of the wate;- The benefits of
;':.::nng water 1n th1s Lime frame and mann~!" are
~ "~:.''''C)r 11c:-ed tf'l CrC)?to .1-,0 ;'-0 c:-tor-:loe Un~"~ 'n tl-,e winter months
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<; ':.;e s'~~plied :y lakes, rivers, streams cr' ',yells In this time frame
. ; ,e demand for the states water is at its 10ft/est le'/e1.
2 If the water used to create the ice storage units is supplied by a
~:r;derground pipe line, or a self draining pipe line and stored at high
8:evations, it will create a water line with high head pressure when
the ice melts i!1 the spring and summer months. This energy source
:.:~~n be used for hydroelectric and high pressure sprinkler systems.
:3 By us:ng a geothermic water supply, the thermodynamic principle,
;}~d cold air temperatures, an energy source is created to supply the
~~;!lplng of water in this time frame. Solar can also be used as a heal
:;ource. .
.:~ These iarge stable ice units can be used in the winter months with
.~ 'cw cover for such winter time activities as skiing and snowmobiling.
.~ Storing water in this manner will provlor; a gradual water
'.:' .::i:arge dunng the spring and summer ~'~(:nths for the support of
~.~:;~-::ul~c:-al, limber, mining, recreation, in(:'.jstri~l and domestic
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The last natural'resource that is needed to complete the project
design is heat. The heat energy source will accrue during the spring
and summer months. This wiil provide the means of melling the tce
storage systems. Therefore, an ample water supply will be created for
the growth of our state. The heat from the sun in the spring and
summer months, coupled with the cold water from the ice storage
U~1tS, benefits in creating a energy source by the use of the
Lhermodynamics princip!e. It will a1so be noted t~at if a high
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,
.:...:'e ~:pltallon penod occurs during the ':J1r~~er and spnng months, the
.:xcess waLer WIll be Induced into the state's aquIfer for storage, The
','!~t3r car.. then be u.sed at a later date wr.en needed; such as in the fall
,:u:-::1g the non -productive months of ~he Lce storage systems.
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:jpsn read!r..g the prevIous text on the general (:escription of the
;:.rc;ects des~gn, it can be understood by t.he aVf:rage lay person that
~!ll~ process is already taking place in OL:r ste.te '.lith the four seasons
cf spring, summer. fall and winter, With the added technology of the
state's university system and people with the expertise on the project
design and development, the project goal is obtainable. The spin o~f of
high -tech as well as other jobs associated with the project design and
construction are too numerous to mention The additional benefits of
',he project are:
: An i licrease tax base for the state due to th() taxable val uat ion of
~ he pro] ec ts components and addi t i ona] ::Ol! uri~ier cuI ti vation by the
,',';-: t '2 r
? I~n industry created to design and prcduce t..1e components of this
;-,',:ro;ect desIgn to other areas that have the ~ame or similar
:_;::2;;raph1cal1ocation and climatic conditio~
3 The abundant supply of jobs to maintaIn the system as well as
other jobs associated wIth the increase of water and energy supply,
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I I .
Creation of High Efficiency Electric Generation
":7trodvction
The pnme sources of electrical generation in Montana are
hydroelectric and steam. Wind generation has also been used in small
cuanttties to produce electricity.
~~,;.droelectnc production is solely reliant on mother nature to
produce enough rnoisture from the snow and rainfall to fill the
~-2ser'loirs with water for generation. In additio!1 to providing a clean
:;u ppl y of electrical energy, hydroelectric darns rnanage the water
:;:upply to the-consumers in the state.
:;i.eam generation is produced by the burning of our state's coal
'.:~jpply. The effiCiency of this type of electrical generation is around
;_~1trty percent This means that seventy percent of the coal's heat
energy 1S wasted. Coal is not the only type df fossil fuel that is used
Inefflctentty in Montana. Gasoline and diesel fuels in today's internal
combustion engines, such as automobiles, trucks. tractors and trains
\:8IY seldom reach a efficiency of forty percent.
~':~ontana's exlreme temperature variations, seen throughout an
annual period, is another source of clean energy. Water, cold weather
1:1 the below freezing months, and hot weather in the late spring and
Slimrfler months, are the basic resources needeci lo create massive
amounts of energy inexpensively. For the past several years, I have
desIgned and patented a unique high efficiency engine and heat
exchanging system. This system design, with the usage of ammonia or
freon, produces a efficiency of eighty percent. Adoption of this type of
energy system, in conjunction with the ice storage units, would
produce extensive amounts of water and energy cheaply. The
f allowing text will give examples of how this type of system can be
used 1n our state.
r::,t les and Towns
Present sewer and garbage disposal systerns are abundant supplies .of
energy needed to make the system successful. The heat energy
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:.eeded for the system WOUld be derived from w~rm wasle waler in
cr;mmunit y sewer disposal systems, and the higher temperatUre heat
(curce that can be supplied by ether incineratir.g garbage or the..
: 'ur::1!lg of methane gas produced by our sewer plants. Cold air 1s the
,.. ':.riensing agent needed to complete the energy cycle of operation
.:' !i:;-.g the cold weather months. Process8d water from the sewer
: ':::int d\;rir.g the cold weather operation vnll be Ilsed in the ice storage
. ",:stem. ThIs cold water supply is used as a condensing agent during
: :':e het ."leather cycIe of operation. Local governments could realize
;.'::d:~;onal income by sel!ingthe vast amounts of electricity and water
;.:'QGuced by the system. .
-
7irnber Indvst ry
~'he wasted wood products that are not used in our state's forests is
unbel1evable. The simple economic reason is the wasted wood.
~~ioducts that are created from logging, timber thinning, and trees
~~aL insects destroy are not in demand. Present use of waste wood is
L y home owners to help heat their dwellings. The high cost of home
~ ,eal1ng created the demand for this type of wood burning.
~
-------
,.~iought. ~:1sects. low pnces and high taxes Lo make their business
ft . .
'~~pro.1 a8~e
A mobIle U!1lt can be used for this type of energy production, The unIt
..,;.;.!l 'ce moved from one locatlOl1. to another for the ice and energy
:",~'cductlc~, AlSO, If there IS a rriajor malfunction WILh the energy unlt,
~ J;[:eren~ ~r1.lt can be brought it) to produce the energy while the
,~~':g:r:al u:",.:~ is being re9aired. The automa~.ed llnit would require
'v'F.~ry lLLUe tIme and efforL from the operator, thereby releasing the
;;erson for oLher duties that are required [or the farming and
: '~,nching operatIon. AddItional cash flow korn the sale of electricity
:- ~cm the unit would insure the usage of thIs system during high
penods of precipitation to increase the water table of the state's
:1qulfer.
/ltlllty - PubliC-and Private
The vast l.:ntouched natural resource of Montana's heat and cold is
:~~rr.ost impossible to described, We have fe-lied in the past to utilize
~~is abundant source of energy. Public and private utilities of this
s~ate, with the system design, would be able to produce large blocks of
81ecLricai energy that can be sold to other states, thereby increasing
lhe cash fiow into our state. If exportation of electrical energy is
i.axed, the added income would benefit thIs state. The sale of this
8nergy at a reduced rate within the state would entice industry, that
!.:onsume la:-ge amounts of electrical energy, into this state.
! .~:','n/~?9 Ind.:./stry
:.1:rung concerns have one of the best potentialS for the'system design
::::1ergy generation and ice storage will create an abundant supply of
!r:.expenslve electricity and water for mining. The increase of demand
j'Qr llme and phosphate for fertilizer by the agricultural industry
."'ould reopen old mines and create new ones. Copper and aluminum
:ndustries are also great benefactors, because of the large amounts of
copper and aluminum metals in the energy system's parts.
-------
~ec~eational.lndustry
;;-:0 added water supply would insure a In(rea~r; In the recreational
:! JC'.Jstry In Montana. A sufficient water ~1.Jpply wOUld increase the
':' GG products for the big game a~d fish;r;:~, ::ic~~,tr1es. Additional
.~~t.::!Llt1es of ".yater wOuld also benefit such indu~;tries as boating,
skiing, and other related activities heavily reIiaiit on an adequate
'..'a\.ef supply. The potent!al of the state's ice st(;rage units is 20
.r~jllion or more in acre f6~t of .water.
Su/'"nmary
Upon the stales adoption of this type of ice storage and high efficiency
energy system, a meeting should be set Lip with a group of
professIonal people with the expertise on this subject matter. The
~eeting would have to be held in strict confidence because of many
;deas I have on the subject matter that may be patentable. .
Compensation is also a factor that has to be dealt with due to lhe:
~~a1'1Y years of time, effort, and expense that were necessary to create
:.:-,is system.
-------
"
5Jr. Levi.latur.
BJR 0020/02
I
2
IDIS& JOI... 818OLUrI0ll m. 20
IIftROOUCm n am., ...n, GILBD7,
fnlAIISOM, P8LA8m, In'OYALL, '8CllW11mDl,
J
4
WAGNa, 8110, """, ...
B' RIJQU8ST or TII& IUJIB 1IA'I'U8AL 818OU1tC~ CQIIIII'lTU
5
,
7
8
a .101... RI8OLUrIOll or '1'88 IIIIATa aim T118
or
1IOU18
REPltUDlrA'I'IVa Of' TIlE nATa Of' ~AIIA I'I'IIOIIOLI IJ8GING 'l'R8
UNI'I'm S'!'A'I'U DlVIIIOIMDlrAL nor~IOII AGEIICI AIIO '!'BE UNI'I'm
,
10
STATU CONGRESS '10 GIVE RICHES'!' PRIORln '10 CLEAllUP or TIlE
11
U
AND to nor~IOII or ALLUVIAL AQUIFERS
aa.BLEW
'1'1'
. .
u.aLIING TIlE IILVER - CllUI( IU.DPUIID SI'I'£.
U
It
IIBDIAI, the "rk.I., .It, locat.d at the h.adwat.r.
of
15
II
the Coluabla RI..r,
I.
Included In the nation'. lar,..t
SUv.r
which, Includ..
the
IIov Cr..k
luperfund C08pI..,
17
18
Ilt./8Utt. AddIUon lit.," and
I.;,..t 81ae floo4lnt. and
..DEAS, 81nlnt actl"lt, for
rear.
he.
18
,It
I. the .It. or the .orld'.
IU
tile pe.t
I'
20
r..ulted
In .0U and .at.r cont_lnet1on and ,chent.. In the
21
2J
.a, ,round .at.r and sudace .at.r fl- In and
and
n.a..
Butt.,
2J
24
lIBaEAS, 81nln, coapenl.. Installed an .Iaborat. puapln,
the act hr.
.lnlft9 period to
and bulllhea.
.,.t- durlft9
2S
d..at.r the under,round .In.. and the 88rk.I., 'It, and
1&..--
IIJR ono/OJ
I
2
IIBDIAS, ""en acU.. 81nl"9 .nded, the PUI8p8 -... tu..ned
I,
off on apI' U
and
2J.
1'82.
lhe
unde"9..ound
.lne..
and
J
4
subaequentl" the
"rkele,
Pit. betan to flood. vlth vate..
rl.ln, 2,'18 r.et In the .lnes and to a depth or 114 re.t In
the pit, and
5
,
tnlEREAS. ACCORDING '1'0 TI'. JIONTANA DEP~!:IfT 0..
BEAI.TlI
7 '
.
AND
DIY IIIOI8(DI'I'AL SC I DICES.
the
&e..lleley
Pit
cu..renlly
contains approal..t.ly 20 billion 9allons of wate.. and fill.
,
avera,.
rate or ~ .llllon to 1.~ .11110n 9allon. a
at
an
10
da,. and
"'DIAS,
area
11
81n.
floo41n9
In
Ie
the
Butte
of
U
U
sl,niflcant
concern
beeause the vater 1. hl~,hly acidic and
contains hl,h concentrations of . Iron.
..nf;la..e8e.
a...enlc.
14
15
lead,
copper, , .Inc, and sui rate. that rar eaceed
ca.lu.,
atat. and rederal atandards, condition. that p..evented vale..
11
17
In the pit rroa fr...ln9
even' when
le8peralure.
rell
to
81nua 40 d89ree. rahrenhelt In 1989; and
IIBaEAS, vater In the we.t Caap of the Bulte .lnln9 area
did dlscher,e
Into
the Silver 80v Creell alluvl.. and Int~
20
21
ba....nt. In the central Butt. area when the Nest
..aled ofr vlth bulkheada In 19~9; and
Caap va.
:u
2)
"'DEAS,
ACCOJIDINC
'1'0 'l'ME MONTANA DEPARTMENT 0.. HEAL TII
AND ENYllIOI8(ENTAL SCIENCES, vater In the &e..lleley
Pit
r08e
24
2S
JO.5 f..t In 1"', J3.2 reet In 1"0, 32.8 reet In 19'1. and
lli.!
reet
In 1992 and the .ater In the pit Is vlthln
Uy'
-2-
HJA 20
-------
838 0020/02
1
.2
1" f..t of contactl.. the allu.la. on the .a.t .all of
pi t, a'"
the
1"
.
lIIIaus.
-.., clth.... of "U. beU- thet the Unit..
I~at.. EII.I~0ft88.tal P~otectlon Ag.ncy he. Ilno~"
p~.U.I..r, cJocu88ntaUon 18I!UC8t181 thet the .unoundl..
5
,
8qUlf.r. -, be cont..l..ted
1. the ..ar f.tur.. but the
7
1
, "'''CY In.t." he. nevotlat.. a. "'1"I.tratl.. or"~
on
con.ent
thet ..t. w.t.r 1".1, tacget. ..11 abowe pr.~lou.l,
,
10
..tabll.bed 1...1., and
...aus. d..plt. u.... ala~.lftIJ ....l0p88.t..
r..ld.nt.
11
12
of ..u. and ~he 8U..r
low Creek dral88'. he.. been
f~u.trated b, the lack of
pr09r... It,
the Uolted Itat..
U
It
"'.1r~otal
Protection
A8J8tIcJ
1. d_lopl.. a pia. thet
.111 8d8qU8t.l, tr.at the COftt_l..ted w.t.r and protect tb.
...1r-t and cIU.- of the ar.a fr- the pot.otlal
15
16
tllr.at to the all...1al 8IpJU.r _non..l.. "U., alld
--Dl. t... IIo8t... D8p8ct8ant of ...1th .and
. ...1r-nt.l lei.... 1. a180 1--1... I.'. t... clea..p of
the 18rk.l., pit ... h88 1. t... put. reported to the
1In1r_tal o..llt, Co88c:U 08 tb8 prOlr... of thet
17
II
l'
21
21
22
cl.a...-
21
2.
-. ,......... .. I~ ....... n .,.. I_ft.. ft8 8OUI8
or """....A71Y11 or ft8 ftAft or ~I
25
7h8t .the O8lted atat.. ".lr~8t.l protection
(I)
-J-
8Ja 20
....
BJR 0020/02
I
2
Ag.ncy and the United State. Cong~... be .t~ongl,
urged
to
,I.. t... .Il..r
low Cr..k.. Butt. Ar.a Supe~fu'" 81t. the
. J
.
hl,he.t p~lo~ltr' for cl.anup .nd
pr._nt
action
to
dl...trou. en.lronaental "",e and huaan h.alth p~obl....
5
,
12)
ftat
t... United State.
EIIvl~onaent.l .~otectlo.
Agency and pot.ntlall, r..pon.lble
partie. proceed with
7
he.t. to develop and I..l...nt plan. and deal9n c~lte~la for
. facillt, to treat cont..l..ted vate~ before It reach.. the
8
,
10
allu.lal aqulf.~. .ur~OUndln9 the Berte Ie, Pit.
U)
of
Hea1th and
'fh8t
the
teontana
Depart_nt
11
12
....Ir_ntal
Scl.nce. _t.
perIodic
report.
to
the
EIIvl~o....ntal auallt, Council on the p~09re.. of the cl.anup
U
It
of
the 88rk.l., Pit and the p~ot.ctlon of alluvial aqulf.~.
und.~l,l.. the .Il..~ low Creet lupe~fund Sit..
IS
16
ftat copl.. of ,till. re80luUon be .ent
the
C.)
~
Iec~.ta~, of, Itat. to.the,Pr..ld.nt of the U.lt" 8tat...
17
11
t... "'1.I.t~.tor of
t... Unit...
Itat..
Bnvlro_ntal
P~otectlon A98DcJ. the Dl~ectoc of .th..teonta.. EIIvl~o_ntal
11
20
. Protection Agency ,OfUce., th.: Oov.~no~
of
the 8tat. of
IlData... alld the teonta.. CoftCJr...lo,..1 Dele,aUon~
-End-
-4-
-------
Fax Transmittal Memo
To:~.
Co.:
. of h~
L
From: ~h." ~'-'"
" c._-
Phone'
Co.:
Il'd U91.I.tare
ILIR 8011/U
Dept.:
Fall...,~ 3 - b f)
H.lft 0011/0.
IJOUS8 .IOIIft 8CS01.UrIC81 80. 11
.NTROIlUCID n DAILW. LYIICII. QUILICI. "'.a. PJ.INICB.
IlAllAIIIG'I'OII. PAVLOVICH. lIMP. 1ICICI8IIUI. .J1CANIIiIOII. D. .0lOI.
VAIl VAU~. IICCUftn. woca.. "".IISftIa. 'IOOL8. GAO:8.
oalSCOLl.. GIUDrr. 88C11. ftIGG. -a'M. UUI8ON.
"
C..""£N. ""'IGOOO. DmlEIITW. I!I8DW. .RIII8DW. I'ASII. _11'8
II
a .101ft .a:!iotOl'JON or ftI8 ....n AND ft8
or
80088
oj
AEPAI:UlftATI."S or ft8 aan - ......... .8COGII"1~ AIIO
URGI~ CDft'JIIQ8D s...~ ftMI .... ...,I08U. ""'I~
HAft8 TIICIIIKJI.OGW nanlllG nAUla'rI- ~ I. 8Uft8.
o
z
..au..
tile
..Uand
""h~t.l -t. 'hcbaolon
IIIDfII~t -- --"U8he4I I.
T..tla9 a.aluatloa
C.at..
~
BuUe, IIoItta... to .....U..t.. ...1... .... 4Ie808at~.t.
.:oet-.fl.cU- t~..t8e8t t.a.oJogln f~ 81.1... ._~ft.
def..H-Ir.I.t... ... ..... .""-lltel _tn. .1Id
.. "'-'--tbLJID1t~t.- ..~- ... .""'waJ. ""tr"1I lea
~
,
II
.,
ar. ,r"ldl.. lDOr"'" 11..-1.1 ... teclllll_l a-.port IOIr
IU!Ift"I'8C 18 or"~ to ...t t.. odtlCl81 "U_l .... to
de"elop a'" teet ..."h08888t81 ...t. Ir~Jat:108 t8cll_I09~'
~
and
22
2:1
.._us. 18ft&: 1tIr"1". IlIar_eeI 800lI0810 --fit. to
Hont... ""'-e..1TU188e11t8~ftl. tv .. .Itl..... ..~-1I...
I.
25
~r14 that a... .clYel'~.I, affect...~ ~aate
and pollutiOll'
Fal'
I.
RCFX14
1
2
aad
NBEaaaS. f8Nr7BC IDteada to pl'09ld. faelJltle. n.cea..I'~
~
.
fat'
..vlrOll8e.tallw
--.a
techDOIOCJl'
de..el0p8e.t
I"
aCOOl'daace with A11 applicable
..d
en., 1 rOlDent.1
I'equlr_nt.;
S
6
""auS. 8111fft'BC. PIrOl8Ot- t8CbltOlogJ teanafee to tb~
pl'l..t. aDd publlo .ec~lr. aDd eacaurag.a the p.rtlolpatlon
of l""tcW. gowel'R88Dt -..acl... tbe acle.tlfle C088Unlty.
ana the public I. actl"ltl.. at tbe Center, .n4
'J
.
. ~
I.
.......... InIIfnBC "111 ....108 -4 e.,al-i. teclloologle8
to .1.1.1.. t.. vol-'- aad to.lelt~ of eavll'on...tAlly
""glag --t. c.u_U. _log pr~1IC8d bl' ladu.hy, .nd
.......... t_lra I. 8 ccltlcal De.. for..... 8av ho....nta I
~e8edlaUaa t.cIu8olawy, 8Dd
"'-.S. II8Irr8C ..... 81101... of .elentlflc pe".OIIDItI
.u
1.2
IJ
14
IS
11
dlr_- (lroe ""~--t 84Jeocla. pd.,ato ladu.t~~.
I..UteUoae .pI hlgbec .-cation I. Moata..., and
-...... .... -hctbec..-....a.o"'.~&-lIZ'Ift'I'l8-callt-
caetlrl...t. .lgalflC88tl~ to e8.Sco"'.Lal cleanup aDd
and
J.1
11
.,
2.
21
.C'08Gelo dew810p8-t
J. the 1'..10.. ..peelally with re9al4
to "'.Iopl..
tocknolawy-be8ed
Inclu.tr 1.. aad
.s.oclated
oppo~tDGltle.r 8ad
.......
tbe St.te of Moata~ wl.~e. to be an laportaat
~..ttclpa.t-i.-tlArdewlIOJlllent-CC-.n. ("co..-Dl-.rtechno 1O"q (..-
eontributl8Q ~ a cleaner
n.. I t ~..
-------
/
RJ. IOU In
glOba. e~.lronnent.
MOlt .
~DORE.
Ba I~ ItIaIOI.VZD 8W ft8 B£NAft .IID T08 IIOUS8
OP ""ItSEIfPA,..VES OF 'I'ID S'I'Aft or -.........
(I)
'l'h8t the Leglalat.re ae*.ow 1 e49. and .apPort
the
creaUOII end d8veJOp8ellt of tile llatlonal: .... hDl88nt a 1 Ma.te
"ecbnology 'l'estl., alld .al..tloa c..te.. 10 "tte, IIollta..,
and recognla. '.e l-.ol'tance of CODtla~
f...t~1' de".~t.
..lIPOrt
fol'
h.
Ut
That
t"e
I89ta.ature .Ul'ge
t.. UIIlted
State."
CoftcJr:e.. a.d appl'opr:late fe41er.. ",IICI.. to
008UII88
rull
fundi.. lor
t.. 9rowt. ... develGp88l1t of .Dfn'IDC at the
Qolted atat.. ~rt...t of "'1'9' ~ ..alle.t ""'........t anc1l
Jot89ratloo racJUtr III "tte, IIo8t....
U)
2laat capl.. 01
tal.
..8801.tI00 be ee.t
bJ
t...
Sea.ta~ 0'
State to -1""-' of Uae -- CoagI'U.IC1G8.
DeJegaUOlt,
to
t.. "'Int.tr:atac
of
t- 081ted
.tate.
"'''h~b. ~otecUOll "'acr. .... to the llecl'eta..... of
... - ---.---...------- ----.-----:----...------------
the a.1 t..
Stat.. Depar:t8eat. of ""I'U, Def....., a.. tlto
10tol'.1 01'.
-DId-
."'.--.-. .""---- - . ---------.--.-.
----. -----. ---------...-
"----
,.
--------.--
"-_.. --. ..-
-.. -. . .
~.
-------
-
WRITTEN COMMENTS
APPENDIX 4, ATTACHMENT 3
BUTIE MINE FLOODING OPERABLE UNIT
RECORD OF DECISION
, !
-------
.~" -. .
~ 'd
3'): '~\! :-S/L 1 <;0
::.:10 I:tNt:HIJI)W ':'d3 ;,.jOH~
Gl
CTEC
Citizens' Technical Environmental CoDJ.JDittee
P.O. Box 593
Butte, Montana 59703
\tay 13. 1994
\Ir. Ru~~ Fo, ~:l, ProJcct \t:mager
r.s. En\'irnn.!nental Protection Agency
301 S. PJ:"~
Helena, ~tT 5'>626
ENVIRONMENT"\'
PROTECTION AGENCY
He: Berteley Pit and \tine Flooding. OIl"
MAY 1 6 1994
MONTANA OFFICE
"car Ru~~:
Hecau~tt CTEC \\'a~ unable to develop a po~ition 00 the BP&~tFOL' hy end of
the comment period April 29. I ~po~e to Pam Hillary on \tay Z and she
in<.1icated that a consen~m ~ti1tement from CTEC ~;ould $till he de$ired hy E.P.A.
I a~\(ed if it could ~'ait until our regular ~lay 12 memher~hip meeting and Pam
indicated that ~'ould ~'ork. ,\~ it turned out. the regular meeting ~'a!!
$uh!!tibutel.1 'J.' 'h a Boarl1 meeting. Five of ~ix Board member~ "agreed~ ~'ith
the ~1)r.5~mll~ ~tatement. The ~ixth ctlo~t!'ln\)l tc) re~ponJ tn the que~Hon a~
\\"nrded." :\one "di~agreed," Following i5 the approve\,1 5\C1tt!ment \vhich u.ill be
reflected in the ~ti(jute~ of the Board meeting of ~lay 12. 1994:
It i~ my opmion that the Berkeley Pit and \lme Flooding remedy ~hould be
properly dirt'cted toward immediate treatmeni of the aer~eley Pit it$elf I.a~
~eparate from Hor!te~hoe Bend treatment \\'hich ~'ould ~tart soon I, I believe it
,~ in the he~t intere~t~ 1)[ the affected citizen~ and future re~ident$ of Butte-
Silver 60\\" County for contaminated \\"ater in the Ber~eley Pit iuelf to he
I'urnped and treated a~ ~oon as po~sihle, utilizing technology that does not
('r0l.1uce rna~~i\'e am()unt~ of 'W"aste $llIdge~. and ma~ing clean ~;ater a\"ai\ab\e
10 the '"ery near future for permanent. oeneficial u~e~, therehy deere"asing the
volume of toxic material~ in the pit.
" Today 'J.:e are mailing the state.ment to all our memhers for th~ir
-------
:: . 0
<..0::)i ",6'LI/;0
:;:10 tfN\:HtIOW tjd 3 I~i)d,:j
.-
you a!' ~()()n a~ 11 hCC:llme~ il\'ailahlc
Th:ln~ :,IIU for your I.;ind !.:()n~ld~!"a!lnn of thl5 51,!\t'ml'r1,t a~ ruhlic
comm~nl (()n5~mLI~ from [\l1tt~~ CitI7.en~' T~chnlcal En \'I rnn mental Committee.
Yl)ur~ \.ery truly.
~ ~ &:.0'
~'1ary ~ay Craig
Vice Pre~ident. CTEC
cc: Pam Hillary. V.$.EPA
Tom Malloy. Pre~ident. CTEC
Brian Tierney, Secretary. CTEC
BiH ~IJcGreg()r, Coordinator, CTEC
-------
Gl
CTEC
Citizens' Technical Environmental Committee
P.O. Box 593
Butte, Montana 59703
(406) 496-4433
April 29. 1994
Russ Farha, RPM
L.SEPA
30 I South Park
Helena, Montana 59626
SCBJECT: .: RESPONSES TO MINE FLOODING OPERABLE UNIT PROIPOSED PLAN,
RECORDED FROM CTEC MEETING
At CTEC's April 21 meeting. the following questions & comments from those in attendance were
taken, for submission to EPA regarding its Proposed Plan for the Mine Flooding Operable Unit. We
.submit them for consideration as part of the public record.
c
Long term viability of the plan was questioned by Mel Rowling in terms of vast unknowns at
the boundary of this operable unit with the Outer Camp (Non-priority soils operable unit), His
detailed questions were submitted in writing.
c
Albert Molignoni submitted written comments and questions. the key element to which was a
request that the final remedy should be flexible enough to incorporate innovative remedies as
they are discovered, and that the final remedy should NOT be locked into EPA's preferred
treatment ( hydroxide precipitation).
c
Several other questions were asked about the value of public participation:
c
one participant wondered if the "deal" hadn't already been signed between the
involved parties (the reference was to the Consent Decree about the critical water
level); the questioner felt that public input wac; !'f)intless
Q
another questioner expressed concern that public input that did not demonstrate
technical expertise was not heeded as highly as was input from scientists, engineers,
aDd other. more tecbnically expert parties; the concern was that the average member of
the public was destined to be kept out of the decision-making process
c
a skeptical questioner wondered how public input figured into the decision-making
process: "how much does it count for? how many points does it get?"
c
Several questions were asked about the 5410' critical water level:
c
c
how was it determined?
by what definition is it "Protective" as a final remedy?
if groundwater modeling specialists are skeptical about any predictions more than five
-------
c::::c
Page 2
April 29, 1994
or ten yem into the future. why isn't a greater safety factor built into the calculation
of the final remedy?
c
A number of people expressed their unhappiness with the plan's downgrading of the
Superfund "balancing criterion" which requires the remedy to "reduce toxicity, mobility. and
volume" of contaminants. Defenses of this strategy based on long-term vs. short-term
protectiveness failed to appease these participants.
c
If flooding of the Pit as fast as possible is a good idea (which was suggested by the State),
why not use all available resources and fill it right away? -.Silver Bow Creek Water. diverted
Big Hole Water, etc.?
c
A number of questions I concerns were raised about the sludges that would be generated
through application of the preferred treaanent alternative:
c
if they are disposed in the Pit. wouldn't they generate more oxygen. thus perpetuating
the acid-generating oxidation cycle?
will disposal of sludge intO the Pit result in increased concentrations of contaminants?
any remedy that seems to make the problem worse by generating sludges that will
have to be dealt with by future generations as another Superfund-type problem does
not seem like much of a remedy .
CI
CI
CI
One participant expressed concern that rivalrheories about long-term Pit chemistry should not
be taken for more than what they are: theories. and that as a consequence. the plan should
:naintain as much flexibility as possible in allowing new technologies to be applied when they
become available.
CI
Several speakers expressed amazement. disappoinanent. and concern that more aggressive
measures to restrict flow into the Pit are not figured into the proposed plan. They consider the
control of Horseshoe Bend water to be the absolute minimum. but they preferred to see
measures taken that would intercept all waters in the system before they reach the
contaminated zones, thus (at least potentially) removing altogether the need to treat the water.
CI
A number of speakers saw no scientific or technical basis to challenge the plan. and lacking
such basis. they saw no reason not to allow it to go forward. .
CI
Considcnble alarm was expressed by several speakers about the plan's treatment of the deep
bedroct aquifea-:
CI
the plan gives no assurances about the dynamics of comaminatedwater over the long
tenn in the deep bedrock aquifer. we just don't know enough about it
CI
what we 00 know about old mining works in the bedrock aquifer concerns some
people with underground mining c:
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CTEC
Page 3
April 29, 1994
c
One speaker expressed hope that this exhaustive process. with all its fits. starts. and mistakes.
would help make the subsequent phases of the decision-making process at these sites more
efficient and effective.
:J
In relation to the eariier-discussed bedrock aquifer issues. the final speaker expressed hope !hat
the plan would conceive of. and implement throughout the entire basin. a Headwater Alert
System. which would monitor. water flows in and around alllcnown zones of contamination. so
that unexpected escapes of contaminants could be detected and responded to before they
become disastrous.
Please enter these comments and questions into the record. and respond to them as part of your
process of working toward your Record of Decision at the Mine flooding Operable Unit
Sincerely. .
.:-:::( ., / t7 I /
,C::;JU.v I)'" if) ")
Dr. Bill Macgregor
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CTEC
Citizens' Tethnical Environmental COmmittee
P.O. Box 593
Butte, ~ontana 59703
February 24, 1994
Russ Forba, Project Coordinator
U.S. EPA/Montana Office
Federal Building
301 South Park, Drawer 10096
Helena, MT 59626
Dear Russ,
The purpose of this communication is to request more time for public comment on the
recently released Draft Remedial Investigation Report and Feasibility Study for the Butte
Mine Flooding Operable Unit. These documents, the result of several years of work on
the part of the agencies and the PRPs, contain a great deal of information which the
public is being asked to digest in a short amount of time. While the public and technical "
meetings have been beneficial, they indicate the need for further study in order. It is
CTEC's understanding that an extension of undetermined length will be granted. In order
for the public to understand the implications of these studies, we would request that it be
long enough (until the end of April?) to ensure that adequate time is given for the
consumption and analysis of the information.
~ Sincerely,
~ roo .
. vin R~
. CTEC President
~N'JI",(J",(.,~:.~, .~
';'AOTECTION AGE/IoC,"
MAR - 7 1994
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CTEC
Citizeas' Tectuaical Eavironmental Committee
P.O. Bos 593
Butte, Moataaa 59703
(406) 496-4433
Quesrioas frequeatly asked about tbe MFOU Proposed Plaa:
Why doesn't the proposed plan call for draining of the Pit?
The Proposed Plan "writes off' the bedrock aquifer as irremediably contaminated. What are the
defined boundaries of the "written off' bedrock aquifer (3-dimensional) and what assurances does
this community have that these boundaries will not change in time?
0"ce ,I,e ROD is finalized. what ta...:gible evidence will indicate that the problem has been solved?
What parameters are envisioned as indicators of success or failure?
What will happen if. at some future date. deep-bedrock contaminants are transported into outlying
alluvium (outside the defined boundaries of the written-off bedrock aquifer). An example is the
known verticaJ upgradient flow from the bedrock aquifer to the aJluviaJ aquifer under the Colorado
Tailings. What dara. assumptions, and calculations have been made to ensure that contaminant
transport cannot happen via this known hydraulic system, or similar undiscovered mechanisms?
How can the division of the Mine Flooding Operable Unit from the Non-Priority Soils (outer camp
seeps and flows) be justified when each is affected by the same hydrogeological system (i.e. rising
groundwater levels resulting from the discontinuation of pumping).
What role has present and future mining played in the selection of this remedy?
Besides the 2.4 MGD ITolD horseshoe bend. what other potentially controllable inflows contribute to
rising Pit water? What control measures were considered for these sources during the RIfFS? What
are the maximum potential reductions of intlow that were calculated as part of the RIfFS? How
much water can be diverted ITom entering the Pit system after mining ceases, thus reducing the
volume of water that needs to be treated?
An assumption underlying all discussions and plans regarding the Pit has been the concept of a
"critical water level." How did this concept come to be the officially sanctioned key to the solution
to the Pit System Problem. How was the Critical Water Level established?
The water treatment technology associated with the preferred alternative creates substantial amounts
of sludge that must be disposed of. Alternative technologies exist which recover metals-thus
reducing the unount of sludge requ~ring disposal. Why were these not pan of the proposed plan?
What long-term assurance does this plan provide to the community that the sludge generation
associated with the preferred alternative treatment technology will not itself become another
Superfund-type problem down the road.
What will be done with West Camp water if Metro Sewer is unable to meet discharge standards due
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
IUOION VIII. MONTANA OF FlOE
FIDIRAL IUILDING. '0' I. PARK. DRAWIR '0011
HELINA. MONTANA 11128.00.8
Ret:
8MO
April 19, 1994
Mr. Kyle Scott
CTEC .
P.O. Box 593
Butte, MT 59703
VIA FACSIMILR
Dear Kyle:
This letter is in response to the questions pOled in .your
April 14, 1994 letter to me concerning the Mine Flooding project.
If you have any further questions or need additional information,
please call me at 449-56720.
Sincerely,
~cU.
Russell W. Forba
Remedial Project Manager
cc:
James Scott, MORSS
Bob Fox, 8MO
. '. .
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EPA RESPONSBS TO
APRIL 14, 1994 CTEC QUESTIONS
1. Why doesn't the proDosed Dlan call for drainina
the Pit?
The proposed plan does not call for draining the Pit for
three reasons: 1) EPA believes that draining the Berkeley
Pit .1s not more protective of human health and the
env!ronment than letting the Pit rise to higher level; 2)
Although the vol~~e of. water in storage is less i£ the Pit
is drained, the volume of water treated is considerably more
(up to 2 mgd more) and the quality of water to be treated
will be much worse than if the Pit is allowed to rise
higher; and 3) the estimated cost of draining the Pit ($350-
450 million) is considerably more than the preferred
alternative ($50 million) even though EPA believe. draining
the Pit provides no signiticant increase in protectiveness.
2. The pro90sed pl~n "writes off" the bedrock a~ifer as
irremediahly contaminated. What are the Droposad boundaries of
the"written off" bedrock a~ifer (3 dimensional) and what
assurances does the communitv have that these bou~daries will not
change over time?
SPA plans to provide a map in association with the ROD which
defines the boundary for which the "waiver" of State
groundwater standards applies. Present plans will place the
boundaries to include areas within the lateral extent of the
underground mine workings iri the East and West Camps.
Significant amounts of information are available which
outline the lateral extent of the underground workings in
the East and West camps. This will be an areal boundary and
not three dimensional. It should be noted that this
"waiver" an~ the corresponding boundaries need to be
established regardle8s of the remedial option employed or
the level at which the pit is maintained. No assurances can
be provided that the boundaries will not change over time,
because the final water quality in this area can not be
predicted. The water quality should improve in some areas
as the system rises and this may decrease the area where
bedrock water quality do not meet state groundwater
standards.
3. Qnce the ROD 1& finalized. what tanaible evidence will
indicate that the problem hag been solved? What parameters ar~
envisioned && indicators of success or failure?
This project is different from other project8 because the
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Agency is trying to prevent a problem from occurring rather
than remedying an existing condition. Because the objective
:s top~e~ent the degradation of the alluvial system by
contaminated mine waters, :he primary indicator that the
problem is solved will be that the critical water level will
never be reached and that there will be no degradation of
the alluvial system from the Pit System. The proposed
mc~itoring network will monitor both the water levels and
wa~er quality throughout the area. In other words the
tangible evidence will be the absence ot degradation.
4. What will happen if. at some tuture date. dee~ bedrock
contaminants are trans~orted into outlying alluvium (outside the
defined boundaries or the written oft a~ifer}. An example is
the known vertical upqradient tlow from the bedrock a~ifer to
the alluvial aquifer under the Colorado Tailings. What data.
aSBumctions and calculations have been made to en8ure that the
contaminant tranSDort cannot hanDen via this known hydraulic
system or similar undiscovered mechanisma?
EPA believes that this cannot happen between the Pit System
and the alluvial system as long a8 we maintain the negative
gradient between the presently dewatered sy_tam and the
alluvial system. The bedrock in the Colorado Tailings area
has not been dew&tered. There is continuous saturation from
the surface soi18 down through the bedrock. In fact, the
'ultimate remedy for the residual groundwater contaminants in
the Colorado Tailings groundwater after the tailings removal
is completed, will probably include a pump and treat system
which establishes a negative gradient between the alluvial
groun~water and the stream. In the dewatered Pit System,
there already exists a negative gradient between the Pit
System and the alluvial system and our plan will be to
continue to maintain this gradient. The primary' assumption
made to ensure that contaminant transport will not occur
revolves around keeping a gradient from the alluvial system
toward the underground workings and the Berkeley Pit.
5.. How can the division of the Mine Ploadina Onerable Unit from
the non-prioritv soils (outer c~ seepa and flows) be 1ustitied
when each is affected ~ the same hydrol09ic system (i.e. rising
aroundwater levels resultina from discont~nuation of p~inq}?
This point is well taken but not for the reason stated. The
OUter Camp has been at homeostatic conditions and has been
di8charging to the surface for many year8. It baa not to
this point been affected by the ce88ation of pumping in the
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The water levels in the Outer camp sha~ts have not responded
to the discontinuation of pumping as you have suggested in
your question. The water level in the outer camp is at
about the 5580 level which is over 500 feet above the
present level in the East Camp system and 170 feet above the
critical water level. EPA does see the need to evaluate the
Outer Camp and th~ impact o~ the existing discharge in its
own right. In retrospect, it would have been better to tie
the Outer Camp in with the East and West Camp evaluations.
Th& proposed monitoring plan includes several monitoring
points in the Outer Camp and the potential threats existing
in the outer Camp will be addressed at a later time.
6. What role has present and future minina pl~Y8d in the
eelection ot this alternative?
Present and future mining plans have played only a minor
role in this remedy selection. EPA believes that if mining was
not ongoing the Agency would still prescribe the same critical
water level, the same final treatment scheme, and the same inflow
control strategy. The only areas which are impacted by the
ongoing mining operations are: 1) the proposed plan integrates
the Horse Shoe Bend water into the tailings circuit because SPA
believes that this alternative is much more cost ef~ective than
having to treat the Horse Shoe Bend water in an independent
treatment facility; and 2) the plan does not require upper basin
clean water diversions because of the need for this flow as
makeup water in the mining operation.
7. Besides the 2.4 mad from Horseshoe Bend. what other
Dotentially controllable inflows contrihute to the risina Pit
water? What control measures were considered for these sourcel
durina the RIfFS? What are the maximum potential reductions ~t
inflow that were calculated as Dart of the RIfFS? How much w;ter
can be diverted from enterina the Pit aftAr minina ceases. thus
reducing the volume of water that needs to he treated?
The other controllable intlows into the system include Upper
Yankee Doodle Creek, Upper Silver Bow Creek, the Bast Ridge
flow, other minor upper basin tlows, and the Silver Lake
pipeline flow. Upper Yankee Doodle Creek, Upper Silver Bow
Creek, East Ridge, and other upper basin tlow8 are about 1.5
mgd; and about 4.5 mgd is delivered through the Silver Lake
pipeline. Approximately.5 mg4 are consumed in the process,
3.1 mgd is stored as insitu water in the tailings, and about
.2 mgd lost to evaporation.. BPA evaluated these inflows and
the potential for redueing or eliminating tham. Ho.ever all
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concentrator with the water rights owned by MR. Even though
the ,Silver Lake import is likely to be reduced because of
the integration of the Horseshoe Bend water, reducing the
other upper basin clean water sources would likely be
replaced by increased Silver Lake flow because there are
minimum total and soft water needs at the concentrator. EPA
the~afcra included only the Horseshoe Bend water as
controllable water in the FS. All of the Horse ~hoe Bend
water, Upper Silver Bow and Yankee Doodle Creeks and East
Ridge flows can be diverted after mine closure and EPA
anticipates including these diversions as part of the ROD.
8. An assumntion underlvina all discussions and nlans regardin~
the Pit has been the concept of a critical water level.- How did
. thia concept come to be the officiallv sanctioned key to the
solution to the Pit Syatem Problem? How was the critical' water
level establiahed?
In the negotiations with the PRPs for the Mine Plooding
RI/FS a preliminary critical water level (CWL) of 5410'
elevation was established. This agreement specified
stipulated penalties of $25,000 per day, if thi8 level was
ever exceeded. The preliminary CWL was established at this
elevation because this was the water level in Silver Bow
Creek at the west end of the Colorado' Tailings where the
alluvial system constricts and upwells into the Rocker
canyon. EPA viewed this level as the maximum allowable
water level for the Pit system (not just the Pit) and it
would be lowered if necessary based on the findings of the
RI. The RI was designed to investigate the alluvial water
levels and gradient throughout the area. After completion
of the RI the data was asstmilated and the 5410' level was
~etermined to be protective and deemed the atticial CWL.
The RI conclusively showed that the alluvial water levels in
the upper basin are higher than the CWL and that tbe
Pit/Ba8t camp system cannot discharge to the higher alluvial
system it the Pit system is kept below the 5410' level. The
5410' level is at least 50 feet lower than the alluvial
water level8 at the alluvial ground water divide to the
south of the Pit. .
9. The water treatment technoloay aBloeiated with the nreferred
alternative creates substantial amounts ot sludae that must be
di$poa~d of. Alternative technoloaies exist which recovtr .
metals-thus reducing the amount of sludae re~ir1ng diaposal.
Whv were these not part of tha ~r~osed plan.
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as copper cementation and solvent extraction/electrowinning
(SX/BW) would not significantly reduce the amount of sludge
generated. The amount of sludge generated is largely
dependent on the pH of the wastewater. With the Pit water
having a pH of 3.0, large amounts of neutralizing agents are
necessary to bring the pH up to satisfactory pH for
discharge regardless of metals concentrations. The basic
cr'~lusion of the FS concerning these metals recovery
t~~nnologies is that the value of the metals does not offset
th~ capital and O&M costs for the metals recovery facility
and that there are still significant wa8tewater treatment
costs after the metals are recovered (and significant
amounts of sludge generated). SPA is hopeful that cost.
effective innovative metals recovery technologies will be
developed in the future that will reduce sludge volume8.
Some ,are being explored presently in Butte. BPA would
encourage the development of such technology and would amend
any decision to include such technology if the PRPs and the
developers of the technology would collectively propo.. a
viable alternative.
10. What lena-term assurance dees this plan provide the
community that the sludie aeneration associated with th~
preferred alternative treatment technol09Y will not itself
another Superfund-type croblem down the road~
becom~
The sludge generated from this treatment technology will not
be a hazardous waste but an alkaline, lime-based material
'chemically similar to the tailings presently generated by
the mining operation. The daily sludge generation for a
full scale treatment plant will be only 1-2t of the volume
of tailings that is produced in the mining operation. Any
sludge repository will have to be designed to reduce
precipitation infiltration, leachate generation" and
leachate migration. It is likely that this repository would
' be built in the active mine area which naturally drains to
the Pit system. The Pit would therefore act as a natural
collection system for the minimal amount of leachate that
might ever escape trom the repository. Because it' i8
nece8sary for a treatment plant to be operated in
perpetuity, regardless of the reme~ial alternative or
critical water level selected, any small amount of leachate
that would be collected woul~ be treated in this facility.
11. What will be done with the West CAIqp water if th.~ M8tro
~ ia unable to meet diacha~~~ 8tanda~d8 d~; t~ ~~~t;;i;;nt
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The West camp water is very different chemically from the
Pit System water and is presently being treated in the Metro
Treatment Plant. If the Metro Plant is no longer able to
handle this flow, the PRPs are required by past orders with
EPA, to build a facility to treat this water. This
treatment plant .has already been designed and these plans
are available for. public review. EPA believes that the West
Ca'~ water may be compatible with the Colorado T~ilin9S
9.~undwater and that these streams may be combined for
efficient treatment in the future.
I:
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THE
Clark Fork
Pend Oreille
COALITION
P.O. Box 7593
Missoula, MT 59807
406IS42~S39 .
P.O. Box 4718
Butte, MT 59702
4061723-4061
P.O. Box 1096
Sandpoint, ID 83864
20&'26U347
G2
I
i
, April 29, 1994
tNvtAONM£NTAL
~OUCTION AGENCY
MAY 0 2 \994'
MONTANA OFFICE
I
I Mr. Russ Faba. Project Manager
I' U.S. EPA
301 S. Park
! Helena, MT 59262
Re: Public Comment: Berkeley Pit & Mine Flooding RIIFS/Preferred Plan
Dear Russ:
. The Coalition requests that EPA respond to each of the fdlowing cancems and
questiQn8 conc~ning the Betteley Pit and Mine FIoocing RIIFS end Preferred Plan:
legal Questions
. How does the Preferred Remedy protect agains1 the release and the ttl'eat of release
of contamination ~ven the fact that wat. can, indeed, mov, ttl'ou~ ,bect'ock of th, pit
(e.g., the mines and pit were dewatered) and contaminated mine wat. arrently
enters Silver Bow Creek from the bedrock a~ifer at the end of the CoIcndo Tailings
where it is a gaining stream?
. How does the Preferred Remedy reduce mobility, toxicity Q" volume of' ,
contamination? We see that it inaeases volume of contaminated wat. and
~oundNater in the shcrt-term and doubles it in the long-term and permenently. We
see that it aeates ~eater toxicity and that the psi inaeases the probability of
mobilization tlYou~ fract\res in the be
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perpetuity without a "beneficial" purpose fa having done so? There will never be
mae water on the planet than is presently available. Perhaps EPA should obtain
public comment from affected water users downstream befae going forward with this
~an. -
. What is the basis fa EPA having put a lid of $60 million on the amount of dollars that
could be spent fex the perpetual remedy fex this site? The public document showing
the Preferred Plan says that reducing the water in the pit was not considered because
it would be too costly. As cost is only one of the nine aiteria fex evaluating remedies.
we recommend EPA go back and develop a plan that reduces contaminated water in
the pit - what is preferred by the overwhelming majaity of affected residents - and
then evaluate its cost effectiveness along with its ability to reci.lce mQbility, toxicity and
vOlume of contamination, its short-term effects, its community 8rCeptance, and its
permanence.
. It is stated that all the a~ematives have shut-term effectiveness because none result
in adverse short-term effects. . We believe short-term effectiveness meana how
effective the remedy is in the sha-t-term and if it deals with the problem quickly. None
of the alternatives deal with the problem quickly; rather, the att«natives attempt 10 .
justify putting off deanup fex decades. Why does EPA not rec~ize the increased .
volume of contamination as a ~crt-term effect. fer example?
. Regarcing the Travona Mine water which is pumped 10 "e B-SB Metro Sewer and
ciluted betere cisc:h..ge to Silver Bow Creek. how do EPA and Montana DHES justify
not meeting $tate water ~ality standards fer Arsenic and Iron in this "Ireatment?8 -
The Coalition asks that you not set an early ~ecedent fer waiving water quality
standards cUing Superfund deanup of theheactNaters of the Clark Fork River: .
. The Coalition believes Butte should be treated as well is other cities ttYoughout the
nation where contaminat~ aquifers .-e. pumped and treated and dean water
discharged. The aquifer can be seen as a vessel that holds the valuable water
res
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the end of the CoIaado Tailings not identified as a release of contamination in the
RifFS (Y: Preferred Plan? Will a study be done to identify how much of this water is of
the (wase) East Camp quality and how much is of West Camp quality? What exactly
are the levels of contaminants in that water over all? (You will recall it was identified
by the State in a recent public meeting as being of Mpocr quality" ).
. Initially, geater volumes of water were entering the Berteley Pit each day than are at
p-esent, and less is expected in the futl.l'e. We understand this is because the
gaaent deaeases as the water rises. Anyone can realize that the balance of the
contaminated bect'ock water has to Q?ing some where. Please tell us where.
. Mere wells ar~ needed in the wea south of the Pit to confi'm that the low level in Well
C is caused by Q-awdown in that area and is not indcative' of a larger ..ea of low« .
gounct.¥ater. ARCO incicates EPA has to JJ'oove if the CWl should be lower than
5,410 feet. Well C is enou~ JJ'oof that there is gound wat.. with a head below 5,410
feet. ARGO should JJ'.ove that the goundtmer is not lower f\I1her south by p-ovidng
a~ate adcitional wells. ..
. What is the wat.,- quality of the bectock aquifer: in the midcle of the valley, say ne..
the ai'pcrt? What is the gound water quality at depth where the bectock d'ops off
toward Rocker? Could a new inc1Jstry using hig, volumes of water in south Butte a- in
Rocker cause inc1Jced infiltration to contaminate existing wells?
. Butt~Snver Bow has a contract with ARCO whereby they ageed to aeate some-yet-
to-be-defined rnstitutionaJ Controls that appear-to indude well bans. To what extent, if
any. does the Preferred Remedy rely on Butte-Silver Bow being able to condemn
some wells and fcrbid dilling oth..s? Please define the geogaphic ..ea expeded to
be affected along with the types of restrictions anticipated fer each. Please state if the
JJ'oper1y owners involved were aware of these potential restrictions beta-e dose of the
public comment period fa- this Preferred Plan.
. Is contaminated water entering gounct.Yater and Silver Bow Creek from ..tas such
as the Q-een lake Seep, the Orphan Gii Shaft, etc. in the Outer Camp ..ea?
. What is the contingency plan if mining does not Cease in 2,0061
. Wili the pumping and treatment plant fer the Berteley Pit water withstand a sizable
ea1hquake1' . .
. Should not the wa-s1 possible case have been considered in IJ'Udently evaluating
the ability of the Yankee Doocle Tailings Dam to withstand a sizable ewthCJIake? A
seismic event of 6.5 may not be In a~ate estimate.
. Will the Yankee Doocle Tailings Dam move south in funJ'e construction plans? We
understand tom those who initiated construction of the dam thlt it has satlnted
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Lf
bentonite clay. ihere are three faults in the area and the Continental Fault runs
through the east portion of the dam. Were all of these considerations known to the
engineet:ing company that reviewed the integ-ity of the dam?
. Can EPA assure residents that "treated" Travona mine water contaminants of
concern - copper, zinc, cadmium, lead, etc. - are not going to become remobilized
downstream tlYough forces of nature?
.Why is construction of the already designed treatment plan fer Travona Mine water
not requred in the Preferred Plan?
. The Critical Water level for the Travona Mine is set at 5.435 feet in the Preferred
Plan. This is awoximately 25 feet higher than alluvial and S1J'face water im~,"jately
down g-acient-tand well GS -27 was at 5.413.9 feet in Fetruary, 1994). How can EPA
aSS\re contaminants are not being released with such a hi~ CWL elevation at 1he
Travona? ARCO should have to prove water cannot leak ttY'ou~ to streams with a
,lower head than 5,435 befere the Travona CWL is set above the level of Silver BcM
Creek at its lowest elevation in the Butte Valley.
. We assume that most treatment facilities are only desig'led to last about 30 yen.
without some majer overhaul er redesig'l. So a pumping and treating facility fer pit
water should be put in place as soon as possible that uses the best QlTent
technology. Every 20 er 30 years it should be redesig'led to inccrpcrate the latest '
technology. Better. proven technologies than that in the Proposed Plan (and which do
not generate massive amounts of waste sludges) ahady exist. Hence, there is no .
valicity to the ergument to wait fer better technology. If you always wait fer next YW'8
model, you never buy the product you need. Buying something wiD aeate markets fer
mere and better technology. A, plant should be designed now that lends itself to easy
, retrofitting er redesigning fer newer technologies that may be implemented at later
dates.
. How long do you perceive that land asposal of sludges would be recJJi'ed betere
new technology mi~t be apJroved by you that Jl'oc1Ices no sludges? How much
area would be requred fer land cisposal of those sludges?
Human Heatth Concerns
. Please see the attached pap« by Luoma and Moore on health haz..ds in the Upper
Chit F ark ~e to mining. Please advise how this Preferred Plan adctesses u
contaminants, ~ven the hig, incidence of lung disease, even among women. -
recerded fer this wea. WiD the Agency fer Toxic Substance Disease Rt9stery review
this resewch to attempt to identify long-term causes of the extremely hi~ rates per
capita fer all ciseases, hec1 asease. etc.
. We understand that winter fog from the Berteley Pit caused a pilot to be unable to
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running out of gas enroute to another airpcrt. How does EPA propose to eliminate this
type of permanent nuisance with a remf:dy that will eventually widen the pit water to
nearly 500 aaes. an inaease of at least two times over that present when the cited
accident took place?
Russ. we reaJize this is a very complex site and geatly aweciate the hard wat
and concern shown by both yourself and Jim Scon of DHES in answering OU'
questions over the past many months.
Thank you fa Y(XS careful consideration and answers to the above CJJestion8.
YOtJ'S very truly,
~~~
Mary Kay Craig
Upper River Field Repre~ .tative
Attachment
cc:
Senator Max Baucus
Senatcr Conrad Bums
Representative Pat Williams
Ms. Cevol Browner, U.S. EPA
~. Bill Yellowtail, U.S. EPA Region VIII
Governor Marc Racicot.
State Representatives
B-SB Chief Executive Jack Lynch
Pk. Neil Marsh, DHES
Mr. Jim Scon, DHES
\
s-
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THE
Clark Fork I
Pend Oreille i
COALITION :
P.O. Box 7593
Missoula. MT 59807
4061542~539
P.O. Box 4718
Butte, MT 59702
4061723-4061
P.O. Box 1096
. Sandpoint. ID 83864
20&'26U347
Ap"iI29. 1994
ENVIRONMENT ~L.
PROtECTION AGENCY
MAY 0 2 \994
MONTANA OFFICE
Mr. Russ Faba, Project Manager
U.S. EPA
301 S. Part
Helena, MT 59262
Re: Public Comment., Berteley Pit & Mine Floocing RllFS/Preferred Plan
Dear Russ:
Attached are Berkeley Pit research an~ comment papers the Coalition has
received from Environmental Studies students at the University of Montana in
Missoula. They are Steve Mietz. Bonnie Gestring, Carla Atrams and Molly Miller.
Please review the the papers and indude in the Responsiveness Summary
answers to the concerns and questions raised by these students.
Thank you.
Y f1S S very truly,
~~-
Mary Kay Crai~ - r
Upper River Field Representative
Attachments
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Alternate Plan and Rationale For
-
Berkeley Pit and Mine Flooding Operable Unit
"
.,
From the Clark Fork - Pend Oreille Coalition
.'
Presented to: u.s. Environmental Protection Agency
Date: June 30. 1994
G2
- j-
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"
Introduction
EPA's Preferred P!an fa remeciation of the Berkeley Pit and Mine Fiooding Operable Unit is
w'\i3c:ept2b1e to the people of Sut:e and ~o t"le C:ark Fcd~ .Pend ~eille Coalition. ~ajcr points of
d:sag-eement are the elevatien at which the 'Pit ',yould be ailcwed to remain in perpetuity, and the future
unbendly idea of waiting 30 more years to initiate any pumping and c!eaning of toxic Pit water.
C1sa9"e~~ent emanates not just from uncenair.:ie5 associated with the ?!an. but 2/50 the certainties-
!~e ,=~air.ty :Mat EP,A,cees;')'t require ar.yi~ing be dene to dean Pit water for another 30 years. and 1\e
c!r.ainty that toe perpetual elevation fa toxic Pit water would leave a heritage of impending aisis to all
future residents '
In c:::nsultation with residents who are knowledgeable about tt\e Hill. the economy and the social
system of Butte, Coalition scientists and technical people have prepared the following Community-
Based Alternative to the EPA Preferred Plan. It combines much of Butte-Silver Sow Coun1y's
recommendations, with revised elevations and time schedules. The Plan grows out of the need for new
treatment technology now, and it re'lies on the proven impetus of deadnnes. American know-how. and
market faces to bring fonh that technology. It allows EPA to move forward with most of the wart '
, suggested in its Preferred Plan. but asks that this occur under an Interim RecCI'd of Decision. In that
way, the new monitoring wells and other needed investigative werk can ocaz under and Extended
Remedial Investigation. The new, effective technologies that everyone unanimously agrees are needed
can be addressed under an Extended Feasibility Study. It allows that the F'mll Preferred Plan and
Record ()!'Decision not be issued until after specific technical and legal data gaps are fined - and that
the Pit be pumped and 1reilled . the ...Iiest possible time, considered to be the Y" 2002.
Recognizing that EPA requa-es technical or legal reasons to deviate from its Preferred Plan, the
Coalition has d,ocumented some of the inadequacies on which thlt Plan i8 based. Th......
summarized in an Appendix. . Reliance on Assumptions, Theories and Speculation,8 fer that is the
one tt\read that runs through all the complexites of the Preferred Plan and it is core to the public's
problem with the Plan. A tremendous number of unsuppcrted assumptions. opinions. modefs and
estimates aeates ., unacceptable cumulative m..~n for error in Butte's one-and-only chance fer
remedy of the Pit and Mine Flooding. Evidence is presented that the Preferred P:an disreg..ds some
of EPA's own criteria for remedy selection (pg. 14; e.g.. Toxic Volume RedUc:1ion. Short and Long.
Term Effectiveness. Cost. some air and water ARAR's [Applicable Relevant and Appropiate
Regulationsj and Community Acceptanc.). Questions and concerns presented here were filtered from
those of Coalition scientists and staff. Butte's EPA grant-funded crec (Citizens' Technical
Environmental Committee). Butte-Silver Bow County scientists. plus students and others who have
followed thi!l: iC:!I:1le !:!::!!y. '
It is also significant to note that a 3~year postponement causes a g-eat deal of current on-the-
gound and underground e~se and understancing of the situation to be lost (death, relocation. etc.),
resulting in reliance on documentation as opposed to fht hand experience. ~use futu'e gen.ations
may have less understanclng than we have at pr.sent. today's generation is in a better position to move
faward with a solution.
The Coalition befieves that. :'''':::.;gh ia U\\JW~'I~:"; ieview of the Appendix. EPA will become
convinced of the validity of the community outpol.ling that the Preferred Plan is unacceptable. The
Coaiition p-oposes the following Plan that combines 1he best aSpects of the E?A Plan. plus removei
some of the uncertainties to which citizens object.
1
"
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A Community-Based Alternative
The Coalition believes that it is in the lon~erm best interest of the citizens of Butte-Silver
Sow and all its downstream neighbors. as well as the environmental health 01 the Clert Fcrt
Ri'ief Basin that contaminated water in the Berleley Pit begin to be pumped ~d treBled as soon
as ~ecl1nicaJly possible. utilizing treetment that minimizes waste sludges while freeing clean
wcfier for permanent. beneficial uses. it is hoped this can eventually indude deaeasing the volume of
~CXIC materials currently in the Pit to provide a geater margin of safety to future generations. The need
!or deCieasing toxic volume fro,m today's levels could be determined based on any inaease in
,::nndence !rom the community after data gaps (discussed below and in Appendix) are filled.
The ~o!/owing alternative plan. liKe the EPA alternative 18/19. holds the Pit level at its elevation at
:he time :he remedy is implemented. The plan agrees with many of the Butte-Silver Bow County
iec:::mmendations. but employs a lower protective Pit water level based on elWtiesa possible
implementation. which is considered to be the Y" 2002. This allows some time to develop more
effective treatment technology, The plan also emphasizes m...agement 01 wat. inflows.
The process fet' implementa~on 01 an alternative plan would include;
"
. an Interim ROO now (Record of Decision) specifying need fet' additional information which
would be accomplished under an
. Extended RJ-FS (Remedial Investigation - Feasibility Study); then a
. Fin. Preftn'ed PI... and .
. Fin. ROD could be issued as soon as an adequate treatment technology is found.
The Coalition recommends that implementation not be tied to any specific Pit water elevation. but
to the need fa soonest possible implementation of treatment, recognizing the need fer responsible
action from today's generation. '
The following paper outlines the impc:t'tant components of this community-based alternative.
A. Adcitionll Data
'.
"
1. Data ~~ ~minated 10 tb.!.Extent PosSible: . 'vi 's i r
the "soft" data and assumotions (see Aooendix) that have aone jnto the ~ on which the
Preferred Plan is based. While net'mally associated with economic projections for decision-mating,
this type 01 exercise would be valuable to both the community and to EPA in justifying whatev..
decision is finally deemed appropriate. This analysis should be accomplished first: 1hen this yew',
Interim ROD would delineate what new data must be generated over the next year to filHn the most
aitical data gaps. Areas which appear to require new data immediately indude:
. Immediate implementation of monitoring well, southeast 01 the Berkeley Pit and in the West
Camp as specified in the Butte-Silver Bow recommendations and by Rawling Technical Services.
~Ius consideration of a deep quality well at Rocker.
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. A ;'i'.ore acc:ura~e water budget anc thorough analysis of potentially slowing inflows. From these.
the 'Jclume of water liecessary to pump in 'j)e year 2002 can be more reliably projected, A total
wa:er :;,;c~et must indude municipal :eakage and. impcr:an~y. ~ate of outflow (inc!uding at the
C:;);c(~CO Tailings). if ~e water :evel st9Ps rising, incoming water is going somewhere. If less water
~eecs :0 ~e pumped in succeeding years. PRP's (Potentially Responsible Par".ies) must prove it is
r',ct leaving the Pit to aeate a new problem.
. Viere cef:ni~ve g-ound water modeling to indude:
"thermal influences
"conservative expectations of cone of depression influence on Pit and tunnels
./ potential East Continental Pit iniluences on contamination migation
./ determina~on 01 exact locations 01 gound water divides: possibilities 01 flow reversals
. Quality of inflow and outflow due to mine flooding must be stated in the Mine FloodingOlU
(Operable Unit) to assure that all contamination Feleases are adctessed. This should indude
characterization of sources 01 bectoct aquifer contamination rel_es at the end 01 the
Colcraco TailingS with remedy fer same addressed under this O/U.
. Pit miaobiolo~caJ and geochemical stucies
. Pit bor.em sediments studies to determine Geochemistry 01 sediments and whether sediments
cvuld be sealing the Pit bottom .
. Deveiopment of downsteam landowner program fer monitoring of -new springs. between Butte
an d Garrison Ju nction .
. Stucies of relationship between saturated bectocle and potential rise 01 alluvhi a~if..
. A pian ~er preventing loss of the mil'lY bulkheads between East and West Camps andfer a
contingency plan for dealing with the loss if it occurs. It would include analysis of East vs. West
hydraulic heads. relationship of locations/elevations of bulkheads to one another and pOSSIbly to
Orphan Girl area, ~een lake Seep, etc.
. Identification of any additional contamin81ts within the OIU with rislc analysis and public
information (e.g., erganic contaminants within current mining lands ~d leach pads)
~ .
. Initiation of air quality epidemiolo~c investigations (poSSIbly by the Agency fei Toxic Substance
Disease Registry) and if necessary, feasibility of stabilizing Pit walls
2. Public n atio : Better public infermation and involvement is needed 1hroughout the
process so new information (e.g.. rislc assessment; epidemiofogic study) is made available in a way
that is both accessible and understandable by the general public. Particular gaps would be fitled:
. a public comment period on EPA proposal to 'Write off" the bedr~ aquifer
. a published list of wells (~vate. public) affected t,y mine floccing, with more open and
proactive EPA communication of implications - where weN bans might occur, etc.
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... 'I -...... - .,
!nterim ROO Mls1 EmDhasize the DivE!'sion of all Controllable WfJtE!' ~om the Pit Source control
a~d ~oi!l;tlon prevention should a!ways be 'toe ~rst sle;::s in pclruiion c:;ntrcl. in addition 10 Horseshoe
Se;d water c~rrently planr.ed ~or diversicn. any increases 10 the Horseshoe Bend flow must be diverted.
S'::-r~ wa!er entering mine shafts must be di.jerted. leaks in the municipal water de1ivery system must
~~ r:::;aired. Pit inflow from current mining operation spills and any possible from planned expansion of
:he Yar.kee Doodle iailin!;js dam must be mCie adequately ada-essed.
C. A More Protective Water lINe.
1. Potential Future Events - Effect on Pit RUing Rate: EPA must identify l.~e types of future events
that could cause either a shutdown of Pit pumping and ~eatment a a need for an increased rate of
. pumping and treatment. A probability value could be assigned to each. induCing the number 01
same otcurrences '. ~ible in perpetuity. Some of these events include:
. Earthquake effects on Yankee Doodle Tailings Dam at higher than 6.5 Richter, and re-evaluating
distance from Dam, depth. dispersal and anenuation factas
. Possible increased flow of Horseshoe Bend water as a result of adding 60 mae feet 01 tailings 10
the Yankee Doo01e tailings pond
. Ear.hquake effec:s on operability of pumping and ~eatment plan
. Ear.."quake effects on Pit tom collapse 01 Kelley Mine wall
. EarthquaKe effects on manmade diversion structures designed to contol Pit 1illing
. Effects on availability of funds fa perpetual operation in event of depression
. Potential ARCa banlcnJptcy effects on availability of funds fa perpetual operation
. Acts of War that may shutdown facilities
. Pot~ntial fa changes in government negating maintenance contracts with County
. . inaeased cost 01 pumping and/a teatment maintenance
..Availability of newer, more permanent treatment tec.'1nology with higher costs
2. Mer.;;n of Safety: A lower Pit level provides a larger buffer against disruption 01 treatment a
catastrophic events that may cause a sudden rise in Pit level. In addition, the iowest Ber1celey Pit
water level possible would be desired by fu1Ure generations because if initial treatment becomes too
costly a ineffective, future generations will search fa another solution, probably a more permanent
solution that doesn't require perpetual care. The less water they are faced with deaning up, fie
fewer costs will be incurred when a decision is made to implement a non-treatment solution.
3. Cbliaation 10 Accept Resoonsibility: The Coalition believes that the present generation must
~cvide the best available teatment option and implement it as soon as possible. All 19 alternatives
considered by EPA shift the burden 01 responsibility from the present generation 10 tuv.
generations. This is not good public policy. Also cumulative effects may be untenable, economically
and environmentally, fa continuation of the quality of life present generations enjoy. The present
generation should implement an ~ffective solution and then not permit the Pit water level to rise'
farther.
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4. TI:a-e!cre '''',s r:w-esent r;~E!'r3!!':~ mu~ :~p!emer.t an 3lT~r.ative mat holds ~e Pit at the
!evc:i it i~ at "hen the ~on=t ~o=ble effective ~ofution t:an be imDlemcnted. Thi~ option
~ovJ(=es time fCt' ~esting and designating a more effective treatment technology than the currently
specrfied method of hydroxide precipitation.
D. Treatment Technology to [)ive FinaJ Pit Level
1. Deadlines ~o be Soecified in Interim ROD: Rather ~an wait nearly 30 years hcping and wishing
fer new. inexpensive technology fer cleaning oj Pit water, new technology can be encouraged now by
employing en1re~eneurial American competitiveness, capitalism and market ferces. Deadlines
drive action and innovcmon just as they did in the space race's moon landing. The race to restere
and cCT1serve our planet needs deadlines. too. Waiting thirty years shows blata..,t disregard fer our
chilaen and grandchilaen. An Interim ROD issued in 1994 would require clean up go forward today,
not badward from 2022. . '..
2. Soonest ention Date to be ecified i Inten an Fi aJ Record 0 . '0 : The Interim
ROD would specify that the pumping and teatment facility be designed, constructed and tested to
accomplish full operation by 2002. It allows that the pumping facility can be adaessed first,
immediately after a water balance budget determines the maximum capacity fa' the facility, because
a pu mping plant would not have to change depending on the treatment technology chosen. The
Interim ROD would also specify the schedule for the treatment facility in a'der te accomplish lb.
JuDy operational end dare 01 2002.
3. T echnoloav DeYefoDment Process: The U. S. Department of Energy is currently funcfing a pubfic-
~ivate partnership to test treatment technologies for remediation of Berkeley p~ water (plus other
applications). Efforts would be made immediately to obtain additional funding from EPA's SITE
progam cr other research gantors so mere than the currei1t two to three technologies per year can
be evaluated. The Interim ROD issued in the fall of , 994 would specify that such a research goup
work with EPA and an oversight council (a' community working goUp) in the Extended FS stage:
. In late 1994. to call for new technologies internationally. Any aganization interested in benefiting
from extraction of metals tom Butte's mine flooding:
" must come forward With ther bench-tested technology and results by a date no later than two
- years from date of the invitation (fall, 1996): a' .
"those who cannot aff~rd to test and cannot find investors must quicily submit ther'.technology to
the research a'ganization(s) fa' possible evaluation and testing- (d\ring the same two yeW's) if
the process shows potential.
. By end of the third year, the top one, two «three tre&bnent technologies will have b-.
seleded from all submissions.
.,
. By end of the fifth year, these top entries will have been pilat tested and bther cost
analyzed, with the most effective one technology selected 8\d specified in 11\1 Fan"
Preferred Plm and Finll ROD issued in 1999. .
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, .
;.'~.
. ,
. -:r,e :r\:ciim liCD wiil have spec;;ied ~at by t~,e end of :he 'ifth year (1999). :he pumping plant will .
ha \Ie ~een designed and construc~ed and that. in years six and seven (2000.2001), the treatment
f;)cility :5 designed and cons1rUcted.
. :~ yea: e;ght (2002). pu l'iip:ng and treatment begin. 8y t~,e end of that 'Jeii!I, de-bug;ing is
completed cred full pumping and treatment operations tate place to hold the Pit water 'eyel
at its 2002 eleyation (or 10 reduce the elevation if that was required due 10 earlier sensitivity
anaiyses). .'
. ...: ~
.'.
E. West Camp
1. The Oitical Water levef in the West Camp's Travona Shaft should be set lower than the Silver Bow
Creek level of 5.410' where it exits the Summit Valley. EPA's Preferred Plan would make permanent
t~le Travona Shaft.s 5.435' CWL (critical water level). Therefore, the contaminated watt r in this shaft
would ~end to flow tQward Silver Bow Creek because the aeek is lower and there are no bulkheads to
prevent it from flowing there.
It may be important fer water in the West Camp to be kept at the ~me level as that in the
East Camp to prevent the Pit water level from rising in the future if water pressure deterierates one of
the many flooded cone-ete bulkheads dividing the camps. These bulkheads were designed to save
pumping costs by allowing West Camp waters to rise while dewatering continued fer operations in the
East Camp. There may be no bulkheads on upper levels. On lower elevations. depending on
hydraulic head. they may not be .adequate to withstand a water pressure reversal from rising of the
mae voluminous East Camp water.
IJn~1 !he additional data is made available on locations of bulkheads and the stresses to them.
!he Interim ROD should at least require that the critical Water lwei in the Travona shaft (presently
set by EPA at 5.4351 be lowered to an elevation less than Silver Bow Creelt's 5,410' elevation
where it leaves the Summit Valley. The Interim ROD should specify that depending on new data to
be generated in the Extended RI, the Travona may immediately be pumped down farther and be
maintained at the elevation of water in the East Camp.
2. WaJer Quality: Treated mine water must comply with water quality regulations. Since 1989, EPA-
DHES (Montana's Department of Health and Environmental Sciences) have allowed contaminated
water to be pumped tom the Travona to the Butte Meto Sewer (under a contract between the
County and PRP's). State water quality exceedances fer arsenic and iron are thereby dluted
through mixing with sewage. Under the Preferred Plan, the Agencies would continue this
arrangement until the County finds they cannot comply with inaeasing standards fer SDver Bow
Creek and opts out of the contact. The Coalition believes the Agencies must insist on compliance
iather than setting a bad precedent fer potentially relaxing other water quality stand8'ds that may be
important to recovery of a fishery. A reatment plant has already been designed as a contingency
and should be put into operation as a requiement of the Interim ROD.
6
~,
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Source of contamina:ed waler west of :ur.e in the Green LaKe seep would be determined now.
Ol,;clity ~cmp'ing immediately :should determine if that water i:s from the Ea:st or the Wm Camp.
:~erety ~.eiping :0 veri~y if East Camp wa1er from :~,e northwest por1ion 01 the Hill is. as the Agencies
~~I=e. c:-air.ing toward the BerKeley Pit
F. Financing
1. PAP's Must ~ovide Bonds UDfront for initial building costs. and to endow perpetual operation and
maintenance. plus a special fund fer upgrading treatment facilities. .
2. Investment 01 Short-Term Savi.Qtt.in Treatment ~nology Reseil'~ODment:
etean ups should proceed immediately after issuance of ~e ROD. In some extraordinary cases like
:1'Ie BerKeley Pit. it may be advisable to delay clean up fer a reasonable time to ~develop new
ted1noiogies (not wait hopefully fer their development). When such'a delay is seleded,1he savings
. on operating and maintaining a conventional ~eatment plant, and the interest earned on what would
have been spent on construction. should be collected from the PRP and invested in developing new
technology. If a new technology is developed that is wholly cr par1ial/yfunded by the PRP, the PRP
would benefit tom other applications.
The money that is saved annually from delay of clean up shoUld be invested in reducing inflow to
the Pit and researching and developing new technologies.
--
The Coalition ails on Montma's legislative delegation and leeders 10 help
convince EPA to loot seriousfy at this proposal. It refted8 the thinting 01
dedicated en~neer8 md scientists who have been involved with the teln.
F100clng 00 for Ye&"S, plus the wishes of affected residents, as de81y
evidenced by over 10-1 01 Butte citizens having signed a petition that EPA
reciJce the wat.. in the a.teley Pit and d.. it up now.
~ .
..
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G. Proposed Schedule to Reach a Final ROD
Dccument/Tast
Call tor New Treatment Research Funding..
list of Private Weiislimpiications
Sensitivity Study of Existing Data by EPA .
Issue Alternate Pfan for Pubfic Comment
Issue Interim ROD (requires items below)
Call fa' New Treatment Technologies
Comprehensive Monitoring Progam
Implementation Begins .
Additonallnflow ContoIs Implementation Begins
New Oata Generated as in "A" above Re. water
budget modeling. sediments. etc.
All Bench Tested Technologies Received
Top Treatment(s) Selected fa' Pilot Testing
Pumping Facility Design and Constuc:1ion Starts
One ireatment Selected fa Preferred Plan
Issue Extended RI-FS
Issue Fanal Preferred Plan
Public Comment
Issue Fan. Record of Decision
Design and Construction Starts for
Treatment Facility
Completion of Pumping Facility begun in 1997 .
Completion of Treatment Facility .
De-bugging of Pumping and Treatment Plant
Pump and TreBI Plant FuRy Operable
.'
8
Completion Date
July. 1994
July. ~ 994 .
August ~994
Sep~ember. 1994
October, 1 ~
October, 1994
October. 19$4...
October, 1994...
October, 1996
October. 1996
October, 1997
October, 1997
Sep~ember. 1999
September, 1999
November, 1999
December, 1999
January, 2000
December, 2001.
December, 2001
December. 2002
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. .
Appendix
.",
. .
. "
EPA Reliance 00 Assu.mDtioos. Theories and SDecu/ation
As E?~ knows, the extreme complexity of itJe Sur.e Hill defies easy ariS'-Ners to remediation of
:Dn7ar.lln2ied waters ffooding ~e undergound mines and the Berkeley Pit. E?A has investigated the
~cb!~~ 2fGcst from the day ARCO discontir.ued the centuries-old pumping of the mine tunnels on
E~h Day. i 982. However. EPA's RJ-FS and Preferred P!an documents unveiled January 27, 1994 lack
':~iTlmuMy support Volume of contamination allowed in the Berkeley Pit in perpetuity is !ikely the most
SeriOUS issue to face Butte. People lact confidence in EPA's Plan because 01 its fundamental
re!iance on assumptions, thea-in and speculation, almu'atiye effects 01 which could be
catastrophic to the community 81d the heedwm8's of the Cri Fort Riy... .
A. Butte's Concerns
The people of Butte assumed that designation as a Superfund clean up site meant EPA would
conduct a "clean up" to deaeese volumes of toxic water and then discharge cleaned water in a timely
manner. While watching the elevation of the P~ water rise, the people aiticized EPA for taking ten ye8'S
fa studies. Then they were amazed to learn in April 1994 ads by the Clark Fat Coalition that EPA's
;:referred remedy would allow the elevation of contaminated water to rise to within feet of thli'
basements before any of ~ would begin to be cleaned and discharged - in the yeer 2022 - ano1her 28
years off. The people of Butte assumed that EPA would take into consideration 1h" concerns:
. Dee-ease in values of homes near a 500 aae toxic lake: inability to sell homes
. Concern fa pLrity of water tom existing wells (without instituting well bans)
. Loss of the economic benefits of drilling one's own well; loss of rights
. Potential flooding of basements from possible saturation of alluvial aquifer
. Hazard to ar and plane passengers as fogs spin out from the Pit
. Constant wary about land stability as the mines fill
. By remedy time in 30 years, much current knowledge about the site will be gone
as old-timers die .
~ Future--untiendly decision to require the next generation to implement a remedy \,
. Untiendliness of adding all future generations with a very shen time in '.
which to read to potential op..ation stoppages, whether ciJe to economic
collapse, social upheaval, Wit, weather, earthquake, etc.
. Potential benefits of devefoping a holistic approach to ~ remedation
~ Loss of fubJre minerals extaction opportunities as Pit ftoods
. Possible adv..se effect on abmty to attract new industies and health, etc. professional,
. Perpetual wanes of downslream folks that toxic ground water win migrate there
. Downslream sites not deaned up fer over 30 years because of Pit delay.
9
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B. Assu mptions Theories and Data ('~s
E?A bases its Proposed Plan on its daim that all water that enters the Berk!/ey Pit is and will be
c::i,!ained permar.enUy in the Pit. This claim is not a fact, but is an assump~on. .
The Coalition S1Tongly urges that befere a Record of Decision is issued, serious attention be
g~\;en :0 !M cumulative effects of the countless guesstimaxes, data gaps, assumptions,
predictions, scientific and ted1nical inadequacies, reii..,ce on theories ;wtd opinions, and
selective disregwd for some 01 the nine regal aiteria for choice 01 remedy that are employed in
documents produced fa this Operable Unit (OIU).
The Coalition believes the potential for errer is vastly multiplied because of the geat number of
variables involved in the studies. lack of some data that could be made available, and near-exclusive
reliance on Potentially Responsible Party (PRP) contracters vs. truly independent, highly qualified
expertise. Although EPA is only required to protect human health and the envronment from toxins, EPA
must assume responsibility fer causing individual and community economic hardships and aeating a
perpetual aisis mentality. EPA's preferred -remedy" to allow the Pit to reach 5,410' elevation and to
wait 30 mere years before teating water tom the Pit and mine flooding (other than Haseshoe Bend)
appears to be gavely flawed. .'
Com
's
1. Ground Walrr- Pit Dynamics
. Modeling of wound water flow assumes const..,t head pressure at depth, a possibly naive
assumption given Butte's intricate 3,500 miles 01 runnels extending over a mile down from mace,
along with elevated water temperatures at most deep levels, none at others (Neversweat shaft),
. and Butte's surface seasonal temperature effects on Pit water. Hydrology students employed by
the Citizens' Technical Environmental Committee (CTEC) have cautioned that EPA does not have
adequate infamation fer modefing assumptions made. They have also ~ovided EPA with
cautionary infcrmation regarding limitations of models in decision-making and degree of
dependability of models. A better idea of what is occurring at dep1h could have been obtained
through computer modeling based on actual mine -stope- books. Despite a 10 ye. study 1hat
cost $10 million,these factual data were not reviewed. .'
-------
. Write-off of bedroct aquifer: Public information on the decision to write off the bedrock aquifer
has been inadequate. The intention not ~o clean up the water wasn't dearly conveyed to the
ccmfi,unity: justifications have not been provided to the Coalition, CTEC or other interested citizens.
E?A evidently assumed that the public did not need to know about this loss in perpetuity of rights to
aquifer water resources. The Ccalition believes a public comment opportunity is necess."
~spec:ally since the decision origif'\ates from a new. erganic contaminant-based EPA guideline that
1he Surgeon General's office indicated was to be rarely used. It would set a precedent for mining-
relat~d waste remed:ation. Many Butte people conjecture that this 'Mite-off is a aiticaJ linK in
ARCO's ability to allow the BerKeley Pit to fill and remain full fa-ever. Modeling of the deep bectock
water was not adequate (assumed constant head pressure), and without additional knowledge of
the dynamics of that aquifer, it is premature to write it off. Additionally, water in the Berkeley Pit
portion is not gound water. but an EPA aeation of a surface water impoundment As such. it may
not be subject to the -gound water" write-off guideline.
. Contamination releases ignored by EPA in RI-FS -.d Preftn'ed PI..: EPA nt' ~ected to
inform the community in the RI-FS or Preferred Plan for this OIU that contaminated bectock water
is exiung the Summit Valley via a -gaining- S1Team at the end of the Colorado TaiHngs.
EPA and DHES (Montana Department of Health and Environmental Sciences) state that as the
Pit rises. water enters it more slowly. Inflow began at about 7.000 gpm. anC:t is now at 5.000 gpm.
But the agencies were unable to satisfactorily answer comment period questions about where the
other 2.000 gallons go. EPAIOHES stated, 'Water cannot leave the Berteley Pit," "Water is puRed
into the Berkeley Pit cone of depression and cannot exit." However, they recently acknowledged to
the Coalition. "yes. poor quality water is upwelling from bedrock below the Colorado TaiDngs. but is
probably not from the East Camp a the Pit in our opinion." The Bureau of Mines es1imates that
95% 01 the water entering Silver Bow Creek at that point comes from the bectock aquifer. The
Coalition estimates that the PitlEast Camp bectock makes up 90% of the Mine Aoocing 00. It
incudes a large cadmium plume according to data generated by the Nattnl Rescuees Damage
Program.
The Silver Bow Creek Phase II RI Work Plan of 3131/89 for the Area One O/U states on page
5 that the bedrock gound water system at the Colorado Tailings would be evaluated under Mine
Flooding studies. This evaluaton was not done. The Coalition was recently told that studies of
water quaJity at the end of the Colorado Tailings are not thorou~ enough nor recent enou-,
to determine whether or not Pit system water is involved, or if releases might be related to
inaeased elevation/saturation of mine lIooding. The Coalition is now told this mine flooding
release. does not exit within the Mine Floccing OIU, so would not be adctessed until some fu1Ure
time under both Priority SoDs and Streamside Tairlngs ClU's.
The Mine Flooding RI states 1hat alluvial contamination follows gound water flow patterns;
that gound water south of the Berteley Pit flows toward Silver Bow Creek. The alluvial aquifer 18
contaminated along the length of the Meto Storm Drain and both north and south of it.
Contaminated gound water tom mine flooding is, therefore, being released into SOver Bow Creek
at its confluence wi1h Blacktail Creek. Releases due to mine floodng must be adctessed under
the Mine Floodng OIU and must be completely researched.
-------
. Assumption that rate of Pit filling is deaeasing is not proven by data: Equilibrium is not
evident: If me Pit does stop rising, then water is esc~ing somewhere. Data from the
Mon:ana Sureau of Mines shows :hat water in the Berkeley Pit rose over two feet more during the
one year period May-April 1994 than it did during the same period ending a year earlier (24.5'
from 5/92 to 4'93 VS. 26.64' from 5/93 to 4194). These numbers do not consider widening of the
Pit as water rises. so even more water actually entered the Pit in the last year. Pit filling is not
deC'easing and water in the Pit could require pumping in less than ten years.
. Acctlar:'/ of Wa1.er Ba'~ce is questionable: Use of averages in RI-FS may cause
underestmation of true amounts of water necessary to be diverted to control inflow. The 2.5 mgd .
(million gallons per day) from leaking municipal water supplies was not included in the water
balance. Herseshoe Bend water was at a higher volume in 1989 than today (4 mgd then: 2.4
mgd in RI) and is said to have increased recently. The possibility of inC"eased water discharge
due to Planned expansion of the Yankee Doodle Tailings Dam another 60' in height has not been
explored. The aC::Ual volume ot water in the Berkeley Pit is unknown; therefere. there is no check-
on what amount of water is possibly leaving the Pit through ground water. Unless an acarate
water balance is (jeveloped. leakage would go undetected. If water is escaping now, ferg.
volumes could escape before the s1art of pumping, If it is impossible to develop a good water
balance. it becomes aiticaJ that early precautions be taken - pumping and treating water as soon
as possible. .'
. Arbilrariness of location of East vs. West Camp water divide: Without monnaing wells, the
location of the water divide is unknown. For example. experts at the Bureau of Mines are not
convinced the Moose drainage concludes in the East Camp. D~sions based on location of this
divide should be questioned.
.
. Concltion of buJtheeds between east 81d West Camp is not known; yet EPA Plans to rely in
perpetuity .on these concrete baniers to keep water at higher elevations in the West Camp from
breaking through to the East Camp and flowing into the Pit
. Cones of Dep-ession influences not proiected: The Berkeley'Pit cone of depression, combined
with the one being aeated by the East Continental Pit, may create an exponentially larger cone of
depression that can have enormous effects on ground water under neighbcri'loods not yet affeded
by contamindon CI' dewatering. loss of stream water near the County Club would affect
landowners there. Owners of homes built on formerly swampy land that dried after th,e Berkeley Pit
began operating in the 1950's (e.g., Sl Ann Slreet) fear that saturation of the bectod(~quifer may
bring an influx of alluvial water to loed basements: Projeded mining company Plans should be
investigated to determine their potential to affed Berkeley Pit contaminant g'ound water rnigation.
Without contingency Planning, at some point, conlrol of Mine Rooding waters could be lost.
The area of inftuence of the Berkeley Pit cone of depression is said to take in me entre East
Camp, or about 90% of the Mine Flooding OIU. The pUblic was never ;ven dear. scientificalfy
sound data to explain EPA's position that the cone of de,ression's influence extends throu~out
mine tunnels that are lower than the surlace elevation of the Pit water, fet alone beneath the bottom
of the Pit. fn fad, the gradent into the Pit is unknown below the surface of Pit water.
12
...
"
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. Impa~s to aUuviai aquifer hrgefy ignored: Other than concern fC( migation of contaminants
~om the Pit, EPAlDHES have either assumed the alluvial aquifer will not be impacted by rising,
ground water. or they do not feel it is relevant to the remedy. Ted Duaime states that when the
Eu~eaL: d Mir,es pr:';ided the Agencies with its opinion 01 the safety of the bedrock ac;uifer for the
;:'referred Plan. they were not as~ed to give an opinion on hyd-ologic impact to the alluvium. While
they have no data to refute safety of the 5,410 elevation fa the bedrock aquifer. they have no idea
how the alluvial aquifer will react to having a saturated beaock aquifer. .A~ain, there is a possibility
01 wet basements.
. ~duced infiltration potential is not adequately adctessed in the documents. Can contaminated
water from the hill a the cadmium plume beneath the old Silver Bow Creek bed travel south and
contaminate private wells? If a new induS1ry requiring high volumes of ground water came to Butte,
could ~ pull contaminated water toward other wells?
. Potential Mne J:Jooding-refated w.1 b.,s w..e not des1y delineated. Though well bans were
alluded to in tI. . I .), in meetings held pria to the end of the public comment period fa this OIU,
there was no information about where such bans might be enacted, nor about any private wells
possibly being dosed. ConsequenUy, affected residents could not comment on potential well bans.
Some add-esses of private wells tested are listed in the RI. In May, after dose of 1he comment
period, a GIS (Geographic Information Systems) map was shown to members of the County Water
Quality Task Face, delineating contaminated alluvial aquifers. Two adctesses listed in the RI as
having exceedances of cadmium. among other metals. are outside the mapped boundary of anuvial
contamination (1920 Elm, 1940 O'8gon). It appears that data are still incomplete er inacCU'ate and.
unless they are contacted individually, residents will remain unaware of any potential dosure or ban
on new wells.
EPA,'s Preferred Plan either assumes community acceptance er, as implied in the FS. a County
zoning ordinance may implement ARCO-initiated well bans on J:r1vate p-operty. An ARCO-County
contact calls for Institutional Controls such as Superfund-rel~ted well bans. Under it ARCO
provided seed monies fa the County to establish a task face to recommend whether er not a
Walter Quality District should be famed to deal wi1h post-Superfund well bans among other issues.
After close of the comment period, the tasle force was shown the contamination map, but it was
stated that no residential wells were expected to be affected. Without site-specific infamation, the
community could not possibly have commented on well bans during the comment period fer
.community acceptance. aiteria.
"
'.
. . Adequacy of stlleles is questioned by Dr. Bob Robins, an international expert on arsenic chemistry
and environmental impacts of mine wastes. Dr. Robins' maia points are:
" The Compreb...sive Monitoring A'owam 8should have been in place befere now.."
" Geod8emistry Ind hyct-ology are not completely understood at p-esent
" Sedim...t IlUdy of the Pit is needed
" Slrong mic:robiofo~C8I study should be induded in the comprehensive monitoring Jl'C9'8m
" A complete... balmC8 on the whole Pit system is needed.
Dr. Robins states that data are not available to show the influence of the ground water on deep
gound water. He does not believe a suggested upflow of deep goundwater from the bedrock into
the Pit is realistic; rather, he believes a downflow of Pit water will be present
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2. l.egal- UnwCIT~ted Waivers of EPA's CWn Remedy Selection Oiteria
.. Short-Term Effects
" An inaease in contamination volume, toxicity ;wtd mobility from !oday's 25 billion gallons to
56 billion in 2022 is certainly notable.
" ~mpounding between 25 and 56 billion gallons of surlace water in a toxic s1ate over me next 30
years adversely affeds in~eam flow.
" ~"'assive impoundment may adversely effect potential uses by water rights holders. The
C:ark Fork River Basin is closed to new water rights because it is so shcrt of water; yet, here
water would be impounded and made severely contaminated.
" Berteley Pit water impoundment aeated by the Preferred Plan should have a beneficial
use. None is evident. Pit water is not used by the actve mining operation. It is suriace 'Waters
0; ~e State 01 Montana" and should not be allowed to become more contaminated.
"Technical expertise 81d site1pecific knowledge would now be una.lable at remedy
time 30 years from now (due to human life span), requi"ing high cost 01 educating new players
and higher potential for error. .
" Short-term disreg..d for intent and meaning of the 1erm -deem up: as in .Superfund
Clean up" vs. generation of a 56 billion gallon toxic lake. Preferred Plan is a postponement. not
a clean up.
" Nothing is detmed for 30 yeWs.
.
. long-term Effectiveness:
" Perpetual effectiveness of a lowered Pit level was not a~ately rese.-ched due to
assumption of excess cost (statement in Preferred Plan document).
" Cost of Preferred Pf81 may be underestimated: At under $60 milfion, it is less than the
repated cost in 1973 01 the pumping Plant in the Kelley Shaft which is now underwater.
" None 01 the alternatives adctess what will occur aft. 30 ye-.n.
" None 01 the alternatives discuss life span 01 the pumping cmd tresting system and Acts 01
God. etc. that might interfere with operation in perpetuity.
" Use 01 the metro sewage Plant to rrest contaminated water from West Camp t.lne
Aoocing disregards Long-termeffeC1iveness reequirements
. Water Ouality ARAR's (Applicable Relevant cmd Appropriate Regulations) for Travona Mine
exceedances and for bed-oct aquifer cischarges to Silver Bow Creek we not met.
. ReciJdion of Volume. Toxicity and Mobility is ignored by allowing the doubling 01 PIt water
volume, inaeasing toxic contamination and allowing water to reach the 5:410' elevation.
. TIrea:t of Contamination ReI... is inaeued. n01 reduced. at 5,410' level tkou~ potential
energy 01 that volume, and weight 01 contaminated water seelcing lower JreSSU'e au.ets.
. Visibility stand.... of the a.. Air Act were not investigated fer fog emmanating tom the Pit
and its effect on safety of auto and ai"tafflc.
. Assessment 01 negligibfe impact to wid.. fowl resting on the Pit Wit.. renes on inadequate
amount 01 research data and does not project impact when Pit is 500 acres and near surface lev,1.
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. New remedy sefection aitEf'ia deyeloped: AvoidiW\ce of litigation with FR?"s joins cost to
drive CtS1 up decisions. EPA re~esentatives have stated that ARCO threats 01 litigation
prohibited them from changing their preferred remedy.
. Community Ace eptiW\ce - k1adequate communication with the public: E?A assumed that
citi,ens would spend who!e evenings at technical meetngs to learn about ~e Pit clean up Preferred
Remedy. They assumed the media would accurately present the sttry to the public even though
KXLF-TV reporters immediately complained (January 27 presentation to Butte-Silver Bow County
Commissioners) that they did not know how to repcrt on the Pit flooding when they were unable to
understand it themselves.
EPA meetings emphasized diversion 01 H17seshoe Bend water, which is only a smaD part of
clean up. They downplayed Pit water rising f17 30 more years - the only thing most folks really care
about. It took two 01~! three months of the comment period fer crec and Coalition members to
anain a fair understanding 01 tJ:Ie phenomenal amount 01 data released simultaneously on Januar.y
27 for public comment. and questions continue to be asked. The Coalition wrote EPA asldng that
they communicate on the few areas of goeatest concern to the comrTlmity, using p-epared television
messages and talk show appearances. EPA used the no cost shows, but the message continued to
divert attention away tom delayed dean up of the rising Pit. People w... surprised to 188'n the
truth about the Pit from Coalition and CTEC media interviews and from CoaJition telephone pon..
ads. handouts. posters. speeches and events. A petition ci'culated by the CoaJition was signed by
over 10% 01 County residents through littfe mere than ttv'ee days effcrt. Whatever comment EPA
received prior to the end 01 the official public' comment period is undoubtedly slight comp..ed to
what it would have been if EPA had tuly valued public input EPA stated at the outset that they
would not change their Preferred Plan without solid technical or legal reasons to do 80: 1hereby
shutting out comment from all but a small elite STouP of en;neers and mining professionals.
Affected residents' opinions were not considered wc:rthy by EPA. EPA wrongly assum.the
public has the time. money 81d expertise 10 technicafly chllienge . A'eferred Plan they do
not accept.
3.
. The Coalition believes that hyctoxide p-ecipitation should be eliminated tom consideration
immediately for lack of effectiveness. It would either inefficiently rKeet the same minD.
p.-p&tullly (Pit cisposaJ) er. generate a new SUperfund toxic w8lte lite with only 51£ to 7-J.
less waste volu me than the enginal volume befere 1reatmenl Inadequate consideration was 9ven
in the saeening phase to ok effective t'etdment tec:hnoloj_. apparen1fy because cost was
given ~edominance over effectiveness. The cost estimllling p-ocess reUed on on. individual'.
"best guesses,. 80me of which have been challenged as artificiaUy hi~. The review dd not
comprehensively evaJuate alternate combinations 01 trl8lment phae8. ARCa stat.. new
. - technologies are welcome only if they cost lesa1han the1eOO.s-era Orne u-eatment.lendng "e
impression that EPA weights cost more than other aiteria. Ultimately, the people of Bulle mult
tate on the burden 01 finding the most effective, cost-sensitive technology. EPA must rescind
their choice of lime teatment and insist that ARCa and Montana Resources accommodate public
and private rese..ch by proviclng on-site accesa to Pit and Mine Aooding watn and indemnify
those puraling solutions today.
-------
4. Inflow Control
. Inadequate Pfan fer diverting clean water inflow from J.fne FToocfng and Pit: Horseshoe
Send's 2.4 mgd of acidic water is ~e oaly inflow to be diverted from the Pit and Mine Flooding in
~~e F=~eferred Plan. Approximately 2.5 mgd of clean water is leaking from 111e municipal water
sys:em. but was ignored in percolation ass~ssments and remediation Plans. Precipitation runoff
from the Bute Hill has being diver.ed to the East Camp/Pit under Expedited Response Action by
E?A. Water presently runs down ihe Moose ctainage and settles on top of the C?i"een Mountain
. mine shaft which is inadequately cevered. While siorm water runoff is part of another DIU, the
above ~amed waters are part of, cr are purposely being diverted to, the MineFlooding DIU by EPA.
. These and any other controllable inflows should be c!eaned and discharged under the Mine
Flooding O/U rather than waiting many additional years to be adchssed under Priority Soils.
5. Human Health Concerns:
..Q-gcrlic contamincrlts under leach peds not adcressed in RJ..fs or Plan: Former Anaconda
Company employees have indicated that the dumping gounds fer Company-generated
contaminants are now covered by leach pads in the active mining opera~on. These contaminants
in dude solvents, acids, used grease arid oil, and other crganics. Given the gradient toward the
Berkeley Pit from the leach pads, these contaminants are likely to be entering the Mine Flooding
system, yet. have not been investigated in the RI-FS. The Agencies have assumed that the
contaminants are diluted and, therefore, not significant. Mere likely, they are DNAPl (dense non-
aqueous phase liquids), seek low elevations, and have sunk to the bottom of the Pit
. Air Quality investigations were not conduded in the RI. Studies in the latter part of this cent\6y.
have shown that human health in the headNaters of the Clark F crk River has suffered from long-
term disease designations of "highest in the nation per capita" fer "aJl diseases: 'ung dsease" and
"heart disease." as cited in Luoma and Mocre's 1990 paper1 . A high incidence of lung cisease was
found in women as well as men, indicating air quality problems out~ide of the mines. There..e no
very recent studies, so it is not known if high incidence of disease continues. If disease is related to
metals particulate, should sources of dust, such as Pit walls. be seaied or capped? Regardless of
the water level ultimately left in the Pil there would still be bare soil. EPA's RI also did not address
citizen inquiies listed in a 1990 Mine Flooding Responsiveness Summary concerning possibility of
toxic gas emanating from rising toxic mine and Pit water. .
6. Future Discounted
1.
.'
'0
. lnadeCJJ8Ie consideration for perpetuBl technology requirements, op.idion ..d
maintenlnce: Given the comparatively short 20~year histcry of the United States and the
burden of pumping and teating water fcr,ver, EPA's Preferred Remedy appe..s not to have
MficienUy weighed the following assumptions: :. -
-I Assumes money wiD be available for perpetual operation and maintenance by aRowing
ARCO to eetf-insure farever; assumes this relatively young corporation will exist forever. .
1 ~azardcus Walles Fram wgHQle MeIaJ Emldicn: The Clark Fartc Walla CcmpI8JC, Mr," Johmie Mea.. 0Ipt. aI
Geaogy, Univ. c1 ttbrana, MssouIa and Samuel N. Lucma. U. S. Geaogical Survey, MInto Park, CA; V.J. Walsa\ (Ed.).
Proc:. 1990 cart Fen Riv8r Symposium, Manrana AcadlmY c1 Sci8nc:8s. p;s. 183-1.
-------
c. . 7'
" In sele~ng the remedy. EPA considers only the fi"st 30 yews' costs: yet. the remedy
would not be implemented until after tt1at 30 years. EPA assumes that dollars will be adequate
fa perpetual operation.
./ Assumes no eJrilquate impacts to the perpetuaJ/y operating treatment Plant
" Ciaiming to protect human health. this remedy mates it undesirable for humans to
continue to five in their tracitional homes within blocks of the nation '5 liI'gest body of
toxic wat..
. Vwiables thai could cause uncontrolled filling of the Pit in the futlre:
./ Assumes thlll mantaning the Pit at 5,-410 feet. only 50 feet below the problem level, is ...
adeqUale m..~n of safety. This allows only two years (at the current fill rate) fer future
generations to recover from Acts of War, Acts of God, economic, cr other disas1ers before toxic
water reaches the alluvium.
.J Assumes negligible e81h
-------
G3
DEPARTMENT OF HEALTH AND
ENVIRONMENTAL SERVICES
REPORT NUMBER R'TCIOO3
BUTTE MINE FLOODING OPERABLE UNIT
REMEDIAL INVESTIGATION I FEASIBILITY STUDY
Public Comment to Preliminary Draft Feasibility Study Report
,
I
I
. I
.
.
,
. t
. j
ROBERTSON TECHNOLOGIES CORPORATION
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~ - ."1r ,r. Iud. t07 v....-
~.... - j . Ii . ,ao HOI.by I".., 9",,,. ColuIII.
Y Robertson Technologi.. Corporation
c.-
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101: 604,"',"12
fa: .04,'" 4'"
April 27, 1994
Project Number RTCSOO3
The SuperfuDd Program
State of MontaDa
Depanmeat of Health aDd
EuvironmMlt.al Services
. StesrnhnAr Bloc:.k Building
616 Helena Avenue
R3Q2-Helena, MT 59620
AaeaboD:
Mr. James O. Scott
Environmental Specialist
Dear James:
RE:
BtrITE MINE FLOODING OPERABLE UNIT REMEDIAL
INVESTIGATION I FEASIBILITY STUDY
Further to your discussions with Rhino ROhrs, please fmd enclosed our report, as a public response to
the above mentioned feasibility stUdy. Would you please forward 'this document to the correct party.
Yours trul Y ,
ROBERTSON TECHNOLOGIES CORPORATION
~/fi16 ~
Andy MKG. Robertson, P.Eng.
Chainnan
AMG:ctw
b);::' ~ ~r,i~~'
[;Ii~t,.,,..~,, . J
ENCLOSURE
, ,
.:'. ~.~ ~ t:
Mo"t~~" ('::JM'- "',
J"O tor:'. ' _n ",.,
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Report Number RTC5003
BUTTE MINE FLOODING OPERABLE UNIT
REMEDIAL INVESTIGATION I FEASIBIUTY STUDY
Public Comment to Preliminary Draft Feasibility Study RepOrt
Prepared for:
The Superfund Program. State of Montana
Department of Health and Environmental Sciences
Steamboat Block Building, 616 Helena Avenue
R302 - Helena. MT 59620
Prepared by:
ROBERTSON TECHNOLOGIES CORPORATION
Suite 900 - 580 Hornby Street
Vancouver, B.C. V6C 386
APRIL, 1994
.(\
/
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REPORT NUMBER RTCS003
BUTTE MINE FLOODING OPERABLE UNIT
REMEDIAL INVESTIGATION / FEASIBILITY STUDY
Public Comment to Preliminary Draft Feasibility Study Report
CONTENTS
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . .
PROCESS DeJELOPMENT . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PROCESS TECHNOLOGY. . . . . . . . . . . . . . . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . . .
THE GYP-CIX PROCESS. . . . . . . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PILOT PlANT TESTING. . . . . . . . . . . . . . . . . . . . . . . . . , . . . . , . . . . . . . . . . . . . . . . . . ~
ReainLoading [[[
Regeneration of Loaded Resins. , , . . . . . . . . . . , . . . . , . . ; . . . . . . . . . . . . . . . . .
Cation R.sin Regeneration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Anion Resin Regeneration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . . . . . .
RESULTS OF PILOT PlANT OPERATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Resin Fouling. . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . , . . . .
Calcium Sulfate Scaling of Resin Beads. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Resin Capacity. . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . , . , . . . . . . . . . . . . . . . .
Resin Loss/Breakage. . . . . . . , . . . . . . . . . . . . . , . . , . , . . . . . . . . . . . . . . . . . . .
Product Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Water Recovery. . . . . . . . . . . . . . ... . . . , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMPUTER MODELLING. . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
METAL RECOVERY AND WASTE PRODUCT DISPOSAL. .... . . . . . . . . . . . . , . . . . . . . . .. 10
NEED FOR DEMONSTRATION. . . . . . . , . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . .. 11
PROPOSAL. . . . . . . . . . . . . . . . . . . . . . . . . . , , . . , . , . . . . . . . . . . . . . . . . . . . . . . . .. 11
LEGAL AND BUSINESS ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. """""'" 11
Patlm Status. . . . . . . . . . . . . . . . . . . . . , . . . . . . . . , , . . . . . . . . . . . . . , . . . " 11
Other Contracts or License Agreements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 2
Rob8n8oft Techncllc9.. co."o,.rion
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RTC5003 . Bun. Mine Roodine Qoer8Ol. Unot
TABlE 1
TABlE 2
APPENDIX A
APPENDIX Et
P8Q8 oj
TABLES
TVpical Feed and Product Water Concentrations. . . . . . . . . . . . . . . . . . . . .. 7
Plant Feed and Product Water Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . .. , 0
APPENDICES
Coat Estimates for Full Scale Application. . . . . . . . . . . . . . .. """"" , 4
Mine Water Treatment Project Cost Estimate. . . . . . . . . . . . . . . . . . . . . . .. 16
AobenlOn Technologie8 Corpor.tion
April. 1994
-------
BUTTE MINE FLOODING OPERABlE UNIT
REMEDIAL INVESTIGA TlON/FEASIBIUTY STUDY
PUBliC COMMENT TO PRELIMINARY DRAFT FEASIBILITY STUDY REPORT
INTRODUCT10N
Rob8ruon Tecn.''106ogi.. Corporation, by submitting this reaponI8, would like to raise public comment
regarding the BMFOU Remedial Inve.tigation/Feasibility Study Preliminary Drift Report compiled by
c.nonte Environmental Service. Corporation. The report id8ntifi8I eight pot8ntiaI tr88tm8nt
technologiea~which survived the initial screening prOCell. TheM treatment technologi81 were then
subjected to I treatability study and final screening.
The conventional treatment. for acid mine drainage i. correctly identified IS neutr8Iiu1ion ontv in the
report. moat often with lime, iind more specifically I twO .tage lime/limutone precipiUtion pIOC888
includinG HIItion.
This treatrnent reaulta in a saturated solution of calcium sulphate which is highly IC8Iing Ind which
poI8I1 Mrioua risk to subsequent polishing process... In this regard, the Hl8ction of re".,.. oamoai.,
as I primary candidate for the polishing technology, involves serious comptications.
Firattv, it i. neceaaary to include a softening process step in order to pretreat the effluent to prevent
scaling of the membranes. .
Furth8nn0r8, additional pretreatment in the form of pH adjustment, chlorination,. dechlorination and
filtration would be required in order to avert damage to the membrane surfaces and a corresponding
drop in performance, resulting in possible failure after only a short lifetime of dutY. All these factors
add a major incremental component to the cost of pretreatment and treatment.
In the extreme case, if pretreatment is not conducted correctly, it will be necessary to replace
membranea at frequent intervals, thereby incurring substantial operating. reptacement and maintenance
C08t8. In addition to this, the proce.. performs poorly, with low water recovery and product water
Quality. We ther8fore auggut that reverse osmosis i. unsuitable a. I polishing t1eltment step.
PROCESS DEVELOPMENT
We would like to introduce an ion exchange process that was developed in South Africa specifically
to deal with problematic chemical effluents arising from acid mine drainage situations.
An intensive research and development study was undertaken by JONnnuburg Consolidated
Investment Ltd. (8 JCI8). (a major mining company) at an operating mine, in order to addre.. this
Roben- Tec"'lOIogi.. Corpor.1io"
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RTC5003 . Bun. Mine RoocSine Oper". Unot
P888 2
specjflC probl8m. The initial approach taken for this study was simillr to that outlined in the feasibility
study dr.ft report.
Aft.. cONidlf'.t* experience had been gained with reverse osmosil technology on pilot scale it waa
finally rejected for the reasons given above. being mainly the addiUonaJ COlt of feed pretreatment Ind
membrane reptacement. Instead JCI concurrently pursued the development of I new technology, and
this hal now been tested exhaustively on pilot scale. Thil prOCNl is now It I technically advanced
stage, ready to be applied It full scale in a reference plant.
The outcome of this intensive R & D campaign is the newly patented GYP-CIX ptOC8II. GYP-CIX wu
specifically devetoped to overcome the problem of acid mine drainage by bulk dualination of the
effluent. Thi& had hitherto not been technically successful, due to the sCaling effect of calcium sulfate
or the COlt of pretreatment to get the solution i!'!to an acceptable Quality in order to deulinate by
reverse osmosis.
The GYP-CIX procell is therefore specifically designed to suit the trutment technology required for
the 8eIket8y Pit wlter. In the GYP.CIX process, the costalt8 held to I minimum by the use of cheap
and readily Ivailat* lime and sulphuric acid as reagents to r8Q8M11t8 the Inionic and C8d0nic ruinI
for recycling through the process.
PROCESS TECHNOLOGY
GYP.CIX technology is based on a continuous counter current ion exchange proce.. Ind has been
developed for the purpose of addressing the problem of calcium. lulphate satur.ted effluents. The
Feasibility Study Preliminary Draft Report states that -ion exchange w.. rejected because the same
level of treatment could be achieved with reverse osmosis, but at a lower COlt- .
This statement would ordinarily be correct for the polishing step only (not for overall treatment).
However, the novelty of the Gyp.CIX process lies in the use of altemative r~eneration reagents.
specifically lime and sulphuric acid, which are low cost reagents, used to regenerate the ionic resins
for recycting through the proc8ll. This innovation for resin regeneration has considerably reduced the
COlt of ion exchange treatment, so that the overall operating and maintenance COlt .re lower than
those of reveru osmosis, when used as a polishing step (which require. softening and other steps
mentioned .bove to reduce the plugging i"dex to within acceptable limitst.
The use of lime, only, al a neutralisation medium for acidic mine effluents results i~ I highly scaling
effluent that cannot be reUied as procell water and, if discharged to the environmem, results in an
unacceptably high salt load being discharged into the natural wlter cour... To date this method has
been the only solution for acid mine drainage, as the existing d8lliination proce.... available have
either failed technically or been too costly. The GYP.CIX procell has been developed specifically to
addrell the problem of saturated calcium sulphate effluents generated in the mining industry.
R~ Teoh.1CIIogiee CofWHIr.tion
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RTC!5003 . Bun. Mine Floodino ~r8b18 Urit
11808 3
The procua ilia limultan80ualy removes metals and othlf' dislOlved ult contaminants cOmmonly
praaent in ICidic mine effluenu and which are not removed to utisfactory levell by the current liming
method. Pelidual metals .nd radioactive contamin.nts, such II radium .nd ur.nium, land other
MnenU, e.g., strontium, arsenic and manganese' .re allO simultaneously reduced aubatantially,
usuallV to '-veil below that required by the Drinking Watlf' Standard.
The patented GYP.CIX procell has successfully shown th.t tM problem of pollution from acid mine
wat. can be controlled by the bulk desalination of the effluent at low coat. Thia has been proven by
tM operation of. 1 m'lhr pilot plant which has been tested and proved on ICtU8I mini w.t.. over
. period of aomI thrH years.
-
THE GYP~X PROCESS
The conventional ion exchange process for the purification of w.tIrI .nd the nonnIIl'8QUir8m8ntl fOf'
expenaive rNgemaauch II NaOH and HCI fOf' relin regeneration, II W8ll11 the und88irIbI8 production
of concentrated aotuble wllte products, is well known .net ia the I'8IIOf'I that ion exchange WII
r8i8ct8d in the Canonie repan.
We wish to pruent new technology that can be applied specifically to Kid mine drainage, including
a d81cription of the key factors of this technology, which avoida the problema mentioned, .nd which
make the GYP.CIX procell worthy of inclusion in a test progrlm fOf' both technic8 .nd economic
rlllOl'lS.
The prOCIU, which ;s continuous, uses counter current ion exchange technology (CIX) for resin
loading, while ruin regeneration ;s conducted on . batch basis. The use of sulphuric Kid .nd lime for
resin regeneration enable. . low cost approach to mine effluent desalination, which, coupled with a
high wit. recovery is an economic solution to the problem of scaling effluents.
The use of .lternative chemicals such as sulfuric acid and lime would present the lowest cost method
fOf' regeneration. However, the use of these chemicals has been .precluded in the past as a
conllQU8ftC8 of the practical problem. arising from fouling of the resin with calcium sulfate, eventually
reducing the uaefut life of the re.in to such an extent that resin replacement would become too
expenaive.
The problema UIOCiated with the use of these chemicals have been overcome by the use of . specially
d8lignld ftuidiaed bid that enable. the deliberlte precipitation of gypsum in tM regener.tion r..ction,
without fouling of the relin ion exchange bead.. The chemical reection. in the GYP-CIX procell are
shown in Fig. 1 fOf' the loading and regeneration step. of cation .nd anion resin. loaded with calcium
and sulphite respectively.
Roben8on "Irechnologi.. Corpor.tion
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RTC5003 . Bune Mine Roodine eperlble U,.t
P808 4
BESIH LOADING
KSIH REGENERA110N
~A8ftI-
I ~ ILUIUI\'
,..,
I'iqur. 1
GYP-CIX PROCESS CHEMISTRY
With the UH of the low cost chemicals mentioned above, the production of CJYI)IUm in the 18tun1tld
regener8tion aotution, and the unique propertiu of the expanded fluidiMd bed of rain to be
regenerated. the proceu has been successfully chemically engineered. It hu b88n ext8Nively tated
in long run t8ltl to prove fouling doe. not occur, and the ProcUl is now patented.
The production of gypsum during regeneration allows for the di.charge of the waate produet as a
slurry, thereby reducing disposal problems. With a high water recovery and hence, a low volume of
waste to be disposed, zero discharge conditions dre attainable.
PILOT PLANT TESTING
To evaluate the long cycle effects on the process. a pilot plant with a capacity of 24 m'/day was
commiuioned and has been operated successfully on acid mine waters from an underground mine for
almost three years. A flow diagram of the pilot plant is given in Fig. 2.
Re.in LoadinG
The feed WIt8r i. pumped to the cation loading section, where it flows by gravity through multiple
upflow fluidiMd bed contaetors or stages. The strong acid' cation resin (SACI i. airlifted between
stage. counter-cu"ent to the water flow. The number of stages employed depends on the
concentration of salts to be removed and on the level of purity of the product water required. The
decationized and decarbonated water is then pumped to the anion loading HCtion which contPins
multi.. fluidiMd ltagel of weak base anion resin (weAl. The mechanical operation of this section
il the same u for the cation loading section. The use of ftuidised bed. in the loading slction enables
unfiltll8d feed wlter to be used in the prOCISS. The flow of feed and product water is continuous and
unintl"Upted.
Roben8on rlchnoIogi.. Corvofllion
April. 1994
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ATCSOO3 . Bun. Mine RoodillQ Oper8ble Unit
11808 5
-
--
-
-
--
-
-..-
LJ
-
-
.
WIQUR8 2 GYP-CIX Process Flow Diagram
The continuous counter-current techniQue used for cation anci anion IoIdIng is W8I known,
commercially proven, cost effective and very suitable for the tratment of I8rge YOIurn8I of WIt8r. The
u.. of the horizontal loading cascade enables easy plant maintenance, while pI8nt c:omroI is f8CiIit8t8d.
Maintenance of the loading cascade can easily be carried out by bypuaing the panicular loading
contactor or stage, without interrupting the plant operation.
The resulting product water is at a neutral pH, low in calcium 1< 100 mgll) and sulfate « 250 mg/l)
and other heavy metal ions and is non scaling and meets effluent discharge specifications. It is possible
to engineer the process to produce a water Quality of Gold Book or Drinkino Wat., Quality Standard.
Aegeneration of Loaded Aesins
The novelty of the GVP-CIX process is in the resin regeneration techniQue and the plaMed production
of Gypsum II a IOIid waste product. A single stage batch regenerator is used. while reoenerants are
recycled to achieve maximum utilisation of chemicals.
Cation Rain Regeneration
The fuUy loaded cation resin is airlifted out of the loading section into a batch regenetltor, where it is
contacted with a 5 % sulfuric acid solution, seeded with gypsum crystals, which is recirculated from
a stirred tlnk. The acid strength in the regeneration solution is controlled by a conductivity controller,
linked to a concentrated acid dosing pump.
RobenlOn Tech.1OIogie8 Corpor.tion
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RTCSOO3. Bun. Mine Flooding Op.,.... Unit
P808 e
The solubility of caJcium aulfat. is low and as soon as the sOlubility limit is reached calcium sulf.t. will
precipitate.. gypaum. The precipitation of gypsum is enhanced by adding gypsum crystals as Sllds
to 8Ct .. ~ nude; to avoid the formation of supersaturated solutions.
When the ruin rlOtnltation is compl.ted, the precipitated gypsum slurry il wuhed out of the resin
bed by a clarified ov.rfIow from the settler. The gypsum precipitate is conc.ntrated in the settler and
discharged from the settler underflow as a thick slurry.
The wuhed resin il tranlferred to a resin rinse vessel. where the rlOener.tion sotution is rinHd from
the ruin por.. using fr88h feed water. The resin rinse can be conducted' on the twice uHd principle
in I conventional Picked bid in order to conserve rinse watll'. The rlOener.ted and rinHd resin il then
returned to tt\8 product .nd of the cation loading section.
Anion R.1in Rea-.r.tion
The rlOtnII"tion of the loaded Inion resin is achieved with lime. To overcome the low sotubilitv of
lime. 2" lime alurry is used, which is again seeded with gypsum cryltal8. This aIurry is recirculated
from . rlOtnltlnt tank, in which the strength of the lime slurry il controlled by . pH control" that
is UMd to dose 10 " lime slurry from a bulk regenerant tank.
The anion regeneration also produces gypsum which is removed from solution by settling and finally
discharged 'Iaalurry waste. The continuous precipitation of gypsum in solution in both the anion and
cation lICtions, allows the regen.ration solution to be reused for subslQuent regenerationl without
a build up of the stripped ion in solution, which further l":1inimises reag.nt consumption.'
Th. Inion rlain is washed using clarified overflow from a settler to remove precipitated solids and is
then rinsed using final product water in a similar fashion to the cation resin. The freshly regenerated
resin is then returned to the anion loading section at the product end.
~ESUlTS OF ~!LOT PLANT OPERATION
The feed WI. to the pilot plant consists of acid mine water from a producing mine pumped from
und.rground, which has been limed and clarified. The feed water hilS the typical salt concentration
given in Table 1:
Robe"80n Technologi.. Corpor.tion
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RTCSOOJ . Bun. Mne Flooding 09.,8111. Unt
pege 7
TABLE 1
Typical Feed and Product Water Concentration.
PII8MtI' FEED PRODUCT
TDS 3000 moll 500 man
TSS 25 NTU 25 NTU
pH 6.8 6.8
~um 500 mOll < 50 moll
-
Magnesium 1 00 moll < 20 mgll
Sodium 400 moll < 100 mgll
Potauium 10 moll < 5 mall
Sulf8tl 1200 mOll < 200 mgll
Chloride 250 mall < 50 mglt
Nitrate 60 moll < 10 mgll
Phosphate 5 mOll < 1 mall
Ruoride 1 0 mgll < 5 moll
Alkalinity 200 mall < 50 mgll
Radium 30 pCll < 1 pCIl
Uranium 1 000 ppb < 20 ppb
Re.in Fouting
Irreversible resin fouling by iron, silica, and organics would add substantially to the operating cost and
limit the desalination performance of such a process. After the equivalent of one year of continuous
operation, no detrimental signs of resin foulin
-------
ATCSOO3 . ...n. Mine Flooding ~8bIe Unit
peve .
Calcium Sulf818 Scaling of R.sin Beads
Elecvomic:rograph .xamination of the resin beads show no pr...nc. of ~lcium sulfate either on the
surflc:e or inside the b8ad8 Ifter 500 eycl.. of loading and r8Qeneration.
R.lin Capacity
Th. total ~pacitv IFigl. 3a & 3bl aa well as the loading kinetics IFigl. 41 & 4bl for the rain beads
W8r8 t88t8d 8t regular intervala and no drop in performance W81 noted. The working C8P8City of the
strong acid cation r88lf1 W8I tYpically 55% and for the weak bale anion rain 85% of the tOt.II capacity
respectively. The.. valuu ar. typical for continuoul ion exchange proc......
Tea.
SAC VI No.
T* c....- WBA. No. ewa-
I
J.
J
I
I'
J
I
..I
.....
i
,. - - - - - - - - -
C\G8
Total Capacity SAC
I
81
.......---------
C\G8
PIOURB
Resin
3.
7101mB
Resin
3b
Total
capacity
WBA
Relin Lo..'8r88klge
On average the rate of resin loss due to breakage. of beads was about 10% per annum for the
macroporoua atYrenic cation resin and approximately 5% per annum for the acrylic anion resin.
The higher 10.. for the cation reain wal as expected due to the bead having less resistance to anrition.
Thil re.in loa is normal and well within the limits for counter-current ion exchange applications.
KIn8b 01 SAC fat U88d I8Iin
'-
.... --
----
- ~--
----
- I
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RTC5003 . Bun. Mine Flooding ~r8bl. Unit
P898 .
Product Wat...
The tYpical plant prodUct water analysil is given in Table 1. In addition to the low levetl of calcium
and sulfate, a signifICant reduction in radioactive elements IUch .. r8dium and uranium W88 achieved.
Ruidual metaJ valuel, such al iron and manganese were also removed to low lev'" in the plant.
Water Recovery
The pilot plant 8Chi8ved an average water recovery above 90 %. Thia figure could be funh8r improved
if rlCYcle of waite lupernatant il employed.
COMPUTER MODEWNG
A computer model hal been designed, based on data accumulated from the pilot plant study. Thi.
model h8a been found to 'simulate the performance of the pilot plant ICCurat8ly. The computer modal
;,.. been run for the full scale application for 2.40 and 8.~8 mod on H0t88 Shoe BInd 8nd B8rbI8y
Pit wat. anatv... supplied in the Canonie Environmental 'Treatability Sampling and B8nch8caI8 T8I1ing
Report', in ord. to I"''' the reagent requirements and technical performance daU. where the
operlting COlt comparilon is important.
The GYP-CIX plant requires a minimum of pretreatment, only liming of thl effluent to pH 10.2 is
considered neceuary, as per test work conducted by Canonie Environmenul Ind the Manuna State
Department of Health and Environmental. The other requirements of feed filtration, pH 8cfiuatment and
chlorination Ire not critical and may not be necessary at all.
The wlter quality Ifter liming to pH 10.5, the required feed to the GYP-CIX plant and the water Quality
after treatment are given in Table 2.
The prodUct water from the GYP-CIX plant will meet Gold Book criteria and hence no fumer treatment
would be required.
It il sugg88t8d that the wlter QuaJity achieved will be sufficient to reuse the wator as a potable water
Quality r8lOUlCl. The water can also be reused as process water or II a drinking water supply for
which I doII8r vII'" can be determined to cover the cost of treatment and, depending on local water
COIU, should offer a profit margin.
The model predicts that a water recovery in excess of 92 % can be achieved, however this can be
. .
further improved if waste recycle is employed.
Robert.on Technolo9i" COFJlOr.tion
April, 1984
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RTCSOO3 . Sun. Mine Rooding Oper", Unot
D808 10
TABLE 2
Plant Feed and Product Water Quality
Parameter FEED LIMED pH GYP-CIX
10.3 PRODUCT
TDS 4500 mOll 500 mOll
TSS 25 NTU 25 NTU
pH 10.2 8.8.5
Calcium 1220 mOll < 150 mgll
Magnesium 1 7 mOll < 17 moll
Sodium 73 mg/' < 70 mgll
Potassium 7.5 mgll . < 5 mgll
Sulfate 3147 mgll < 500 mg/'
Chloride 25 mgll < 25 mgll
Nitrate 26 mgll < 10 mgll
Alkalinity 100 mgll < 50 mgll
METAL RECOVERY AND WASTE PRODUCT DISPOSAL
Due to the low concentration of base metals in the Berkeley Pit .water and the low commodity value
of these metals. no economic opportunity for recovery of valuable metal products would appear viable.
Therefore the technology to recover metals has not has been examined. The metal values would report
to the sludge al a precipitate. The water that can be recovered from the Pit is considered to be the
most valuable commodity and it is here that efforts will be concentrated to recover economic value.
The only waite product produced by the process is the gypsum sludge generated in the regeneration
reaction. Approximately 415 000 gpd of gypsum sludge will be produced by the plant. The gypsum
sludge ia a highly immobile salt form. due to the very low solubility of gypsum in water. The gypsum
sludge can be filtered to a moist cake, if required. and disposed to a scheduled site. where it is
anticipated that an impoundment liner will not be required.
Robe"lon'T8chnoIo9i" COlDor.tion
ADnl. 1994
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RTCSOO3 . Bun. Mine Rooding ~I8bIe UniC
P808 11
The wet gypaum sludge from the underflow of the regeneration clarifier can be disPosed of directlv
back into the pit. if acceptable, where it would not resolubilise. This would be a very inexpenatve
option for diapoaal.
NEED FOR DEMONSTRATION
The novetty of the GYP.CIX technology lies in the use of alternative cheap reagents. sui ph uric acid and'
lime for regen8IItion of the ruin, thereby limiting the overall tr..tment COlt. The co.t of rugents
contributu more the half (70 '!fI1 of the final overall treatment COlt. The procell producu I solid
wllt8. which conatderablv ..... disposal problems. Many other novel ISP8Ct8 are included in the
detait of the procell design, and a complete systems approach haa been adopted.
The proc... has been fullv demonstrated on an integrated pilot plant operation over three yur.. Thi.
operation WII successful in that no fouling of the ion exchange resin waa observed and the plant
performed within the design parameter.. It is therefore considered that an IdditionII pilot ptlnt atlge
iI not required Ind that the proc... i. ready for commercial apptication.
It il. however necessary to introduce a reference plant. so that the technology cln be demon81rlted
on I large seale to successfullv desalinate acid mine water. The Berkeley Pit water limed to pH 10.2
is ideally suited for the process demonstration.
PROPOSAL
We propose that a full feasibility study be commissioned for a GYP.CIX reference plant to be
constructed to demonstrate the technology on the Berkeley Pit water.
This feasibility study could include Horseshoe Bend water. the alluvium or run off water to delav the
time that the Critical Water Level is reached.
LEGAL AND BUSINESS ISSUES
Patent Statu.
Johannesburg Consolidated Investments Limited is a publicly listed company in South Africa with
diverse interests in gold, platinum. uranium and coal mining as well as commercial and industrial
ventures. They are one of the five large mining groups with an asset base in excess of $1.000 million.
Chemical Effluent Treatment Process (Pty.1 is a wholly owned subsidiary of JCI.
Rob.neon TechnolOQi.. COfllOI.rion
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RTC5003 . Bun. Mine Roodlng 0cI.,8DI. Unit
P8e8 1 2
Thl'Technotogy for thl GYP.CIX process is the propertY of:
CHEMICAL EFFlUENT TREATMENT (PTY.) LIMITED ICHEMMEFFCOJ
Cnr. Fox . Harrison Streets
Johannesburg. South Africa
A patlnt for the proprietary technology used in the GYP.CIX proclSl h.. blln granted in South Africa.
A patent hu b88n applied for in the USA. This patent application hu beln .'Iowed.
Othlt Contr8Ct8 0# Ucen.1 Agre.ment.
ROBERTSON TECHNOLOGIES CORPORATION is the exclusive licensed distributor of thl GYP-CIX
technology for Canada. the United States of American and Mexico.
Robenaon T IChnologies Corporation is a 100 percent owned subsidiary of Stiffen. Robertson and
Kirsten International Group of Companies, an international mining. glOtechNcaJ and Invironmental
consulting group. In thl USA. SRK has branches in Reno. Nlvada; Denv... Colorado; Redmond.
Washington; and Columbia. South Carolina.
This report. Project Number RTC5003. Butte Mine Rooding Operable Unit Remedial
Investigation/FeasibilitY Study, has been prepared by:
ROBERTSON TECHNOLOGIES CORPORATION
1!u4~
I
Andy MacG. ~c:.ar:~-:;.., ~ .:"W,
Chairman
RoOen8Ofl T8ChnoIoei.. COfJ)or.tion
-------
~
.l~it~;fi~LP,~J,;,
~ .:. ~:l. ,-
APPENDIX A
Colt estimate for FuU Sca88. AppDcadon
. ." ',-~
.""'.'
. '.:.::.",i
. .':",
':',,,,
""'.: :'...', ,"',' ..t~'
": .~...: '.') .
'..... ".
."....,
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RTC5003 . Bun. Mine RoocSing ~r8DI. Unot
P888 1 4
APPENDIX A
Cost Estimates for Full Scale Application
FUll SCALE COST ESTIMATE
The cost estim~te is based on the designs and cost estimates completed for four different plant sizes.
From these estimatel a regression formula was derived. whereby the capiUl COlt of the plant could
be estimated for. any plant size and any salt load. Furthermore. the capability existl to do design
studies and COlt estimatel for any plant size for any application. where the fHd and capacity can be
defined.
OPERATING COST
The operating cost has been estimated using the available commercial information for the COlt of
chemicall. power. labour etc. The operating cost has been estimated as foilowi. broken down by
subheading:
1.
Chemicals 2.40
Sulphuric acid (6.8 kg/m31 $ 50lton
Lime (4.8 kg/m31 $ 60lton
Resin replacement 0.18
Cation resin $ 2000 1m3
Anion resin $ 5000 1m3
Power $ 0.04 /kWhr Q..!S.
TOTAL $/1000 US gal 2.77
2.
3.
For 2.4 million gallona per day (gpdl this amountS to an annual cost of US $2.43 million pa. This
estimate excludes the COlt of newalisation pretreatment.
Labour for the plant can be provided on a shared basil with 0"' operator and one supervisor required
per shift. The maintenance COlti are likely to be low al the plant consiltl primarily of tanks. pumps
and valv...
Roben8Oft Technologi.. Corpor.tion
-------
RTC500:I . Bun. Mine AOOGlng Oper8Ol. U,..t
P8G8 I 5
CAPITAl COST
This figure includea allowances for the following items:
.
.
Full hardware inventory design. procurement and erection;
All computer software to run the plant;
An initial resin inventory; and
Engineering design.
.
.
The total cOlt of the complete 2.4 million gallon per day installation would be approximately
US $7.0 million without contingency. This order of magnitude cost estimate has bien verified by an
independen~ ':ost estimate by Kilborn Engineering Pacific Ltd. which is included in Appendix B.
-
This estimate js an order of Magnitude estimate IOME) and is accurate to with + 25% . 10%.
The total cost of the complete plant for a total of 8.48 million gallons per day would bI approximatelv
US $10.0 million.
Rob.n80n Technologi.. COrDOr.llon
Alp"l. 199.
-------
APPENDIX B
Mine Water Treatment Project
Order of Magnitude Cost Estimate
by
Kilborn Engineering Pacific Ltd.
-------
1.0
CAPITAL COST ESTI~IATE
1.1
CAPITAL COST SL"fMARY
The estimated initial capital costs required for the proposed plant are S 8,473,000.-
This figure has been rounded to the nearest thousand dollars. Details of the estimate are
presented at the end of this section.
The estimate was prepared for RobertSon Technologies Corporation (RTC) by Kilborn
Engi"neering Pacific Ltd. (Kilborn). The opinions, judgements and assumptions provided
herein are based in part on information provided by RTC. While Kilborn has used itS best
effortS to p:"'wide relative costs based on the information provided, It should be understood
rhat this is considered to be an Order Of Magnitude Estimate with an accuracy to within
= 25% at the summary level. All costs are expressed in second quaner 1994 US dollars
without intlation allowance.
1.2
BASIS OF PRELI'fI~ARY ESTIMATE - I:\TITIAL CAPITAL COSTS
1.2.1 SeoDe Definition
The work scope for the capital cost estimate is based on preliminary drawings and quantity
take-offs from a similar plant in South Africa, adjusted to climatic conditions in Butte,
Montana. Kilborn has allowed for a pre-engineered building over the process area to
prevent freeze-up in winter and to protect drives and motors. Battery limit is considered to
be the fenced area shown on Drawing HBA 130040009 REV A. "
The estimate covers capital costs beginning with the start of detail engineering and
continuing until the completion of the initial construction and start-up of the facility.
1.2.2 Material Ouantities
Equipment sizes & quantities as well as quantities for construction materials were extracted
from the quantity take-off provided by RTC for a similar plant in South Africa. Kilborn has
added a building over the process area. Where it was not possible to develop quantities
from the information provided, allowances were made based on Kilborn's experience on
similar projects and adjustments were made to reflect the most current information on this
project.
KILBORN
-------
1.2.3 Pricine Basis
Unit prices for constructed facilities were developed based on Kilborn's experience on
similar projectS and adjusted to this project scope, location and date.
All equipment and materials are assumed to be purchased new.
1.2.~ Labor Rates
For the purPose of this preliminary estimate the average composite project labor rate is
assumed to be $ 35.- per hour. This includes supervision, small tools, overhead & profit and
is based on a standard work week of 40 hrs with no allowance for overtime.
It is assumed that all work will be done by qualified Contractors on a continuous
construction program with no work interruptions.
1.2.5 Construction Indirects
The estimated construction indirect costs cover:
Contractors' mobilization and demobilization;
Contractors' bonding and insurance;
General site costs and clean-up requirements;
1.2.6 En2ineerin2. Procurement and Construction Mana2ement
The cost for engineering, procurement and construction management is factored on the
direct costs for this project based on average costs for these services.
1.2.7 Contin2encv
KILBORN
-------
Contingency is included in the preliminary capital cost estimates at 20 % of total estimated
cost.
The contingency is intended to cover the cost of items included in the scope of this study
which cannot be specifically delineated at this stage of project development. It is not an
allowance for scope changes. or price escalation. In our estimation. the contingency
allowance will be spent.
1.2.8 Oualinc:Hions
The estimate is based on construction work being executed by qualified contractors mainly
through firm price contracts.
1.1.9 Exclusions
Specific exclusions from the estimate are:
Cost of financing and interest during construction;
Provisions for future expansion;
Specific exclusions as defined in the line items of the estimate details.
Primary po'-"er supply. substation and feeder to the electrical room.
Water supply to the plant.
Feed line of mine water to the plant.
Discharge lines for product water and gypsum slurry from the plant.
Any settlement or holding ponds which may be required.
Telephone system.
Sewage treatment and discharge lines.
Owners costs (such as management costs. land costS. permits. etc.)
1.3
INITIAL CAPITAL COST ESTIMATE DETAILS
The estimate details for the initial capital costs oegin overleaf.
KlLBOR.V
PAGE 3
-------
Kil~orn Engineering Pacific ltd.
IJ80 Burrard Street
Vancouver, B.C.
9999- 99
-.--- -. --.------ ----
AREA
ITEM
DES CHI P I ION
----....__.h
100 DIRECT COSTS
700 INDIRECTS
1100 INDIRECIS
YOO CONIINGENCY
--- --_.._--
. ..- ------------
MINE ~AIER IREAIMlNI PLANT
ORDER Of MAGNIIUDE CAPITAL CO~T E~IIHAll
fOR IONl/DAY PlANI NEAR BUTIE, MONIANA
MAJOR AREA SUMMARY REPORI
0.._____----
rolAl
MHRS
L AUOH
COST
----- -..- .--.- _..
- -.- .. --.. - _.
J2,\I~S
I, I~j,OIl~
o
II
o
II
o
o
- u_-.... - - --
------- - - - - -- -- '--'--
PROJECT TOTAL
-- _,_h- ----
--... --- ... -
.J2,9~S
1,IH,OIl~
MAltHIAL
COSI
2,2SII,/Y1I
{~lI,IIIIU
j,OOIl,/y13
-.-------
U Al'rt I \14
P"ge: 1
HUll 11111" : 11 :3.1: 13
C:SHI(.~T_1.D8F
-------- - -
~UULUNIHAI.:I
CDS!
rol Al cu~ I
II
1,121,bOO S,133,4133
I , I ,. { ,UOII 1,\l27,UIIO
U U
1,412, UUlI 1,~ 12,11110
II
~,i10,bOO
II,H2,4Ui
..-------.. ".- -
-------
KIlborn Engineering Pa,lflt ltd.
1380 Burrard Street
Vancouver, B.C.
9999-99
AREA IIEM
DES C RIP T ION
MINE WAIER TREATMtNI PLANI
ORDER OF MAGNITUDE CAPITAL COST ESIIMAIE
FOR 'ONL/OAY PLANT NEAR BUTTE, MONTANA
AREA SUMMARY REPORT
TOTAL
MAN HOURS
lABOR
COST
, ,
U A!JI'II 'I..
Page: ,
Run I line: 11: 33: 1]
C:SRK-WT_1.DOf
..------
MAI[RIAL
COSI
TOTAL COS T
SUIIWNlliAlI
COST
-.---- ----- .-. .----.- ..--'--- - -.n . _.-.- . -
~!RLC' COSTS
20 CIVIL 1,,1,13 I~I"I,~II ,..U, '1111 U NS,I,J6
30 STRUCTURAL AND IIUILDINIiS 1,03S 21,6,2011 ~OIl,~YS I , SU'J, uuO l,063,80J
SO MECHANICAL EQUIPMENT " SSS SI"I,25 JlC>,100 0 3110,S2S
60 PlATEWOIIC '1,,8S1 S19,1I1I1 116/, yIU 0 1,381,11111
10 PIPING 3,396 118,8S1 21S,91~ U ]]1,,112
'80 ElECTRICAL 1,690 S9,,1SU 111'1,300 0 2SII,I,SO
90 INSTRUMENTATION 0 II 0 1,1~,blJO 1,'2,600
SUB TOTAL J2,91,S 1, 1S3,OIl~ 2 ,lSII, IYIJ 1,/21 ,6UU S,IH,I,IJJ
IN DIRECTS
710 COIISlMABLES 0 0 ISO,UUU 0 I~U,UOU
720 CONSTRUCT ION INDIIECTS ° 0 0 JOII,UOO 308,000
no EPCM 0 0 0 119,000 119,000
740 STA.TUP & COMMISSIOIIING 0 ° 0 1S0,OOO 150,000
SUB - TOIAL ° 0 7S0,OUO 1,1/1,000 1,921,000
INDIRECTS
800 CUlER'S COSTS 0 0 0 0 0
SUB . TOTAL 0' 0 0 0 0
CONT I NGENCY
900 COIIUNGENCY 0 0 0 1,1,12,000 1,1,12,000
SUB - TOIAl 0 0 0 1,1,12,000 1,1,12,000
-------
KlllIum Engineering Pacific: U<.I.
1380 Burrard Street
Vancouver, B.C.
')999-99
~_._----
DES C RIP I ION
AICEA
IIEM
. "h. -. - ---
... .-----.-.-
MINE WAIER IREAIMENI PIANI
ORDER Of MAGNIIUDE CAPITAL COST ESIIMAIE
FOR IOKl/OAY PlANI NEAR 8UIIE, MONIANA
AREA SUMMARY REPORI
lOlAl
MAN HOURS
lA8UR
COSI
PROJECI TOI AI
..----.. --.--.--.------ -..-.----- ---.. --._-
- . - . . .
-----------------
.._--------- --
32,91,5
I, 153.08~
MAIEICIAl
COSI
3,UOII,798
, .
,!,! A~Jf'1l 'II,
p..ge: 2
11'"1 I lOll" : 11: 33: 13
C:SIIK-wI_1.DBF
-... -.--.".
SU8C11NIliACI
COSI
lOlAl cosr
4,HU,t-OU
8,1,12,1,111
-------
lCilborn £nyim,ering Pclcific ltd. MINE WATER IREAIMENT PLANT 22 AI" II Y.
1]80 8urrard Street ORO[~ f MAGNITUDE CAPITAL COST ESTIMATl Pdye: 1
Vancouver, B.C. . fOR IUMl/DAY PLANT NEAR BUTTE, MONTANA N"" 1111'" : II:H:II
9999-99 DETAil REPONT C:SNK WI. 1.0111
----.-. - ------ - - --- - "-. -.---. -----
COOE OESCRI P T ION on UNIT lA80R TOIAl lAIlOR MAIENIAl MATERIAL SU8CONIRACT SU8COIHRACI TOIAI
AREA ITEM UNIT MHRS MHRS (uS I 0 .UNIT (oS 1 COSI UNIT COST COST (OST
--- - -. '0---_---'------ --_._----- ..---. - . --- 0_____- -- - - -.-.--- --
Ulli
20 I.UU tNAUINt & CLEANING SURfACE AREA ",~"O Mo? U.U~U 101 ], ~&!H U.W 2,.!oli ~,lYc.
20 l.OU IXCAVAIE .2MD fOUNDS Bf M/C 210 H3 O. I~O jl 1,10j 4.UO Ii~U I, '1.1
20 3.UU IKTNA'UVEN 10 EXCAVAIE IN ROCK 28 Hj 0.4110 11 hi.! ~lI.UU ':.1011 y',:
20 4.00 EXCAVATE TM fOUNDS Bf HAND U') H3 I.4UO 311~ Jj, " I~ Jj . ~ I~
20 ').00 I')HPA ')0 HM THICIC BLINDING 14') M2 0.2~0 36 1,"6Y I1.UO I,W~ l,lIo"
20 6.00 2')HPA REINfORCED CONCREIE flOOR ON GROUND jO') M3 ').000 1,')2') ,)3,j/~ 209.0U 63,74~ III, IlU
20 7.00 200 HM BlOCIC WAll fOR CONTROL ROOM lY,) M2 1. 600 H2 16,~20 36.0U lO,62U l1, 14U
/ 20 8.00 DOORS, WINDOWS, fiNISHES, ETC. fOR CONIROl ROOM 1 5'" ]0.000 ]0 1,0')0 '),000.00 5,000 6,O~U
20 9.00 ]OHPA REINfORCED SUSPENDED CONCRETE fLOOR ]2 M] 8..000 256 8,960 2')0.00 8,000 16.90U
20 10.00 3UMPA REINfORCED CONCRETE WALL ')4 M] 7.000 ]78 13,230 240.00 12,Y60 26,1110
-------
Kilborn Engineering Pacific Ltd.
1Jao Burr8rJ Street
Vencouver, B.C.
9999- 99
MINE WATER IREAIMENT PLANI
ORDER OF MAGNITUDE CAPITAL COST ESTIHAIE
fOR IOKL/DAY PLAN I NEAR DUTTE, MONIANA
DETAIL REPORT
COOE
AREA I TEM
DES C RIP T ION
- .....--.------ - .----.- .--.------ .----.-
L ADOR
UNIf MHIIS
---
.. _0. - -----.
ZD
IZ.OU MS IN~lRTS & EMBEDDED STEEL
ZO
li.UO 20KHO x ~OO MM fOUNDATION BOLlS
ZO
14.0U SECURIIY FENCE SURROUNDING THE PLANT AREA NOT
INCLUDED
20
15.0U ~ASHIlOOH ALlOWANC~
ZO
16.00 ~IIELIMINARY & GENERAL INCLUDING SIIE LAYOUI AND
SURVEYING
STRUCTURAL AND BUILDINGS
30
1.00 ACCESS PLATFORM AND STAIRWAYS SUPPORT STEEL WORK
ASSESSED TONNAGE STRUCTURAL SUPPORT STLWORK
(LIGHT)
30
2.00 STRUCTURAL SUPPORT STEELWORK (MEDIUM)
30
3.00 OVERHEAD PIPE BRIDGE i 60KG/M MASS
QfY UNI I
TOIAt.
MHAS
.- .. --------
--" -- - - ___-n .-..
IABUR
COSI
MAIEIlIAL
UN If COS I
a AlJrll 9~
Page: 2
1111" I II lie : 11: 3i: 11
C: Silk -1/1_1.0Bt
MAIERIAL
COSI
SIJBCUNIAACI
UNII COST
IUIAI
COSI
SUBCONIRACI
COSI
2,700 kG O.U/U W<,I b,61~ \.,. I U,ILlO I~,II~
j/S NO O. SUU WU b, ~6i iU.ulI 11..!IJU 1I,!lIi
Z SUM I~U.OOO }UU 10,~UO ~,UUU.UU II,UUU I!I,~UU
1 SUM 500.000 ~UU II, ~UU I,~UU.IJU I, ~UO 2~,UUU
CIVIL TOIAL
4,413
14.0 TONNE
Z7.000
378
151.0 TONNE
Z4.000
3,6Z4
11.0 IONNE
ZZ.OOO
24Z
151,,1,511
13,Z30
2,ZOO.00
IZ6,81,0
2,100.00
8,HO
Z,OOO.OO
140,',1/11
29S, ~ ib
30,800
41,,030
317,100
1,i,J,940
22,000
-------
Kilborn Engineering Pacific ltd.
'380 lurrard Street
Vanc:ouver, B.C.
9999- 99
--.
MINE ~ATER TREATMENT PLANT
ORDER OF MAGNITUDE CAPITAL COST ESTIMATE
FOR 10Hl/DAY PLANT NEAR BUTTE, MONTANA
DETAil REPOIIT
CODE
AREA If EM
DESCRIPTIOII
-------_.
QTY UNIT
MA TEIII AL
COST
--.---.--
3D
4.00 PLATfOIlMS ~ALK~YS SUSPENDED a 6OKG/M2
]0
5.00 SIAIRS C/W HANDRAILING
30
6.UO EGLCRAIE fLOOIIING BUTDIP Aw3B 40.4.54""
30
7.00 IIANDIIAII GAlV. C/W TUBULAR BALL TYPE STANCHIONS -
990MM
]0
8.00 PAINT SIIIUCTURAL STEELWORK SB 1P.2EIN
30
9.00 PRE-ENGINEERED BUILDING ALLOWANCE INCLUDING
fOUNDATIONS, BUILDING, HEATING, VENTILATION AND
LIGHTING .
MECHANICAL EQUIPHENT
5D
1.00 PP-01 fEED ~TEa PUMP ACT. VOl 500M3 a 15M HEAD X
22 ICW
WATER PUMP 15D II 150MB C/W ]OI(W MOTOR
5D
2.00 PP-D2 DEGAS TOW£R PUMP ACT. VOl 500 H3 a ISH HEAD
HANDLING PH2 WATER
ACID PUMP 150 II 150NB C/W ]0 ICY MOTOR
16.0 TONNE
70 M
262 H2
aSH
192.0 TONNE
1,670 H2
1 YO
1 NO
--- ----- -- . .. -.-. -.-
LABOR TOTAL LABOR MAIERIAL
UNIT MHRS MHRS COST I. UNIT COSI
-- --.-------- -- -- .----. --
22.000 3S2 12,320 2,OOU.UO
15.UOO 1,050 3b,/50 I, UbU.OO I~. ZUU
l.uuO lbl "',I/U 'I~ .uu .!~.6YII
3.3UU 7~3 25,YU6 <'1.UII ", I.!.'.J
3Z,OllU
2.000
31\1,
13,1,1,0
2,611U
15.00
7,035
21,6.20B
508.595
40.000
40
1.400
5,500.00
5,500
40.000
1,400
6,500.00
6,50U
40
SUBCONTRACI
UNIT COST
..._--
22 Aplll Y..
Pdge: \
Mun IIRICO: 11:31:\1
C:SMK'WT_1.0Ut
.-...- ---------
SUBCONIUCT IOIAI
COS T (0$ I
"1.,j~1I
l1U, Y'".
j~.U(,"
3U,II \
Ib,j~"
IUU.UO I,3U"',OOO
1,3UY,UUII
1,3U9,OOO
2,Ob3,8U3
SIMUCTURAL AND BUILDINGS TOTAL
6.90U
-------
Kilborn tnglneering Pacific Ltd. MINE WATER TREATM~NT PLANT 22 AI''' I \I~
1380 Burr.rd Street ORDER OF MAGNITUDE CAPITAL COST ESTIMAIE P~ge: ~
Vancouver. B, C. FOR 10ML/DAY PLANT NEAR BUTTE, MONTANA lilli' I I nit! : 1':H;U
99I}9- 99 DETAIL REPORT C; Silk wi _1.0UI
--_. - -------...-.--..---. --------+-------. "'..- ... ....... ..---- --
CooE DES C RIP T ION QTY UNIT LABOR TOTAL LABOR MAIERIAL MAIERIAL SUBCONTRACT SUBCONIIIACf lOlAl
AREA ITEM UN IT MHAS MHAS COSI ,UNI I COSI COST UNIT COST COST caSI
------ ------.---.--- -----------... -.. -. --..----- -----"-
50 J.OO I'P'OJ I.AIION RINSE WATER PUMP ACT. VOL 100"3/HII iI 1 NO ~~.ODO I.~ I, ~ I~ 6,OOU.UO 6,UUU 7, ~/~
20" HEAD PUMI' 200 II 15DNB 5.5KW MOTOR
50 ~.OO I'I"O~ lAIION WASH PUMP ACJ. YOlo 25OM3/HA iI 12M 1 NO ~~.OUO ~~ I, I,) (') 6,UIIU.IJU b,lJUU I, ~/)
HEAD' ACIDIC WATER PUMP 11 ICW
50 5.00 PI'-05 ACID DOSING PUMP ACT. YOLo 1M3/HR iI 5M HEAD 1 NO 20.000 ~U lu,l 2,~UO_UU 2, ',1111 j,~UU
. CONCENIRATED ACID 98X H2sO4 DOSATROW ACID PUMP
50 6.00 PP'06 CATION REQEM PUMP ACT. VOL. 25OM3/HA iI 15" 1 NO 1,0.000 1,0 1,4UU ~,~UO.UO 5,~00 6,\lOU
HEAD' ACID SLUIRY
ACID PUMP 15ICW MOTOR
50 7.00 PP'07 CATION SLUDGE PUMP ACT. VOL 25 M3/HR iI 5M 1 NO 30.000 30 I,O~O J,OOO.OO 3,000 Io,O~O
HEAD HANDLING ACID SLURRY PUMP ClAIR DRIVEN
50 8.00 PP-08 ANION FEEO PUMP ACT. VOL 50OM3/HR iI 15M HEAD 1 NO 1,0.000 1,0 1,1,00 6,500.00 .6,500 7,900
HANDLING WATER a PH2
ACID PUMP 150 II 150NB C/W 30ICW MOTOR
50 9.00 PP-Q9 ANION RINSE WATER PUMP ACT. VOL 250M3/HA iI 1 NO 1,0.000 1,0 1,1,00 6,000.00 6,000 7,1,00
20M HEAD, PUMP 15 KW
50 10.00 PP-10 ANION WASH PUMP ACT. VOLV25OM3/HR i 12" 1 NO 1,0.000 40 1,1,00 5,500.00 5,500 6,900
-------
Kilborn Engineering Pacific Ltd. MINE ~ATEA fREA'MEN' PLAN' U April "'"
1]80 lurrard Street ORDER Of MAGNlfUDE CAPITAL COST ESflMAIE P.,ye :
Vancouver, 8.C. fOR 'OML/OAY PLANf NEAR BUT'E, MON'ANA Nun II"'" : II:H:I'.
9999.99 OEIAIL REPONT C: SHK 'W' _'.oUo
-----------------.-------- .--- -
CooE 0 E S C RIP , ION QJY UNIT LAIIOR 10TAL LABOR HA'ERIAL HAnRIAL ::iUIiCON'UC' SUIiCONIRAU 'DIAl
AREA ITEM UNIJ MHAS MHAS (OS, UNIJ COSI CDS' UN IJ COST CDS' COSI
, .
--.--- -_. ---- ----- . ..---- ----. .--.
50 11.00 PP-11 LIME DOSING PUMP ACf. VOL 25M3/HN . 5H HEAD, I NO 30.UUU 30 1,050 3,300.0U 3,3UO ".j~1t
HANDLING LIME SLUARY, PUMP ] KW
50 12.00 PP-12 ANION REGEN PUMP ACT. VOl 250M3/HA a 12M 1 NO IoO.OUO 1,0 1,1,00 5,50U.OO 5,500 b,Ylol'
HEAD HANDLING LIME SLURRY, PUMP 15KW
50 B.OO PP-13 ANION SLUDGE PUMP ACT. VOL 25M]/HA a 5M HEAD 1 NO 30.000 30 1,050 3,UOO.UU 3,UUO Io,U5"
HANDLlNGLlME SLURRY, PUMP ClAIR DIIVEII
50 11,.00 PP-I1o SUMP D'SCHARGE PUMP ACT. VOL 25M]/HA a 10M 1 NO 35.000 35 1,225 Io,OUO.UU ",UUO 5,t.",
HEAD, IoOMMD CAL'GHEI VIS PUMP 1L/S 10M H ] KW
50 15.00 FA-OI DECASSER TOWER FAN UII'T, ]K~ FAN 1 NO 20.000 20 700 1,60U.UO 1,6UO 2,5uII
50 16.00 AG-OI CA'ION REGEN. AGI'ATOR 20M3 1 NO 1,0.000 1,0 I,IoUU 15,50U.UU 15,500 Ib,YUII
AGITA'OR 20M] C/~ 5.5K~ MOTOR
50 17.00 AG-02 LIME TANK AGI'ATOR 20M] 1 NO 50.000 50 1,750 15,500.00 15,500 17,25lJ
AGIJATOR 20M] C/W 5.5KW MOTOR
50 18.00 AG-O] AIIION REGEII. AGITA'OR 20M] 1 110 50.000 50 1,750 15,500.00 15,500 17,2SU
AGlfATOR 20M3 C/W 5.5 K~ MO'OI
;,0 19.00 S8-01 CATION SIEVE 8EIIO ]00 MICRON APERTURE WEDGE 1 110 ]0.000 30 1,050' 5,500.00 5,500 6,550
-------
Kilborn Engineering "acific Ltd. MINE ~ATER TREAIMENT PLAN I 22 Al'r i I 9..
1Jao 8urrard Street ORDEN OF MAGNITUDE CAPITAL COST ESTIMATE P"ye: 6
Vancouver, B.C. FOR IOML/DAY PLAN I NEAR BUTTE, MONIANA Mun lime : 11 :J3: 13
9999-99 DETAIL REPONT C:SIIK"H_1.0Bf
-----..-. .-..---- ~- ---- .. ---- --. -- ... ----- --. -- -...--.-..----
CCDE 0 E S C RIP , ION an UNIT LABaN TOT AL LAIIOR MATERIAL MATERIAL SUBCONTRACT SUBCONIRACI TOTAl
AREA ITEM UNIT MHRS MHRS COST I . COS.T COST IINIT COST COST COST
.----- - - .- _. ._--_.-- ------ -----.. -- - ...- -- - ---
50 20.00 5B.02 ANION SIEVE BEND JOO MICRON APERTURE WED~E 1 NO JO.OUU JO I,O~U ~,~OU.OO 5,50U b,5~0
WIRE TYPE SIZE 2000 X 1500 SEIVEBEND
50 21.00 sC.OI CAli ON PROODUCT SCREEN JOO MICRON APERIUNE 1 NO C!5.UOO l5 8/) I>,IIUO.IIU b,UUII b,tJ/)
STATIC SCREEN 2000 X 1500
50 22.00 SC.02 ANION PRDODUCT SCREEN JOO MICRON APERTURE 1 NO C!5.000 C!5 tJ/5 6,OOU.UU 6,000 6,tJ/~
STATIC SCREEN 2000 X 1500
50 2J.00 SC-OJ CATION ~ASH SCREEN JOO MICRON APERTURE 1 NO J5.000 3~ I,U5 II,OOU.UU 8,OUO 9,225
STATIC SCREEN 1000 X 4000
50 24.00 SC-04 ANION YASH SCREEN 300 MICRON APERTURE STATIC 1 NO 35.000 35 I,U5 11,000.00 8,000 Y,U)
SCREEN 1000 X 4000
50 24.00 SERVICE ITEMS INCLUDING SUMP PUMP, AIR COMPRESSOR, 1 SUM 1,00.000 400 14,000 110,000.00 '10,000 104,000
DRYER, RECEIVER, FILTERS, HEATING ETC.
50 25.00 OVERHEAD CRANE & MAINTENANCE HOISTS 1 SUM 300.000 300 10,500 65,000.00 6~,OOO 7~ , 5uO
50 26.00 SPARES a 61 Of EQUIPMENT VALUE 1 StM 15,000.00 15,000 15,000
-------
leilborn En!jln"ering Pacific lid. MINE ~AIER TREAIHENI PLANI a AI" I I Y.
1380 Burrar...' Street. ORDEN OF MA~NllUOE CAPIIAL COST ESIIHAJE P..ye: 1
Yancouver, B.C. FOR 10HL/DAY PLANI NEAR BUITE, MONIANA IIlMI 110.., : l1:Ji: II
9999, 9't DETAIL REPORT C:SIIIl'~I_I.DBI
---- .._---_.. no .-._u -.-.-----------.-- --
CODE DESCRI P T I 0 II OTY UNIT LABOR IOTAL LABOR MAIERIAL MA 1E.R I AL SUBCONIRACI SUBCOII I RAC I JUUI
AREA IIEM UNI I MHRS MHRS COST UNIT COSI COSI UNIT COST COST CUSI
--..--- .---.--. .--- -- ,.
.-.-.".- -. -...- . ---- ----- - . - ...----.-.-. --. -.
WW!!!!!
60 1.00 lle-OI FEED WATER TANIe . ACT. VOlUME 50M3 3500 DIA. 1 NO 40.0UO 1,0 1,4UU 11,000. UO II.UUO Il,4UlI
X ~~OO HIGH C/W THIEE NOZZLES ALL PLASTIC, WATER
'lANK
611 .00 IK-02 TO 07 . CATION lOADING CONTACTOR 4000 DIA X 6 NO 4~.000 270 9,4~0 II"OUO.UU tl4,OUU 9j,4~U
3000 ~ALL HEIGHT flAT BOTtOMED WITH tM TEGNALLY
MOULDED fLGED INLET NOZZLE I 100 WIDE ESCAPSULAIED
flOOR SUPPORT liNG 500 UP FIOM IOUOM lOOSE CORR,
~~Rf. 4000 DIA TOWEl flOOR CYlllIDER STEPP
60 .00 TK-08 CAtiON PRODUCT TANIe ACT. VOl. 20M3 2200 DIA 1 NO 30.000 3U I,U~u 7,UOO.UO 7,UUO tI,U~I.
X ~500 X THREE IIOZZlES All PlASTIC'TANIe
60 . .00 tlC-09 CAtiON CONDITIONING tANIC ACT. YOlo 2OM32200 1 Slit 30.000 30 I,O~O 7.000.00 7,000 II,O~U
DIA X 5500 X T"IEE NOZZLES All PLAStiC tANK
60 ~ .00 TIC-10 CATION OYER flOW TANIe ACT. VOL. 20M3 2200 DIA 1 Slit 30.000 30 I,O~O 7,000.00 7,000 8,O~0
X ~500 X THREE IIOZZlES All PLASTIC TANIe
60 6.00 TIC.lt CAtiON lATCH REGENEIATOR ACT. YOlo 38M34000 1 SUM 45.000 45 t,575 15,000.00 15,000 16, ~ 7S
DIA X 3DOO "1'" All III Gal' MATl C/W fOUR NOZZLES,
TAIIIC
60 7.00 TIC-12 SULpHURIC ACID TAIIIC . ACT. YOl 15"3 X 2600 1 SUM 30.000 30 1,050 6,~00.00 6,500 7,~~0
-------
kilborn EngIneering Pacific ltd. MINE WAIER IREAIMENI PI AN I 22 Api II v,
1JIO Burrard Street ORDER Of MAGNIIUDE CAPIIAl cas 1 ESIIMAIE P..g,,: II
V8IICouver, B.C. fOR IOMl/OAY PlANI NEAR BUllE, MONIANA lIulI I 111M! : II:H: IJ
9999.99 OEIAll REPOIII C: SilK' WI_1.0tlt
'.__0_. -..-- 0___- _..- -..---------....- .
CODE DES C I I P T 10M Qn UNIT LABOR 10lAl lAtlOR "AIERIAl "AIEIlIAl SlJUCONIRAC I SUBCUN I RAC I IOIAI
AlEA ITEM UNIT "HRS "HRS (OSI UN II cas I COSI UN II cas I COSI COSI
I.
----- --...-....- .-------------..----. --.,.. .----.-..--- . ---- -- -.
TANK
60 8.00 IK"] CAIION REGENERANI TANK' ACT YOlo 20M] ]000 I SIM 30.000 3u I,II~O 7, lUU . 110 (,20U 1I.2~U
. 3000 . fOUR NOZZLES All PLASTIC TANK
60 9.00 IK-14 CAllaN CAlC" POT 4000 . 500 YAll " YIIH 3500 I SUM 45.UOO 1,5 I. ',(~ 10, ~uu. .,0 10.~UU Il,u6
o 60 OEG CONICAL BOT 10M YIT" INIEGR MQUlOEO flGEO
OUTLET & ORAWDff NOZZLES ON GRP KNUCKLE RING
SUP paR I ]00 0 . 500 W liNG, 4200 . 200 0 lAUNDER
flGEO. OUT 75 WIT" INTEGR. MOULDED Off NOZZLE
60 '0.00 IK-15 TO 20 ANION lOADING CONIACIOR AS ABOVE I SUM 95.000 95 3,525 17,OOO.UII 11 ,UUU 20,5l~
CONIACIORS BUT 4700 OIA. . ]000 WAll" WIT" flOOR
SUPPORI RING 500 UP fROM BOTTON ET AND SURROUNDED
8Y 5000 OIA . 200 D GRP lAUNDER AS PEl SKEICH IK
15 TO 20 ETC. CONTACTOI
60 11.00 IK-21 ANION PIODUCT TANK ACI VOL. 30M3 EACH 2600 1 $1M 45.000 45 1,515 9,OOO.Ou 9,000 10,H~
DIA. . 6000 "IG" . T"IEE NOZZLES All IN PlA~IIC
TANK
60 12.00 TK-22 ANION CONDITIONING TANK ACT. YOlo 30M3 EA 1 SUM 45.000 45 1,515 9,000.00 9,000 10,515
2600 OIA.. 6000 " . T"IEE NOZZLES All IN PLASTIC
TANK
60 13.00 IK.23 ANION OVERflOW lANK ACI. VOL 20M3 2200 . 1 SUM 30.000 30 1,050 7,000.00 1,000 8,050
-------
.
Kilborn lllyineering Pacific: ltd. MINE YATER TREAtMENT PLANT 22 Aj.>ril V..
1380 lurnrd Street ORDER Of MAGNITUDE CAPITAL COST ESTIMAIE p..ya: Y
Vencouver, B. C. fOR IOML/DAY PLANT NEAR IUTTE, MONTANA Run I. Ole : 11:33:1\
9999- 99 DETAil REPORT C:SRI( WI_1.DIII
-- --_.- -. ------- -._------- -. .--- -..---.----
CODE DES C I I P T ION QTY UNIT LABOR TOIAL lABOR HAnRIAL MAIERIAL SUBCONTRACT SUBCONTNACT TOI.AI
AlEA ITEM UNIT MHRS MHRS COST UN! T COST COST UNIT COST COST COSI
---"---_. . - ..---------- ---"-
60 14.00 TK-24 ANION BATCH REGENERATOR ACT VOL 52M3 4700 1 SUM 80.000 80 2,800 15,000.00 1~,UOO 17,8UII
OIA. K 3000 H X THREE NOZZLE All GaP CONTACTOR
60 15.00 TK-25 LIME MIXING TANK ACT VOl. 20M3 2500 K 4500 K 1 SUM 30.000 30 1,05U 7/,OUO.oo /I, UUO 78,U~1J
THREE NOllLE ALL IN PLASTIC, TANK
60 16.00 IK.26 ANION REGENERANT TANK ACT. VOL 20M3 2500 K 1 SUM 30.000 30 I,O~U 7,UUO.uu I,UUU II,U~IJ
4500 K THREE NOZZLES ALL IN PLASTIC, TANK
60 17.00 TK.27 ANION CATCH POT 4000 X 500 YALL H YITH 3500 1 SUM 1,5.000 45 1, ~'5 10,~00.00 10 ,500 12,Uf~
D 60 DEG CONICAL BOTTOM YITH INTEGR MOULDED FLGED
OUTlEi & DRAYOff NOZZLES ON GaP KNUCKLE RING
SUPPORT 3DD D X 500 W liNG, 4200 X 200 D lAUNDER
flGED. OUT 75 YITH INTEGR. MOULDED O/f NOZZL
60 18.00 TK-28 DEGASSING TOYER COMPRISING Of 3000 DIA K 1 SUM 70.000 70 2,1,50 "'.000.00 '" , 000 Ib,4~U
3000 H flAT 10TTOMED flGE OPEN TOPPED TIC C/Y
INTERNAL 2500 DIA. X 2500 WAll OPEN flGED TOP
STilliNG CHAMBEI/OVERFlOW WEll & CENTIAl 1500 K
10000 H FlGED TOYEI. 1500 X 2000 FlGED SPOOL
PIECE WI
60 19.00 EXTRA fOR GRP COYl TO SUIT TOWEl INCL. ERECTION 1 SUM 30.000 30 1,050 3,000.00 3,000 4,050
nc.
60 20.00 YE-OI CATION TRANSFEI VESSEL ACT. VOl. 12M3 2000 2,555 ICG 0.020 51 1 ,789 3.00 7,665 9,45~
-------
lI:ilborn Engincering Pacific ltd. MINE ~AIER IAEA'MENI PLAN' U A"r II y,
1]10 Burrard Street ORDER OF MAGNIIUDE CAPITAL COSI ESIIMA'£ P"Qe: III
Vlnclluver, B.C, FOR IOML/OAY PlANI NEAR BUTTE, MONIANA Run 11111.. : l1:H: n
9999. 99 DETAIL REPORT C:SRI( WI_1.0Ilt
------_...~ +---..------- ---------
ailE 0 E S C RIP T ION OTY UNIT lABOR 10lAl LAIIOR MA T£k JAL MAIERIAL SUBCONIRACI SUBCON'UC' IOUI
MEA IIEM UNIT MHRS "HRS [051 I, ..lilT [051 [051 UNIT COSI con COSI
----.- -.- --------
60 21.00 2S0MM OIA TANII: NOZZLE (R/l) 6 NO 8.000 1,8 1,c.UO 'lll III I.!U 2,I,IIU
60 22.00 RUIIDER LINING PlAIEWORII: 3.1 M2 3.S00 116 1,,11..1 IU IIU 2, .110 6,1~j
60 23.00 VE-02 ANION TRANSFER VESSELACI. VOL 12 M3 2000 OIA ,2,S~S KG 0.020 SI I,IUY j,IIU 1 ,bC.~ y.~~..
K ]200 H x SIX NOZZLES ALL IN M.S.
60 21,.00 2SOMM OIA IANII: NOZZLE (R/l) 6 NO 8.000 1,8 l,bUU IlU.OU flU 2,1,111)
60 25.00 RUBIIER LINING PLATEWORII: 31 M2 3.~OU 116 I"Ul,j IU.IIU l,HU b, Y'\
60 26.00 CH'OI CAIION WASH COLUMN - IS00 OIA K I,SOO [/W 1 NO 1,0.000 1,0 1,I,OU 11 , OUU . UU ",UUU 12,I,UII
]000 DEEP 60 DEG CONICAL BOIION C/W LAUNDERS AND
NOZZlES
60 27.00 CH.02 ANION WASH COLUMN - lS00 DIA K 1,500 C/~ ]000 1 NO 35.000 ]5 1,22S 11,000.00 11 ,000 12,U~
DEEP 60 OEG CONICAL BOIION C/W LAUNDERS AND
NOZZLES
60 28.00 SE-OI CATION SETILER 14000 DIA X 2000 C/W 12000 .84.0 IONNE ]5.000 2,940 102,900 2,100.00 176,1,00 219,3UU
DEEP 60 DEG CONICAL BOTTOM C/W 500 DIA . 10000
STILLING CHAMIEI & 2000 DIA TO 5400 DIA X 2500
DEEP IAfFLE fAIIICAIED IN M.S.
-------
IC II born Eng i neeri nil Pad fI c ltd. MINE WATER TREATMENT PLANT a Aprl I ,
1310 Burrard Street ORDER Of MAGNITUDE CAPITAL COST ESTIMAIE P"ge: ,
vancouver, B.C. fOR IOML/OAY PLANT NEAR BUTTE, MONIANA Run Iinle : 11 :H.'
9999.99 DETAIL REPORT C:SNK'''I_'.0u1
_._--- ---- -_.- _.. .----------
COOE DES C RIP T ION QTY UNIT LABOR TOTAL LABOR MATERIAL MAIERIAL SUBCONTRACT SUBCONINACT TOIAI
MEA ITEM UNIT MHRS "HIlS COST 0, U;II T CDS I COST UNIT COST COST COSI
.------- ----.- ._- _. ---"-.--'-
60 30.00 RUBBER LINING PLATEWORIC 1,228 M2 3.000 3,681, 128,91,0 60.00 15,611U 202,6'"
60 31.00 SE-02 ANION SETTLER 14000 DIA . 2000 CIW 12000 .81,.0 lONNE 35.000 2,91,0 102,\100 2,100.00 1/6, ~UU 219,1111
OEEP 60 DEG CONICAL lOT TOM C/II 500 DIA . 10000
STILLING CHAMBER & 2000 DIA TO 5400 DIA . 2500
DEEP BAffLE fABRICATED IN M.S.
60 32.00 l50MM OIA TANK NOZZLE (R/L) 2 NO 8.000 16 ~c.O I~O.UU l4H lIuli
60 33.00 RUBBER LINING PLATEWORIC 1 ,228 M2 3.000 3,681, 128,91,0 60.00 73,6110 202,b.o,
60 ]1,.00 PAINT PLATEWORIC SlIP 2flN 15.0 TONNE 1. 500 23 1118 12.00 1110 y, u
PLATEWORK TOTAL 11,,857 519,987 867,910 1,187,8\11
mllI!i
70 1.00 PLAN' fEED AND DISKARGE PIPING NO' INCLUDED
70 1.00 EMERGENCY SHOWER SS C/II EYE WASH 2 NO 30.000 60 2,100 2,100.00 1,,200 6,30U
70 2,00 POLYPROP PIPING 250MI 510 M 1. 500 765 26, 775 80.00 1,0,1100 67,57~
70 3.00 POLYPROP PIPING 200NB 135 M 1. 300 176 6,143 60.00 8,100 11,,21,1
-------
ICllborn Engi,neeriny. Pacific Ltd. MINE ~AIEK IAEAIMENT PLANI U A.,... I '14
1380 Burrard Street ORDER Of MAGill TUDE CAPITAL COST ESIIMAIE P..ge: Il
Vancouyer, B.C. fOR IONL/DAY PLANI NEAA BUTTE, MONTANA Aun lime : l1:H:U
9999' 99 DETAil REPORT C:SIIK.~I_1.DIH
------- - -_._- -.-- - - ----- ... -"-.-.
CODE DES C RIP T ION QTY UIIIT L ABOA TOlAl LAOOR M~lEk IAL MAIERIAl SUOCOIHRACT SUBCONIAACI 10lAI
AREA ITEM UN IT MHAS MHAS COST , . UN I I cas I COSI UIIIT COST COST cas I
--.------ ---.------.-.-. ----.- -----...----
10 1,.00 POlYPMOP PIPING 150llB 2i5 M I. 000 235 8,22> I,>.UO IO,ST> \II,8UlI
10 5.00 POlYPIiOP PIPING 80llB 111 M 0.800 11, 501, 3u.uO >4U I,UI,I,
70 6.UU PUl 'PRoP pfpE f I " I NGS 1 SUM l,IIU.OUU 1,110 Ib,lJUII II, UULI.IIU 11,UII'1 U,IIUII
10 7.0U COMPRESSED AlII PIPING 20NO MED SABS 62 MS 120 M I.UUU IlU l"lUU j).lIu 4,~UIJ 1I,I,lIIJ
10 8.00 POIAOLE ~ATEA PIPING 25NB MED ~T SABS 62 CS GAl V 2U') M 1. 000 200 1,000 l,>.tJU ' ,uutJ Ib,UU')
PIPING
10 9.00 20MM SABS 6Z CS GAlV PIPING 6> M \. 000 65 2,1l5 I,O.UU l,6UU l, , tll~.
10 10.00 GATE VALVES 250118 CI VOSA II, 110 1.000 98 3,t,30 2,000.00 26,000 31.I,JO
70 ".00 200MM liB PUMP Slin -Off VALVE 1110 6.000 42 \,470 2,000.00 \1,,000 \5,t,70
70 12.00 150811 118 PUMP SIIJT-Off VALVE 6 110 5.000 30 1,050 1,500.00 9,000 TO,050
70 15.00 100MM 118 PUMP SIIJT-Off VALVE 4110 4.000 16 560 800.00 3,ZOO 3,760
-------
Kilborn Engineering Pacific ltd. MINE WATER TREATMENJ PlANJ U ApI"! I ".
1580 8urrard Street ORDER OF MAGNIJUDE CAPITAL COST ESJIMAIE P"ge: 1
V8nCouver, B.C. FOR IONl/DAY PlANJ NEAR BUJTE, MONJANA Run lime: 11:31.1
9999. 99 DEIAIL REPORT C:SRIC'WI_1 LJU
----- ------- .--.- -----_.~_._. -.. - - --- --.- -- ...--- ------. - ---_u_.-
COOE 0 E S C I I P T 10M QIY UNII lABOR TOIAl lABOR MAIERiAl MAIERIAl SUBCOIII RAI:I SUBCONlRACI IUIA
AREA IIEM UN IT MHRS MHRS COSI UNII COST COSI UNIT COST COST CO)(
------ - - ------_..
10 IS.DO SOHH NB PUMP SHUT' OFF VALVE 1 NO 2.000 2 70 20U.UO 200 "
10 16.00 2S0HM NB RESIN FLOW CONIIOl VALVE I, NO 10.000 1,0 1,4UU 1,OOU.UU I.!,OOO H.',I,
70 11.00 MISC. PIPING. VALVES & FilliNGS AllOWANCE 1 SUM 800.000 8UO 211,UOU ~2,UUU.00 ~.!,UUO 80,"'"
70 111.0U 1'11'1 HI. SUI'POII! S, HANGERS, INSULAIION E IC I SUM 2S0.000 2~0 ",/~1I b,IIlIU.UII (',UIJU 1~, :'.
PIPING IOUl 3,196 118,IISl 21~,YI~ .BI,,/i
UECIRICAl
80 1.00 POWER SUPPLY 10 MCC & PLANI NOT INCLUDED 1 SUM
80 1.00 MCe flJIC 15 MOTORS (TOTAL 172KW) 1 SUM 1,0.000 1,0 1,1,00 11,,000.00 11,,000 15,~Ut
80 2.00 POWER DISTRIBUII(IJ TO MOTORS INCLUDING SJARJERS, 1 SUM 1,000.000 1,000 35,000 112,000.00 112,000 11,7,OU"
COMTROl AMP POWER wlRIMG
80 3.00 llCi" II NG INCLUDED 1M IUllDIMG COST
80 4.00 INSJRUMfNT DISTIIBUTI(IJ BOARD 1,0 WAY 2 SUM 20.000 40 1,1,00 6,SOO.00 13 ,000 14,411U
-------
lilborn EnYlneering PaLl'ic ltd.
1380 Burr.rd Street
VlnCouver, B.C.
9999' 99
MINE WATER TREATMENT PLANT
ORDER OF MAGNITUDE CAPITAL COST ESTIMAIE
FOR IONl/DAY PLANT NEAR BUTTE, MONIANA
DETAil REPOIIT
12 AprJ I YI,
Pdge: 11,
Run lime: 11:33:13
C:SKI(-WT_'.DBF
.-----------.
- '-------"U""-'-
... - -.----.---. --
CODE
AREA IIEM
DESCRIPTION
QIY UNIT
lABOR
UN II HIIKS
TOTAL
MHRS
lAIiOR
COST
MAIERIAl
I UNIT COSI
MAnlllAl
(OS I
SIJIICONTRACT SUBCONIRACI
UNIT COST COST
lOIAI
COSI
.. ---.-. - ..
..- ..---.------
--.---.----- .----- ----
- ---.----..--.
80 6.00 I~A WEAIHtI: PROOF PLUG BOX INCLUDING WIRING 15 NO 10.000 1~0 ~.2~U IUO,OO I, ~OO 6,l~0
80 7.00 6J AMI' \/l1t..NG WTLET INClllOlNG WIRING 6 NO 10.UOO bO 2. IlIU 31111,UU 1,/111.1 J,YUI!
10 11.00 GIIWNDING .,llOWANCE 1 SUM 110.000 110 2,IIOU I"OUlI,OO '" ,lllhl c.,IIUU
80 9.00 SECONDARY TRANSFORMERS 1 SUM 1,0.000 I,U 1,1,00 20,OUO.00 lO,lIOO ll,l,OU
10 10.00 AlII CONDIIIONING UNIT FOR CONTROL ROOM 1 NO 1,0.000 loO l,loOO 5,OUO.00 ~,OUU 6,loUU
10 11.00 EMERGENCY liGHTS I POWER SUPPLY 1 SLtt 100.000 100 3,~00 12,OUU.UO Il,OOU 1~,~OU
10 12.00 MISC. POlltIl AND WIRING 1 SUM 1,0.000 1,0 l,loOO 7,000.00 1,000 11,1,00
80 1].00 FIRE EXTINGUISHERS 1 SUM 10.000 10 3~0 1,000.00 I,UOO 1,3~0
ELECTRICAL TOTAL 1,690 59,150 199,300 258,1,50
INSIRUMENTAI ION
90 1.00 SOlENOID VALVES 12 NO 1,000.00 12,000 12,000
-------
Kilborn Engineering Pacific Ltd.
1]80 lurrard Street
Vancouver, B.C.
9999- 99
COOE
ARU nEM
DES C RIP T 10M
90
3.00 (AT ION REGEN PUMP FLOW INDICATOR 250NB
90
4.00 CATIUN ~ASH PUMP FLOW IMOICATOR 100NB
9D
5.00. CATION RINSE PUMP fLOW INDICATOR 200NB
90
6.00 DEGASSER FEEDPUMP FLOW INDICATOR 250NB
9D
7.00 ANION LOADING FEEDPUMP fLOW INDICATOR 25DNB
9D
8.00 ANION REGEN PUMP fLOW INDICATOR 250NB
90
9.00 ANION ~AS" PUMP FLOW INDICATOR 200NB
90
10.00 ANION RIMSE PUMP fLOW INDICATOR 200NB
90
11.00 PLANT 200N8 fEED fLOW TOTALISER
90
12.00 f£fDWATER TANK LOW LEVEL SENSOR
90
1].00 CATION REGEN TANK LOW LEVEL SENSOR
MINE WATER TREATMENT PLANT
ORDER OF MAGNITUDE CAPITAL COST ESTIMAIE
fOR IGML/DAY PLANT NEAR BUTTE, MONTANA
DETAIL REPORT
-.---..---
QJY UNn
LABOR
UNn MHRS
TOT AL
MHRS
--. -- ---- ---.----
" '
-------
Kilborn Engineering Plcific Ltd.
1180 lurrard Street
V8nCOUVer., B.C.
9999.99
CODE
MEA I TEH
DES C . I P T I D M
90
14.00 CAIION OF TAlK LOY LEvEL SENSOR
90
T~.OO CAIIUN COND. TANK "IG" LEVEL SENSOR
90
16.00 CAIION COND. TANK LOY LEVEL SENSOR
90
17.00 CAIION CLNG "IG" LEVEL SENSOR
90
18.00 OEGASSER LOY LEVEL SENSOR
90
19.00 OEGASER "IGH LEVEL SENSOR .
90
20.00 ANION REGEN LOY LEI/EL SENSOR
90
21.00 ANION REGEN TANK LOY LEVEL SENSOR
90
22.00 ANION OIF TANK LOY LEVEL SENSOR
90
23.00 ANION COND. TANK LOW LEVEL SENSOR
90
24.00 ANION COND. TANK "IGH LEVEL SENSOII
90
25.00 ANIOI! PROD. TAJIIC LOW LEVEL SENSOII
HINE ~TER TREAIHENJ PLANT
ORDER OF HAGMITUDE CAPITAL COST ESJIHAiE
FOR IOHL/DAY PLANT NEAR BUTTE, HOIIIANA
DETAIL REPORT
QTY UNIT
TOTAL
HHRS
-------..--------- . -...-..
LABOR
UNI T HHRS
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
1 NO
LABOR
COSI
MAIERIAL
UNIT COSI
I.
-._----- _..
MArERIAL
cosr
U A.-"I ~..
P..ye : 16
Nun r line : I1:H:U
C:SRK-IIJ - 1.0Bf
- --------.--.. .. ------.. --.-
SUBCONTRACr SUIiCONIRACr rOJAI
UNIT COST cosr cosr
.---_. - -
1,200.00 1,200 l,lUU
l,lUO_OO 1,2UO 1,2UII
l,lUO_IIO l,lllU l,lOll
1,211U.00 1,2UO l,lUII
1,;WO.Ou 1,200 1,20U
l,lOU_UO 1,200 1,2UU
1,200_00 1,200 1,20U
1,200.00 1,200 1,200
1,200.00 1,200 1,200
1,200.00 1,200 1,200
1,200.00 1,200 1,2011
-------
Kilborn Engineering Peel;le Ltd.
1380 lurrerd Street'
VMeouver, B.C.
9999,99
MINE WATER TREATMENT PLANT
ORDER Of MAGNITUDE CAPITAL COST ESIIMATE
fOR IOML/D'Y PLANT NEAR BUTTE, MONIANA
DETAIL REPORI
22 April 9~
Pilge: 11
N.., lime: 11:3]:0
C:SRI('WI.1.0111
------
.---...--..
----- -_._----
-----------
COIlE
MEA ITEM
DES C . I P T 10.
QJY .lNIT
LABOR
UNIT MHRS
TOIAL
"HIS
LABOR
COSI
MA IER I AL
,UNIT COSI
MAnRIAL
COSI
SUBCONTRACI SUBCONIRACI lOlAI
UNIT COST COSI COSI
---.
----- .---.----. .. ..-.
------- . .. -- --.
90 26.00 ANION ALNG HIGH LEVEL SENSOR 1 NO 1,200.00 1,200 1.20u
90 27.00 CATION LOAD CONT. 1. LEVEL DETECTOR 1 NO ~,UOO.OO ~,OOO ~,UU,.
,
90 28.00 ANION LOAD CONT. 1 LEVEL DETECTOR 1 NO 5,000.00 ~,OOO 5,Ouu
90 29.00 CAIION NEGEN TANK COND. INDICATOR CONTROLLER 1 NO ],~UO.OO J,~OO J,~lIlJ
90 30.00 ANION REGEN TANK PH INDICATOR CONTROLLER 1 NO 3,500.00 3,500 J,~Ou
90 31.00 WASH COLUMN RESIN OUTLET PHOTOELECTRIC CELL 250NB 2 NO J,OUO.OO 6,000 b,OOU
90 32.00 ASCO THREE-WAY SOLENOIDS VALVE ACTUATOR 21 NO 1,200.00 .?~,200 2~,201l
90 33.00 RESIN OUT CBR CONTROL VALVE 250NB 1 NO 3,000.00 3.000 i,OOO
90 34.00 DRAIN CSR 100NI VALVE 1 NO 1.500.00 1.500 1 ;500
90 35.00 DRAIN CCP 100NB VALVE 1 NO 1.500.00 1.500 1.500
-------
Kilborn Engineering Pacific Ltd.
1380 lurrard Street
Vancouver, B.C.
9999- 99
HINE WAfER TREATHENf PLANT
ORDER Of MAGNITUDE CAPITAL COST ESflHAIE
fOR IONl/DAY PLANT NEAR BUTTE, MONIANA
DETAIL REPONT
22 ApI" I I Y.
P..ge: 111
Run lID'" : 11:3J;U
C:SIU':"IoII_I.DBI
- ----------------..
.--.----------
CCIOE
MEA I TEH
DES C . I P T 10M
on UNIT
LABOR
UNIT MHIIS
TOTAL
MHRS
LABOR
COSI
HAIERIAL
, "UNIT COST
MAIERIAL
COSI
SUBCONTRACT SUBCONIRACf fOIAI
UNIT COST COST COSI
.-. ---.-------
--'-
90
38.00 OVERflOIoI CTV 100NB VALVE
I NO 3.0UO.00 3.000 3,UUU
1 NO 1.50U.00 1.500 1,50U
1 NO J,UUU.OO 3.000 3,Uuu
1 NO 2,UUU.UU 2.000 l.UU'1
1 NO 2,UUU.00 2.000 Z,UUII
1 NO ~,UUU.OO 2,UUO 2,UUU
1 NO 2,UUO.OU 2.000 2,OOU
1 NO 3.000.00 3.000 3.00U
1 NO 3.000.00 3.000 3.000
1 NO 3.000.00 3.000 3.000
1 NO 3.000.00 3,000 ].000
1 NO 1.500.00 1.500 1,500
90
]7.00 RESIN QUf cwe 2S0NB VALVE
90
39.00 RESIN OUf CTV 2S0NB VALVE
90
40.00 RESIN IoIAfER TO CfV 1S0NB VALVE
90
41.0U 1 USED RESIN TO CTV IS0NB VALVE
90
42.00 1 USED RESIN TO CCT IS0NB VALVE
90
43.00 SPENT RESIN fOCSR 1S0NB VAlI"E
90
44.00 RESIN QUf ABR 2S0NB CONTROL VALVE
90
45.00 RESfN QUf ACP 250NB VALVE
90
46.00 RESIN QUT AWC 250MB VALVE
90
47.00 RESIN QUf AT V 250NB VALVE
90
-------
Kilborn Engineering Pacific Ltd.
,JaG lurr.rd Street
Vlneouvar, B.C.
9999-99
MINE WATER TREATMENT PLANT
ORDER Of MAGNITUDE CAPITAL COST ESTIMAIE
fOR 1OML/DAY PLAN I NEAR IUTTE, MONTANA
DETAIL REPORT
CODE
AlEA I TEN
DES C . I P T 10M
QTY UNIT
TOTAL
MHAS
------_.__.-.. .-.--.-
"AIERIAL
COST
LABOR
UNIT "HRS
LABOA
COST
90 1,9.00 RESIN WATER TO ATV 200NB VALVE 1 NO
90 50.00 1 USED RESIN TO AIV 200NB VALVE 1 NO
90 51.00 1 USED RESIN TO ACI 200N8 VALVE 1 NO
90 52.00 RINSE RECYCLE TO fWT 200N8 VALVE 1 NO
90 5].00 SPENT RINSE WATER 200N8 VALVE 1 NO
90 51,.00 DEGASSSER RECYCLE 1DON8 CONTROl VALVE 1 NO
90 55.00 CATION LOADING fEED PUMP CONTIOl VALVE 250NB 1 NO
90 56.00 CATION REGEN PUMP CQMTIOl VALVE 25OM8 1 NO
90 57.00 CATION WASH PUMP COI/TORL VALVE ZOONB 1 NO
90 58.00 CATION RINSE PUMP CON TOIL VALVE ZOONB 1 NO
90 59.00 DEGASSER fEED PUMP CONT.Ol VALVE 250NB 1 NO
MATERiAl
,UNIT COST
22 A/,ral ~.
P"ge: 1\1
Run I III'" : 11:J]; IS
C:511K-"I_1.01l1
-----
SUBCONTRACT SUBCONIRACT TOIAI
UNIT COST COST COSI
-_._-
2,500.00 2,500 2,5Ld
2.500.00 2.500 2. ~I.I
2,5UO.00 2,500 .?,~" I
.?,~UO.UO 2,500 l.~lI"
2,500.00 2,500 2,5UO
1,000.00 1,000 I,OUO
],000.00 ].000 ].000
].000.00 ],000 ],000
2,500.00 2,500 2,500-
2,500.00 2.500 2,500
-------
Kilborn En9)neering Pacific Ltd.
1310 Burrar~ Street
VlnCouv8r, B.C.
9999.99
CODE
AlEA I fEM
DESCRIPTIO"
1 NO
90
60,00 ANION LOADING fEED PUMP CONTROl VALVE 2~ONB
90
61.00 ANION REGEII PIMP CONTROL VALVE 200liB
90
62.UO ANION WASH PIMP CONTROL VALVE 200NB
90
63.0U ANION RINSE PUMP CONTROL VALVE 200NB
90
64.00 PRESSURE INDICATORS
90
65.00 PLC SYSIEM
90
66.00 CONVERTORS E69f TYPE
90
67.00 WATER TRAP ASSEMBLY
90
68.00 fEED WAfER CONDUCTIVITY METER
90
69.00 TESTING, MISC. WIRING, SUPPORTS, ETC
MINE WATER TREATHENI PIANI
ONDER Of HAGNITUDE CAPITAL COST ESTIHAIE
fOR 10ML/DAY PLANT NEAR BUTTE, MONIANA
DEtAIL REPORT
---..-.--.-----
QTY UNI T
LABOR
UNIT HHRS
TOTAL
MHRS
1 NO
1 NO
1 NO
~ NO
1 SUM
'" NO
1 110
] 110
1 St.II
INSTRUNfllTATION TOTAL
L AUOA
COST
HAIERIAl
, UNIT cas I
HAIEKIAl
t:OS 1
U Al'l II 'J..
P~\le: lu
Kun lime: 11:31: 1\
C:SRk 1I1_1.DUI
. ---- ----_.._n. --
SUBCOllTRA[1 SUB[ONIRACI
UNIT COST COST
IUIAI
C051
..----- -
J,UOO.OO 3,000 3,OuO
l,500.00 2,~00 2,~00
~,~uo.OO 2,~00 2,50U
~ , ~ 00 . 00 2,500 l, ~U,I
~UU.UU 2,OOU l,UUU
I/U, UUU. UU
110,UUO
110, UUII
I,OOU.OU
Y,UOO
Y,UUII
600.00
600
600
1,,000.00 12,000 12,000
50,000.00 50,000 50,000
-------
Kilborn Engine~1 ing Pacific Ltd.
1J80 lurrlrd Street
Vencouver, B.C.
9991)-99
CODE
AlEA InM
DES C . I P , 10M
CONSl»IABII~
710
1.00 CATION RESIN
710
2.0U ANION RESIN
CONSTRUCT'IoN INOIREtTS
720
1.0U CONSTRUCTION IMOIRECTS AllOWANCE
Ifill
no
1.00 ENGINEERING, PROCUREMENT AND CONSTRUC'ION
MANAGEMEMTALLOWAIICE
S'AR'UP & COMMISSIONING
740
1.00 STARTUP & COMMISSIONING INClUDIMG VENDOR REPS,
CONTRACTOR ASSIS'AMCE, S'AI'UP SUPPLIES AND PARTS
AND ENGINEERIMG ASSIS'ANCE
MINE WATER TREAIMENT PLANT
ORDER Of MAGNITUDE CAPITAL COST ESTIMATE
fOR IONL/OAY PLANT NEAR BUT'E, MONIANA
DEtAIL REPORT
22 AI'...I Y.
P dge: II
RUII I ill.., : 11:B:11
C:SRK WI.1.UUt
.+--- ---- ---..
---...
.-_.-- -.--"
Qn UNn
lOT AL
MHRS
HATU IAl
COST
:.UBCONIRACI
IINIT COSI
SUBCONIRACI 10lAI
COST COSI
lABOR
UNn MHRS
LABOR
CDSI
MATERIAL
, . UN I T CDS I
--------
--- ---- . .---
100 MJ 2,~00.00 l~O,OOO 2~O,uu.J
100 MJ ~,oou.OO ~uo,uuu ~OO,ouu
CONSUHABLES IOIAL I~U, \lIIU I~O,I"'II
1 SUM
JUII,OOO.OU
jllll,UOO
108,OU,'
CONSTRUCTION INOIREC'S lOTAL
JOH,OOO
108,OUU
1 StM
719,000.00
719,OOU
7"",
EPCM TOTAL
719,000
719,001.1
T S""
I~O,OOO.OO
1~O,OOU
-------
Kilborn Engineering Pacific Ltd.
1J80 lurrard Street.
Vancouver, B.C.
9999.99
MINE WATER TREATMENT PLANT
ORDER OF MAGNITUDE CAPITAL COST ESTIMArE
FOR IOML/DAY PLANr NEAR BUTTE, MONTANA
DETAIL REPORr
COOE
.IEA I TEM
DES C RIP T 10M
LABOR
UNI T "HRS
WNER'S [OS!;!
800
1.00 OWNER'S COSIS MOT INCUDED
CONTINGENCY
900
1.00 CONTINGENCY a 20X
..-----
..---..--...-. _.
Qn UNIT
TOTAL
"HRS
----------.- -.
STARrup & COMMISSIONING rorAL
OWNER'S cosrs rOIAL
1 SUM
CONrlNGENCY TOTAL
.-' ---~---
PROJECT TOTAL
32,945
LABOR
COST
- '--' - -- --- ---_.
~A'ERIAL
I "IT cosr
1,153,085
---- . ----- .-.. - -- .
.-.--.-- - -- .
HAnKlA!
COSI
3,0011,798
22 April 9~
Pdge: 22
R,UI IIIie : 11:]3: 1 J
C: SRIl IIr _1.DIU
------. -_..-
SIIBCONrRAcr SUBcONrUCI r01A1
UNIT COST COST COSI
____0_..- -.
.. -_._----.------
150,UOO
1,41l,UUO.00 1,412,000
1 ,4 12, 000
.-- -_..-
4,310.600
--. - -.-.-
150,OOU
1 , 4 12, OUU
1,41'!,OUU
-------
ARCO <>
;Ci :3St Parli( S~reet. SuIte 400
~~aconca. '<1cl"tal"a :97"
-~'eonone 406 :03 :2' 1
=acsrmlle 406 :63 5269
PRP 1
April 29, 1994
ENVIRQNMINTAI.
PROTECTION AGINC'I
NAY 0 2 199.
\fONT ANA O";Cf
CERTIFIED-RETURN
RECEIPT REOUESTED
vK~. Ru.. Forba
EPA Project Coordinator
Butte Mine Flooding Operable Unit
EPA Mon~an. Operations Office
Federal Building
301 South Park Street, Drawer 10096
Helena, Montana 59626-0096
Joe Santarella, Jr., E.q.
Oftice ot Regional Coun.el
Environmental Protection Agency
One Denver Place
999 lBth Street, Suite 500
Denver, Colorado B0202-2405
Duane Robert.on, Chief
Solid and Hazardous Waste Bureau
Montana Department of Health and
Environmental Science.
Cogswell Building
Helena, Montana 59620
William B. Kirley, I.q.
Legal Division
Montana Department of Health
and Environmental Science.
Cogswell Building
Helena, Montana 59620
Re:
Mine Flooding Order on Consent, Docket No. CERCLA VIII-90-09
Dear Sirs:
ARca submits the enclosed comments regarding the Proposed Plan
for the Mine Flooding Operable Unit issued by EPA on January 20,
1994.
If you have any questions or would like to discuss any of the
comments, please contact Mr. Dave Sinkbeil at 406-563-5211.
Yours truly,
c~: D. E. sinkbeil
File: 70.01.110.1
File: 70.01.110.2
"lla",e ~.Cl"'f~C C ; -: 1"".
-------
o~,29/9~
':'6;17
COMIIENTS OP '1"U A'l't.AN'I'IC RIaFIELD COldPA1n'
ON HIm PLOOt)ING P.OPOSED PLAN
DATED JANUAaY 20, 1994
I~1T!iC:~':T:~N
A..."ID O'!::RVIEW.
':'he A::an::.c R.ic~!::'eld eompa~y (" AReO") submits tr.e
followi~g comments regarding t~e Mine Flooding Proposed Plan
("Plan") iss~ed by 2PA on Jant.:ary 20, 1394 fa:: addressing
contaminated water i~ the Berkeley Pit and sur::oun~ing areas,
''''n:..~h make up t~e Eu~:e Mine ?looding Operable Unit ("Mine
Floodi=i OU") o~ ~~e S:..l'ler Bow Creek/Butte Area Superfund Site.
As yo~ know, ~:O ~as =egponsible fer preparation of
the R.emedial Investigati.on ("R.:") and Feasibility Stud.y ("PS")
:or the Mine Flcoding OU, which serve as the basis for the
alternatives reviewed in the Plan for ad~ressing Serkeley Pit
waters. Acco=dir.gly, ARCO is intimately familiar with the
various details, co~lica:io~s and uncertainties involved in
developing a remed:..a~i:n plan fo:: Berkeley Pit waters. In
pa::ticula=, ARC: ~as grappled wit~ the many difficult issues
presented by the ~ac: t~a: ths remedy will evolve over a course
of decades ar.d is largely dep8n~cn: ~p=~ :he timing and evolution
of on-site mining ac~ivi:ies anc associated water discharges, as.
well as :u~u=e Ee~ke:ey ?it filling ra~es. Oue to this unusual
situation. ARCO believ~s t~at tr.e Plan T.~S~ balance certainty L~d
conc::eteness agai~s: che .~e=ent need to:: flexibility as the
situation unfolds.
In worki~g through these co~11=atior.s and
dit~~~ulties. A.~C: ar.c £~A seem :~ ha~e ar=ived a: a c=~~~ ~oal
ct developing a ;re~er=ed alter~a:ive a~: 5t.:ppor:~~g Plan for C~e
~ine Flocdi~g CU which ensures :~at Ser~eley Pi~ waters will be
concai~ed and t~a~ r.= release to the al:~7:al aqu~!er ~ill occur.
With that overall goal i~ rni~d. ~eo has strivec to develop
alterr.a~ives in t~e FS which taKe a c:r.serrative and proactive
approach to preventing any su:t =alease. However, ~here water
treatment or pumpir.q options present no a:ditio~al benefit to
human health in tr-e environment, but result i~ additional COSts
or other problems, ARea has s:reened OU: s~ch measures as
unnecessary an~ councerproduc:ive.
After carefully reviewing the Plan, A.~CO generally
accepts Preferred Alte=r.ative 6/7 as preser.ced in tbe Plan.
However, ARCO believes t~at i~ one critical r=spect Che Plan
tails to p::ovide ~~r t~e r.ecessary tlexibili:y inherent i~ the
lcng-term natur= cf ~~:s ?lan. ARCO bslieves that with a
-------
OV29/9~
lS: 1 i
will ensure ~ha: :~e overall goals ot :he Berkeley P1~
remeQiat10n process will be oet.
AS a final introductory point, ARCO notes that the
evolving nature of the remedy suggests that additional Compon.n~s
of the Plan ~y be developed :~ subse~~ent remedial design or
im~lementation documents. To :te ex:enc that such aQ4itional
components, suet as the pre~ise desi~ cf.~edrock well monitori~q
points, are noe expressly presenced 1~ t~.s Plan but are reserved
for later description, ARCO expects to be afforded the
opport~nity :0 comment on t~ese docurnen:s anQ reserves all righ:s
in th;.s regard.
-T
~_. .
.!OLtJ't"'.B CF S~FAC::E WAT:;:R. FLOW T~ BE nn~.
The ~ost cr~ci:al aspect ot the Plan that requires
c:ari!ication and/or mOQ~fication surrounds requirements for
co~trol of sur~ace water f~ow, both before anQ after mining. The
Plan in numero~s places refers to surface water inflo~ as
synonymous wich and equal to Horseshoe Bend flow. iac. A.S. p. 2
(referring to treatment o! "surface water inflows (i.e.,
Horseshoe BenQ)"). Apparencly drawing from RIIFS data incUc:atir.g
that the average flow of Horseshoe Bend is 2.4 MGD, the Plan
seems to imply t~t a total of 2.4 MGD surface intlow must be
~r~~:e~ regara~ess~: future actual surface flow rates a~
Horseshoe Send.
On this point, ARCO believes chat SPA has attempted to
set a rigid volume for treat~~nt and/or water diversion where
more flexibility is needed. EPA states throughout the Plan that
it wil~ main:ain a f~exible posi:~on wich respect to accual
methods ot controlli~g and treating surface waters. ~,~,
Plan at p. 2. In contrast, EPA's apparent designation of an
arbitrary treatcenc volume is not only c=~~terproductive, but
ignores tr.e evolutionary and dynamic nature of the Berkeley Pit
situation and surrounding mining act1vi~ies.
First, adoption of the 2.4 MGD figure assumes withou~
any supporting data that c~e Horseshoe Bend tlow will remain in a
steady state once mining ceases. Since E~A's P~an assumes that
the predominant sur~ace water contribution will be Hor..shoe Bend
water, the Plan needs to be tailored to the actual amount ot
Horseshoe Send ~low over time. For instance, upon suspension of
mining activities, ARca believes that Horseshoe Send tlow may
well Qiminish signiticantly over time. Thus, by arbitrarily
designating a 2.4 MGD treatment requirement, SPA may actually
require that water be pumped up from the Pit for treatment where
Horseshoe Bend flow is insutficient to account tor this volume.
Such a program would increase dramatically remediation c:osts
-------
O~/Z9/9~
18:15
withouc contribuc~ng to the overall goal of pr8venting Berkeley
?it overflow to alluvial systems.
Secona, the importance o! flexibility in surface water
int:ow treat~enc ~clume airectly ties into the design ana
cor.Struc~ion 0: any future creatment plant. The appropriate
parcies will be in a much better position to design a useful,
cost.efficient treatment plant tor Horseshoe Send water rather
tban a potencial mix of aorseshoe Bend ~ other wacers needed
solely to reach the 2.4 MGD figure. SPA's Plan ao wricten seems
to suggest that the parties must design a plant in the relatively
near future to account for a 2.4 MGD volume that may not exist at
the time the plane becomes cperational. Again, ARCO has shown in
aev~loping the RI/~S, ana accepting the general contours of
Alternacive 6/7 (which is much more expensive than ocher feasible
options presen:ed ~~ t~e FS), that ~t ~s willing to work within a
very conservaci7e and proactive framework to prevent Berkeley Pit
water from reaching the critical water level. Yee, by mandating
the 2.4 MGD inflow threshold, SPA threatens to require the
parties to incur unnecessary costs cased on a "snapshot" analysis
of water flows, where abSOlut8ly no additional proeection to
human health and the environment is afforded by these costs.
Third, t~. importance of focusing surface inflow
con~rols on future Horseshoe Bend flows, as oppose~ to.&n
arbicrary 2.4 MG~ fi~=~, ~~ un~&~~~ored by uncertainey
surrounding fit ~~~i:li~g rates. In 1993, ARCO issued a study
which suggested that aerkeley Pit waters would not reach ~he
critical wate: level under c~rrent conditions until at lease
40 years from now, and that, i~ Horseshoe Send was properly
controlled, the critical water level would never be reached.
"Preliminary Mo~elin; of Fu~~re Berkeley Pit Water-Level
Elevations and Inflow Rates," Pebruary, 1993. Ce~ainly, if sucn
predic~ions were to materialize, ARCO would seek a reexaminati~n
of t~e need to build ~ treacment plant :or Horseshoe Bend
waters. In the meantime, EPA has pushed for, and ARCO has
accepced, a very conservative and proac~ive approach to ensure
thac Berkeley Pi: ~aters are contained. Ado;ti~g.this approach,
EPA was unwilling to use Pit infilling rates reflected in the
1993 scudy, and projected in the Plan ?it infilling dates of
2015, if no remedialaction~ are taken. a~d 2022, if Horseshoe
Bend is controll.d.
By virtue of its years ot intensive study of th1s
problem, ARCC b.lieve. that Pit infilling rates will continue to
diminish. Yet, the extensive monitoring program inclu4ed within
A1ternative 6/7 will eliminate this "crystal ball- a~ect of the
reme4y by providing ongoing data necessary co calculate pit
filling dynamics. ARCO believes thac there is a significant
chance chac the rerouting and permanent control or treatmen: of
Horseshoe Bend waters, regardless ot their exact volume, will
-------
, '
O~I Z9/U
18; 18
likely result in s~abilization of the ?it such that the goal of
protectiveness will be accQmplisned. It seems unreasonable and
illogical given this po~en~ial tor stabilization ~o es~ablish a
2.4 MGD figure which may not reflect future surtace flow
condi~ions. ~hen viewed in the :igh: ot ~he uncertainties
surrour.di:g pit infilling rates, mandating such a figure may
result in the requirement t:.at ~aters aCtually be pumped trom'the
aerkeley Pit ~et~~t~standi~g that the Pit has already reached a
steady state.
In this regard, EPA notes that one alternative that was
screened and rejected d~ring the FS process was the immediate
pumping of Berkeley Pit water to maintain or lower the water
level in the Pit system. ~PA rightfully point. out that this
mucn more cost:y opcion provided no increased protection ot human
health and the environmen~, because the Alt.~ative 6/7 was more
than sutticien: to prevent reaching the critical Water level.
ARCO believes t:.a~ this exact rationale applies to the ar=itrary
designation of tr.. 2.4 MGD ~igure representing Horseshoe Send
tlow, when Horseshoe Bend :low may not continue at that
threshold. Accordi:gly, ARCO requests that the Plan b8 rewritten
to state that ~ ~ 2.4 MGD, as retlected by ongoing Borseshoe
Bend sampling and actual site conditions, along with other
surface flows, be contrclled or ~re&ted as outlined in
Alternative 6/7.
III.
'!"REA TMBN'I' ':"Ec:HNO!.CGI
ARCO sanerally ag~ees with the ~reatment technology
proposed fo:' any ~ecessary post-mining t:eatment plant, but would
like to em;:hasi:e that ~r.e "nydroxic1e precipitation with aeraticn
process" develcped by Dr. Huang at ~-1ontana ':'ech is an inngvative
technology. ~s we unc1erstand it, aera~ion has not been utilized
togecher w1th hyc1roxide p~ecipitation at these high flow rates.
Accordi=gly, t~is technology, li~e many ethers underlying the
remedy, will :eed to be conti~ually evaluated as the appropriate
treatment time approaches. Again, the ~lan would be better
tailored to the realities ot the Pit situation, and would better
serve the public interest, i~ it emphasized t~at tlexibili:y ar.d
ongoing evaluation would be necessary tor treatment ~lant
matters.
IV.
SLUDGE D::SPOSll
In the same vein, ARCO generally agrees that sludge
disposal location must be left open, and requests that this point
be made explici~ i~ tr.e plan. The sludge disposal question ot
whether sludge goes "inco the pit" or "into a repository" ~
ngr. and should. not 1:. answered tociay. Much more testing needs to
-------
; 1 ;;3, 3~
~~.~,;
~e performed in t~e futu=e on innovative technologie., as well as
pilot scale testing cn ~he hydroxide precipitation process
. developed by Dr. Huang. The point in time when treatment plant
design actually ~egins is the best time to make the determination
of where best to dispose ot sludge.
. The r.eed for tlexi~ility to account for evolving
innovative technology is parti~larly pertinent to the sludge
issue. Once sludge is placed in an out-or-pit repository, the
metals in the sludge will never ~e extracted because or the
manner in which metals are bound ~p as metal hydroxides, and the
added costs associa~ed with extracting the metals. Hc~ev.r, if
the sludge is returned :0 the Berkeley Pit, there is a much
greater cha~ce tt!.t metals will be available for' ."'traction in
the future by an innovative technology, and will become more
condentrated as more sl~dge is added to the Pit.
ARCO app=eciates the opportunity to CO~nt 'on the Plan
and to work'with EPA and other parties to resolve these and ot~e=
issues that may arise as the remedial plan evolves.
-5-
-------
. .
GOV 1
r'"
'7
. ~., ':'''-:..e,.,
~>...~v/,~"
'r::.....-~~-::
~r-"""!i~~:
~- ~~'.
~-~
~'~
.
'Yr:ffr ~
United States Department of the Interior
FISH AND WTLDUFE SERVICE
ECOLOGICAL SERVICES
FEDERAL BUILDIN8, US COURTHOUSE
301 SPARK
POBOX 10023
HELENA '"' 59626
.
February 23, 1994
Mr. Russell W. Forba
Remedial Project Manager
U.S. Environmental Protection Agency
Region VIII, Montana Office
~eder 1 Bldg., 301 S. Park, Drawer 10096
Helel.:.,-MT 59626-0096
Dear Russ:
As part of Interagency Agreement DW14932668-01-3 in which the U.S. Fish and
Wildlife Service (Service) provides technical assistance to the U.S.
Environmental Protection Agency, we have reviewed the Butte Nine Flooding
Operable Unit Preliminary Draft Feasibility Study Report (FSR) and th. Nine
Flooding Operable Unit Proposed Plan, and we have the following comments.
The Migratory Bird Treaty Act of 1918 (HBTA), as amended, 16 U.S.C. 703 et seq
and the Bald Eagle Protection Act of 1940 (BEPA), as amended, 16 U.S.C. 668 et
seq are not listed in the Draft Screening and Description of Potential Applicable
or Relevant and Appropriate Requirements (ARARs) in Appendix Y of the FSR.
Similar to the Endangered Species Act, both the MBTA and BEPA are federal
location-specific ARARs and should be included in the appropriate section.
We realize that the proposed plan is generic and that the detailed construction
design will be done during Remedial Design\Remedial Action.after signing of the
Record of Decision. However, we recommend that the treatment sludge disposal
facility be designed to prevent exposure of migratory birds to the sludge. This
sludge will contain elevated metals and arsenic concentrations, and any water
ponding on the, surface may attract waterfowl ind'shcrebirds.
~.
We agree that if the .ultimate ARAR for all projects relating to discharge of
waters to Silver Bow Creek. . . are -Gold Book. criteria including chronic water
quality criteria8 (FSR, Appendix Y, page 30), the proposed remedy will be
protect1ve of the Silver Bow Creek aquatic environment. We would recommend that
the M1ne Flooding remedy design be coordinated with the remedy for the Streamside
Tailings and lower Area One Operable Units so that the Mine Flooding discharge
will not iffect the Silver Bow Creek channel.
:!\!'..:C\",. "It. .
-"~iecTICt~ ~.":!'-:"-
"'CI~I.. ,
MAR - i 1994
-------
..
Thes. co...nts are provided as technical assistance only and do not constitute a
position the Department may take in the future regarding possible injury to
natural resources.
If you hav. an1 questions concerning our response to your letter, please contact
Bill Olsen at (406) 449-5225. We look forward to working with you during the
cleanup at the Berkeley Pit.
Sinc~'\A.. ~ ... J .
~/!:. .~"(J~
Kemper McMaster
Field Supervisor
Montana Field Office
cc:
Environmental Contaminant Coordinator, ES, Region 6, FWS, Denver, CO (Attn:
Patty Stevens)
Regional Environmental Officer, Office of Environmental Affairs, 001,
Denver, CO
~
':.- .
2
-------
O""'CK 0"
CHIEF EXECUTIVE
TO:
FROM:
RE:
A)
B)
DATE:
1)
A2)
BSB 1
BUTTE-SILVER BOW
COUItTHOU..
BUTTK. MONT"'N'" 88701
"".... COO II .0,
PHONE 723-8262
April 27. 1994
U.S. Environmental Protection Agency
Russ Forba, Remedial Project Manager
Butte-Silver Bow Local Government
Chief Executive Jack Lynch and Council of Com~issioners
Attached are the documents that represent Butte-Silver Bow's' comments on the
Berkeley Pit Remedial Investigation/Feasibility Study and Proposed Plan
Council Resolution No. 1635
Authorizing submission of formal comments
Exhibit A (to Resolution)
Ai)
Formal comments as reviewed and approved by the Council and Chief
Executive (eight-page document, including one-page summary)
Technical comments -- as a supplement to the formal comments of the Council,
addressing several specific details regarding the RI/FS; attached is a 2/25/94 letter
to Forba/EPA from Dr. Robert G. Robins
Exhibit B (to Resolution)
An public comments, letters, and documents received by the County, both in
response to the County's formal position paper as well as the RIIFS & Proposed
Plan, including:
Bl
B2
B3
Excerpts from minutes of Council of Commissioners Regular Meeting, 4/6/94;
Written testimony, John W. Ray, Butte, MT. as a supplement to oral remarks
made at 4/6 meeting of Commissioners;
April 11, 1994 letter from Mary Kay Craig, Clark Fork Coalition, Butte, MT,
as a supplement to oral remarks made at 4/6 meeting of Commissioners; also
includes a technical paper. Hazardous Wastes from Large-scale Metal Extraction:
The Clark Fork Waste Complex, MT, by Johnnie Moore. University of Montana.
-------
B4
Written testimony, Rep. Fritz Daily, District 69. Montana Legislature, Butte.
MT, as a supplement to oral remarks made at 4/6 meeting of Commissioners:
also includes a copy of House Joint Resolution No. 13. Montana Legislature re:
suppon for the National Environmental Waste Technology Testing and Evaluation
Center in Butte;
B5
Written comments to Jack Lynch, from Ray Tilman, Montana Resources. in
response to rirst draft of County position paper
B6
Technology Profiles Sixrh Edirion, Superfund Innovative Technology Evaluation.
as submitted by Irving W. DeVoe. Metanetix. Butte, MT, as a supplement to oral
remarks made at 4/6 meeting of Commissioners;
87
Written comments. Alben Molignoni. Rocker, MT. as a supplement to oral
~ remarks made at 4/6 meering of Commissioners: also includes a POWERSHAFT
LIMITED proposal on the creation of water storage systems and high efficiency
electric generation with Pit water;
B8
Written comments, letter to Jack Lynch and Council, from Ms. Sandy Stash,
ARCO, Anaconda, MT. as a supplement to oral remarks made at 4/6 meeting of
Commissioners:
89
Excerpts from minutes of Council of Commissioners Regular Meeting, 4/20/94:
810
April 20, 1994 letter to Jack Lynch and Council. from Rep. Fritz Daily, Butte,
MT. as a supplement to oral remarks made at 4/20 meeting of Commissioners:
Bll
April 20, 1994 letter to Jack Lynch and Council. from Mary Kay Craig, Clark
Fork Coalition, Butte, MT, as a supplement to oral remarks made at 4/20 meeting
of Commissioners;
B12
April 20, 1994 letter from Barbara Archer. Butte, MT. submitted as written
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solutions,
bot~ in
.~:'l:.~~e
and c:-eat:.ve
req'...li.::;
~e~s c= :ec::.~o:cgy and :.r:. the :.mplementation process;
and
on :an~arf 27, :?34, :::.e U.S. =:nvi=onmental Protection
Agency
:-eleased.
and
Remedial
:~vest:.gat:.cn
::-..s
Feasibi:':.:y
for
:::e
Mir.e
s::.::iy
a::d
?:-oposed
Plan
=:~odi~g :pe~ab:e ~~::,
N::':'=::' :.~cludes :::.e 3e:-keley Pi:
and Gndergrou~d ~i..e ~c:-~:.~gs; and on said date ~~e 0.S.
E:1Vironrnenta:..
opened
t::.e
;~bl:..=
?!"=~ec:':'=::
Age!:c'l
comment period,
unt:.:..
Apri: 29,
1994,
t.o p:-ovide an
opportunity for public :.~volvement in t::.e =:.~al
:-emed'f
decision; and
WHEREAS,
the
rneet:.~g
of
of
the
Council
Marc~
23,
1994
at
Commissioners, local gover~:nent staf.f p:-esem:ed a draf,:
set of commen':s regarding t::.e Remedial :r:.vest:.gat:.::~ a:-.d
Feasibilit'l
St-.;dy
and
tr.e
p:-c;osed
?lan
for
Xi~e
Flooding Ope:-acle
Uni':;
said comments were d=af':ed :0
serve as the local government's formal submission to t::.e
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:??4,
a:~er
:::eir
:':li~:.al
r~view
and
~~,
==nsi=e~a:.:'-=::,
:::.e Cct:.ncil
did approve :~e immediate
" -'
:-e.l.ease ::: :::.e
:RAFT :::omments :0 the general public and
." . .. d
ai. ~~~:~~s~:~ ;a~:~es; a~
:he
C:;:.:.::=i2.
:i:.d sc::edule
and hold a
special public
heari::;
~n .;pril 6,
to solicit
input from the
:994
gene:-a:
;:.,;b:':.c and all interested parties about
the
:?AF':'
and
... "- ~ -
~.._--
meeting,
the
council
=::~rr:e~.-::s ;
at
:-ecei "led :Cot:: "/er::a1 and wri ':. ':en input for consideration
:':1 :-evis:.::g ':he c:cmmentsi
and
upon
:-~cei;:.
cf
public
the
Council
of
comments,
:~mmi.ssic::ers
:.ns~:-uc:.ed
the staff :0 prepare a ::::al
"/ersic:l of
ir.cc:-;:orating any ::ecessary
:~e ::::::mmen~s
:-evisiens
based
the
ex;:-essed
of
':~e
views
on
Commissioners,
the
public
i::;ut
f:-om
the
Apr::
6
hearing, and ether information submit:ed :0 the ~ocal
government and;
the Council of Commissioners of the City and County of
Butte-Silver Bow, State of Montana, after due discussien
and deliberation, and in hopes ef fostering the level of
innovation and c:-eativity
neeaea to ffieet the concer::s
and needs of i:s citizens,
find that it is in the best
interests 0: the City and County of Butte-Silver Bow,
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:-~EREFORE,
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11 SECTION 1:
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SECT:ON 2:
25
State
~: :-!on:ana,
::~mme~:.s on ::::
: ~ submi:
::;r~al
- ....
.:-.e;nea:.a-
and
a:-.::.
- ' ,
-::'/e s::;a i: :cn
?easiJ:i.:'::y
Study
?~opcsed ?:ar. ==r :::e ~i~e ::~od:::g C~e~able
::::.:..: :.:>
::-..e
u.s. E::i:ror.~er.':al ?rc~ec'::on Agency J:y :~e deadli.::e c:
April ~3, :'394.
:;::: ::' ::..=:SOL.v~:J
BY THE CCt~C:~ CF C:MM!SS:ONERS CF
CCL~~Y CF 3t~T:::-S:LVER BOW, S:-ATE CF MONT~~A:
Tr:at:
~::e Council of Commissioners of the City and
Count:y cf 3u~:e-Silver Bow, State of Xontana, does
::ereby :ind and de~ermi~e ~~a~ i~ :s i~ the bes~
:~teres~s of :~e City ar.d Coun~y cf Butte-Silve~
Bow,
Sta~e of Montana,
a
and ~a~s
:0 prepare
fo~a~ resolution establishing t~e County's for~al
comments ~egardi::g :::e Re~edial !::iestigation ar.d
Feasicility Study and Prc~csed Plan :or :he Xi~e
Flooding Operable Unit, :::c:'udi::g :::e Berkeley Pi:
and Underground Mine Worki::gs, thus responding to
the call for public comments in t~i.s matter; and
to
au:horize
the
to
Chief
Exec'J.t:.ve
sign
and
submit the formal
comments,
here:.n attached as
Exhibit A, to U.S. Envircn~ental Protection Agency
on behalf of the local government at the Agency's
public hearing on April 26, 1994.
That
all public
1994
input
:rom the April
6,
hearing before the Council of Commissioners, and
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a::y
:Jther
-~
:::format::m
sul:ml.ct;d
~reviot.:.sly
3'~l:sequent 1 Y
::ca2.
-..---
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government
=n
. .'
~a~~:~ =e at:ac~s~ ~s
- . .. .
:.X~:"=:":
3 and made a ~ar~ -~
. - 1 " ,
:~e :=~a su=m~SSl:n
by :~e City and C=unty c:
3u::; -Sil'/er
the
u.
S.
2nvironmental
30w
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- ."
~r~:;c::on rtgency.
:-::ae t::e C:erk
send a copy of this Resolution to
c::e following:
Unit;d States Senators Max Baucus
and :onrad Burns, and United States Representative
?at ~illiams; Governor Marc Racicot; Butte-Silver
3cw representatives to t::e
Montana Legislature;
Wi::::.am Yellcwtail, ~egion 8 Director of t::e U.S.
2:wironmental
Robinson,
Protection Agency;
Bob
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---..;----,
:'w1c:::a:1a
:epar:::-:ent
of
Reale::'
and
2nvironmental
::ark
C:=ali:.:.oni
Sc:..e:-:=~s;
Fork
ARC8; Montana Resot.:.rces; and all those persons who
provided input at the April 6, 1994 public hearing
before the Council.
That this Resolution shal: be in full force and
ef:ect from and after passage and approval.
PASSED this 20th day of April, 1994.
/..- /f'
~ .-s$- ir~ ~:., ~
~"1AN OF THE C8~":NC::" OF COMMISSIONERS
'"
4
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APPROVED this 20th day of April, 1994.
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: A:':'ES:':
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I : 1 C:'ZRK &. ;'=:C8RDER
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8 ! I APPROVED ;'.5 :'0 FOR.'1:
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Butte-Silver Bow Local Government
. Comments on
Berkeley Pit Remedial Investigation/Feasibility Study
and Proposed Plan
Al
BSB 2
The Berkeley Pit mine flooding is a unique problem that will require unique and creative
solutions, both in technology and in the implementation/administrative process. "Business as
usual" will not solve the problems nor render the most innovative solutions to this critical
community problem. The Butte-Silver Bow local government, through its Chief Executive and
Council of Commissioners. submits the following comments on the Berkeley Pit Remedial
Investigation/Feasibility Study and Proposed Plan in hopes of fostering the level of innovation
and creativity needed to meet the concerns and needs of our citizens.
1.
Assurances\Scheduling for construction of treatment plant
The Proposed Plan should document a tirm schedule with a conservative trigger point for
plant construction to provide greater assurances that the critical water level is never
approached.
2.
Enhanced l\lonitoring Program/Public Education
The County proposes the immediate installation of two new wells southeast of the
Berkeley Pit and one new monitoring location near East Continental Pit, coupled with a
comprehensive education program that ensures information is disseminated regularly in
terms clearly understood by the average citizen. Also needed is a clear process on how
the data from the RI/FS will be updated, panicularly if any new data indicates any
impact on the environment or human health, thus triggering changes in the preferred
plan.
3.
Innovative Technology: Call to Action
The ROD should require the use of innovative technologies to supplement or replace the
hydroxide plant and ensure that the 'best available'. proven technology is used at the time
of implementation, thus avoiding the problems with hvdroxide DreciDitation. such as:
. sludge disposal in the Pit or at a new repository;
. future contamination from leaving billions of gallons of poison water in the Pit;
. the loss of the orebody, an enormous economic resource made into a long-term
community liability.
EP A should create a pannership with the PRPs and the County to set a firm goal to
develop a comparable remedy of equal effectiveness that is sensitive to cost.
4.
Waiver of requirement to restore the bedrock aquifer
There must be no linkage between a waiver writing off the contaminated bedrock aquifer
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1.
Scheduling for construction of treatment plant.
The Critical Water Level (CWL) has been set at 5410 feet by the regulatory agencies and
the PRP's based on a scientific model. There is an administrative order in place that dictates
the water shall never exceed this level. However. there have been no absolute guarantees that
the predictive model will match what will actually happen 'in terms of water movement. nows.
etc. Thus, the County would contend that a more important taSk is to develop and document
an appropriate plan to provide greater assurances that the CWL is never even approachea.
In this regard. the County believes a firm schedule for building a treatment plant should
be made a pan of the Record of Decision (ROD) to alleviate the genuine concerns of our
citizens. Towards that end. the County believes the following factors should be considered in
developing a conservative schedule that 1) addresses the possibility of unforseen eventS and non-
absolute assumptions made in the RI. and 2) will allow a reasonable amount of time to bring a
treatment plant on line well in advance of any crisis:
.
Weathered bedrock. Based on data in the RI, a critical saddle point in the top of
weathered bedrock exists near the southeast edge of the Pit at 5350 foot level. Water
reaching this alluvium level could behave unpredictably, Le., shon term rises in water
level, due to the density differences in the alluvium and the weathered bedrock. could
potentially yield a short-term change of gradient for this locale, thus allowing water to
tlow away from (and not toward) the Pit. Therefore. the County believes it would seem
reasonable to consider this level as a staning point to trigger action.
.
Insure dam safety at Yankee Doodle Tailings Pond (YDTP). There is a possibility
that an eanhquake could release saturated tailings from the Yankee Doodle Tailings Pond
into the Pit. Thus. to provide public assurances. it would seem prudent to provide a
buffer of 10 feet -- to 5340 feet -- to accommodate the tailings that could flow into the
Pit after a large earthquake.
, .
-- Note: The analysis done by Harding Lawson Associates (HLA) is not the worst-case
scenario. Liquefaction is predicted to occur in the top 50 feet of the dam after an
earthquake equivalent to 6.5 magnitude. No effort was made to characterize the
materials at the base of the darn, which former ACM employees have called casually
deposited, random fill material (at the time there were no dam design plans comparable
to those now required under the active mine permit). Several recommendations are made
by HLA to "beef up" and monitor the dam. These recommendations (which should be
incorporated into MR's permit revision issued by DSL) also must be included as
requirements in the final ROD to insure future dam stability.
.
Plant construction/operations lead time. Most industry estimates indicate a three-year
"shakedown" period is needed to make a treatment plant fully operable. As for linking
this "shakedown" period to a point in time in the future. the County suggests the
following:
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Currently, the Pit water level rises 25' per year: however. the predictive model indicates
this fill rate should decrease over time. In light of these facts, the County recommends
using the till rate at the time the water reaches 5260' as the timing indicator to determine
when plant construction should commence.
For example, according to the model and data for the Preferred Alternative 6/7. the
5260' level will be reached in the year 2009, and the rill rate that year is expected to be
about 10'. If the model holds true, then a three-year shakedown period would equate to
30' (3 x 10'), and plant construction would commence when the CWL reaches 5310'
(5340' minus 30'), predicted to be in the year 2014.
Again, the actual fill rate when the water reaches 5260' will determine when plant
con~truction would begin. If the fill rate proves to more or less than 10' at that time.
the tJming of the shakedown period would be adjusted accordingly.
Thus, the recommended level that triggers action to establish a construction schedule
should be set at 5260' and the treatment plant should be guaranteed to be fully operable by the
time the water reaches the 5340' level. Thi5 5('hedule would leave 70' of free board below the
current CWL. The 5260' level is also within range of the original CWL of 5216' which is the
contact betWeen the alluvium and bedrock, thus providing added assurance that the trigger point
for action is sufficiently protective.
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2.
Enhanced Monitoring Program/Public Education.
The County acknowledges that the Monitoring Program outlined in Appendix I of the RI
is reasonable. However, to provide the highest level of assurance to the County and its citizens,
the County would recommend that additional monitoring be included in the plan, as follows:
.
Two new monitoring wells should be drilled in the region southeast of the Berkeley Pit;
the objective of these wells would be to extend the bedrock aquifer contours through the
linear path of the Berkeley Pit and Well "C". These wells would provide further
verirication that mine rlooding problems are not migrating south and east.
.
A monitoring point/station should be located adjacent to the wt Continental Pit to
monitor that pit's intluence on the bedrock aquifer.
The County would request that these monitoring points should be installed during the summer
tield season of 1994. Further, the County would pledge to work closely with the EPA and PRPs
to locate these monitoring. points to acquire the most useful data.
Equally important to an expanded monitoring program is educating and informing the
public about these activities. In the ROD, EPA must commit itself and the PRP's to developing
a comprehensive program to educate local citizens on the flooding of the Berkeley Pit and any
potential contamination problems. Information must be widely disseminated, on a regular basis,
and in terms that are clearly understood by the average citizen.
Towards this end, Butte-Silver Bow stands ready and willing to assist in developing a
program (multi-media. computer graphics, etc.) to insure that the citizens of the County are kept
well informed on results from the monitoring program, progress of treatment plant construction,
and other issues related to tl00ding of the Berkeley Pit.
Finally, the County would recommend that the ROD include specific language that clearly
aniculates the process for updating the data from the RifFS. particularly if any data or
information used to decide on the preferred alternative proves to be incorrect or inaccurate. The
County and its citizenry need to know:
c)
how the agency and PRPs will respond to new and/or better information that
emerges from actual data collected, particularly if this new information has any
impact on the environment or public health:
how and under what conditions the decisions in the ROD will be changed, based
on updated information; and
how the County or an independent party designated by the community can be
directly involved in the decision-making process thoughout the monitoring period
and the implementation of the remedy. .
a)
b)
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3.
Innovative Technology: Call to Action.
. Although the County believes a firm schedule and trigger point should be established to
build a treatment plant, a greater goal is to develop an alternative technology solution to preclude
construction of a conventional treatment plant. Even under the most conservative scenario for
plant construction, the County believes there is an ample window of opponunity to develop
reliable technology alternatives.
A firm commitment by EPA. DHES and the PRPs to investigate and ::":'Iplement
innovative technologies is needed to spur action toward this development objective. As outlined
below. this commitment and resulting success has the potential to save money in the remediauon
process, and would help avoid what are viewed as flaws of the selected technology in the
preferred remedy 6/7 (hydroxide precipitation),
3.1
Technology alternatives.
In the RIfFS, ~chof the 19 remedial technologies was evaluated individually and not
in combinations. Thus, no effon was made to determine whether certain combinations
of technologies might achieve some synergistic benefit that does not occur with just a
single technology. The County would suggest that an evaluation of combined
technologies could become pan of the "innovative technology" research on waste
remediation being done in Butte through a variety of business ventures. In general, the
County believes that all of the questions that could be asked and answered through this
evaluation would lend increased assurance to Butte citizens that the "right" choice will
be made at the time of implementation.
3.2
Selected technology at odds with metals recovery.
The purpose of hydroxide precipitation is to tie up the heavy metals and metalloids
(arsenic) in insoluble forms to prevent the spread of contamination in surface and
groundwater. Once the sludge is produced. the metals are essentially unrecoverable
should future metals recovery technology become feasible. Thus, the hydroxide
precipitation option precludes the future recovery of a mass of metals that represents a
significant economic resource.
3.3
Slud&e disposal - Not in the Pit.
Based on input from several mining professionals residing in Butte, it appears that using
the Pit itself as a hydroxide sludge disposal facility is unwise, inefficient, and ultimately
counter-productive. Much time and money will be spent to raise the pH of Pit water by
adding lime in a treatment plant. It is expected that the sludge produced will have a pH
near 7. If sludge is disposed of in the Pit, it will be re-introduced into extremely acidic
water (pH - 2-4) and the metals in the sludge will be re-solubilized. Thus, the same
metals will be treated over and over. Disposing the sludge in the Pit would also cause
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3.5
the CWL to be reached sooner. For these reasons, disposing of any sludge in the Pit is
unacceptable (Alternative 6. Preferred Alternative).
3.4
Better analysis of non-Pit. sludge repository options.
Hydroxide precipitation with reverse osmosis polishing would generate from 500 to 1000
tons of sludge each day. Using the assumptions in Appendix A of the FS, about 0.2
MGD of sludge would result in a volume of 2867 cubic feet of sludge to be disposed of
each day. The County estimates that if this volume of sludge were piled 12 feet deep.
it would require"about 2 acres of land each year for disposal. Thus. in 50 years. a 100-
acre repository would hold about 52,322,750 cubic feet of sludge that would have to be
monitored for leaks in perpetuity.
BU1..rtng a Subtitle D RCRA repository would be expensive. given the need for the
installation of liners and leachate collection systems. Also, a sizeable amount of County
propeny would be needed for the actual repository as well as additional acreage for a
buffer zone surrounding the repository. In addition, the County may, at the request of
the PRP's, assume responsibility to monitor the repository and perform routine
Operations and Maintenance (with PRP funding).
Although these activities are challenging, a non-Pit repository appears preferable, given
the disadvantages of using the Pit. In any event, the FS does not adequately assess the
tasks of siting and designing a non-Pit repository, which seems to infer that a decision
to use the Pit has already been made.
Loss of orebody for future resource development.
Another ramification of the use of the Pit as a sludge repository is the loss of the
underground orebody. Allowing water to approach the 5410' level means the loss of
potentially tens of billions of dollars in gross revenues from the sale of metals and tens
of millions of dollars in lost tax revenues to the County, State, and Federal governments.
Valuable ore that could provide jobs and tax revenues and insure the economic future of
Butte-Silver ~w for years to come is being written oif in advance as contamination.
This orebody must be considered a long-term, strategic economic resource." not potential
contamination.
The following scenario has been developed from historical data collected by the
Anaconda Copper Mining Company and New Butte Mining to illustrate some of the
potential economic benefits to be derived from protecting and mining the orebodies
underlying the Butte Hill.
. Shallow ore reserves are 122,786,894 tons containing 0.88% copper and 0.33 oz/ton
silver. Using the assumptions that 1) 100% of these reserves would be mined: 2) 80%
of the copper and silver and 70% of the molybdenum would be recovered from that ore
mined; and 3) the copper is worth $lIlb, the silver is wonh $4/oz and the moly 50c/lb,
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the copper in shallow reserves is wonh $I,728,839,467.and the silver is wonh
$129,662,960. Shallow reserves represent a combined value of $1,858,502,427.
. Deep reserves are 2,231,034,219 tons of 0.06% Cu, 0.21 ozlton Ag, and 0.028%
Mo. Using the assumptions above, the value of the copper is $21,417,929,000; the
silver is wonh $1.499,254,995; and the molybdenum is wonh $437,282,707. Deep
reserves represent a value of $23,354,467,000. l"sinl the assumptions above, the
combined value of shallow and deep ore reserves is $25,212,969,000.
These conservative estimates are based on proven reserves delineated by the Anaconda
Company and reponed by Richard N. Miller, Chief Geologist, in the document "Ore
Reserves and Resources: The Anaconda Company, Butte District, Montana to January
I ""'8." According to this ACM repon. signiticant deposits of manganese. zinc, and
lead ~also remain to be mined under and adjacent to the .Berkeley Pit. If continued
flooding is allowed in the Pit, and worse, if the Pit is used as a sludge repository, this
orebody would essentially be lost or rendered considerably less valuable for future
generations. Worse yet, an enormous economic resource would be written off in
advance as a liability to be treated with lime and disposed of in sludge.
3.6
Conclusion re: Innovative Technology
The central issue is that the expense and operational complexity of either sludge disposal
option appears to justify greater emphasis on innovative technologies that would reduce or
eliminate the production of sludge. Likewise, the goal of any treatment option should be to
reduce or eliminate all waste streams, not simply to solve one problem and pass along
another to the next generation.
The County would suggest that the ROD be written to require the use of innovative
technologies to supplement or replace the hydroxide plant and ensure that the best available.
proven technology is used at the time of implementation. Funher. the ROD should require the
EP A, based on a thorough technology assessment and review over the next twenty years. to
verify the suitability of the selected technology. The EP A should join forces with the PRPs and
set a goal to develop alternative technologies that offer a comparable remedy of equal
effectiveness that is sensitive to cost.
The County would also suggest. that the ROD clearly allow for sufficient access to the
Pit water and provide needed indemnification from Superfund liability for those panies interested
in proving the viability of alternative technologies. In the absence of such provisions, it would
appear that any language in the ROD about the possibility of using innovative technology in the
future is purely gratuitous.
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4.
Waiver of requirement to restore the bedrock aquifer.
EPA has announced in public meetings that the agency will be issuing a waiver (as pan
of the ROD) for restoration of the contaminated pan of the bedrock aquifer. This decision
means that no effon will be made to remediate "the contaminated panion of the bedrock aquifer
because it is technically and economically infeasible to do so.
This waiver will set a precedent for Superfund cleanup on the Clark Fork and allow EP A
to ignore one of the main criteria for cleanup: reducing the volume, mobility, and toxicity of
contamination. When EPA issues the waiver as pan of the ROD, it is assumed the requirements
of "Guidance for Evaluating the Technical Impracticability of Groundwater Restoration"
(OSWER Directive 9234.2-25) will be followed.
The County's concern is the speciri~ language of this waiver. The COunty would request
full involvement in the review of this document. The County's interest will be to ensure that
a full evaluation has been done and tt~at no linkage is made between the contaminated bedrock
aquifer and other aquifers that would allow additional waivers in the future. In addition. the
boundaries of the contaminated bedrock aquifer must be clearly delineated on a map, and explicit
language must be included in the waiver to explain restrictions on future uses of the
contaminated groundwater.
8
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Butte-Silver Bow County Technical Comments on
Berkeley Pit Mine Flooding RIfFS
Remedial Investigation
I.
Additional infonnation is needed on the West Camp to further define the
water level tluctUations over time. To protect the West Camp area from
tlooding, it would be prudent to perfonn additional monitoring in locations
hydraulically lower than the Travona and, at a minimwn, reconstruct Well
21 to obtain more reliable data.
2.
If Alternative 7 is chosen. repository siting for Pit sludge must begin now.
Several repository sites have already been identified in a 1992 srudy
("Mining & Milling Waste Disposal Area Siting Study"). An off-site
repository for sludge will have unique requirements. Each of the possible
repository sites already identified should be evaluated for possible sludge
disposal.
3.
Use of averages (RI. Fig 3-2) is an inadequate representation of water that
must be divened from Pit and could result in underestimation of Pit fill rate.
4.
A discrepancy between "average" and "valid" slurry data results in
underestimating the volume of water arriving at Yankee Doodle Tailings
Pond by 13 %. Thus. the recommendations made by Harding Lawson
Associates for the Yankee Doodle Tailings Dam must be implemented
immediately to insure public safery.
5.
Regional recharge, evaporation. precipitation. and runoff data are excluded
from the Pit inflow calculations in Section 3 in the RI and result in the
incorrect asswnption that the Pit is a "closed system."
6.
Several assWTIptions made in the groundwater modeling are flawed: I) the
Pit aquifer is not isotropic and homogeneous; 2) no rationale is given for
selecting many of the boundary conditions; 3) impacts to the alluvial water
table as a result of water rising in the bedrock aquifer are not addressed. and
4) inconsistencies were noted in the sensitivity analyses for wells GS-28 and
GS-29s.
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.
Feasibility Study
1.
In the Remedial Investigation no Jata were collected to characterize the
geochemistry of current Pit sediments (see attached conunents of Dr. Bob
Robins). Consequently. the feasibility of sulfide precipitation (which may
already be occurring nn a large scale in Pit sediments) was not fully
evaluated as a possible remedy. Pit sediments must be better understooJ
before any consideration is given to sludge disposal in the Pit.
1
The combination of Freeze Concentration and Multiple Effect Evaporation
wa~ not evaluated to detennine if Butte's dry, cold climate could be used to
adv-antage. Freeze. concentration was dismissed because of energy
requirements. No effort was made to evaluate the potential for using the
cold weather that dominates Butte for 6 months each year to reduce man-
made energy needs. Nor was any effort made to evaluate the possibility of
using the sunny and semi-arid climate in Butte to see if solar energy could
be used to run (or supplement energy needed to run) the evaporation units
required for Multiple Effect Evaporation.
3.
Why was only one treatment technology for metals recovery (copper
cementation) evaluated during the final screening? Other newer technologies
(e.g., those of Metanetix and TetraTech) have been tested in actual cleanups
with some success. Metals recovery from Pit water has a great potential to
turn a current liability into a long-term economic asset. This section should
have been one of the most extensive in the FS. Instead, metals recovery
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PI
Dr. Ronel1 G. Robins
25 AJelaide A venue
LinJfield. NSW 2070
AUSTRALIA
Fax/Phone: Int+ 61-2--~16 3923
25 F~bruJr:" 199~
~1r. Russ Farba
Remedial Pruject ~1Jnager
t:. S. EnvironmentJ! Prote::ian Ag~ncy
301 Suu1h Park
H::len:1, MT 59626
U.S.A.
. DeJr Mr. Foroa,
COMMENT: Proposed Plan. Mine Floodin~ OP.ernhle Unit.
Berkelev Pit. Burte. Montana
r am a retired academic, having been Fuundacion Head of the Department of Miner:1l
Prucessing and E:
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An important aspect of pit-system chemistry relates to the r~ctions that are occurring
in the sediment that is funning on tl1t: pit bottom, submerged benches, and previously
cunnected old underground mine workings. The sediment thickness at the pit bottom (1993)
WCLS said to be possibly 200 ft. The sediment generally wiU almost certainly be becoming
sulfidized by a variety of chemical interactions, but there appears never to bave been the
suggestion of an investigatiun of sediment in the Berkeley Pit, apan from" my own in 1993.
A complete undersunding of geochemistry in the Berkeley Pit needs infonnation from
a sel1iment study.
Due to sediment sulfidation it is likely that an oxidation-reduction boundary has
already developed in Berkeley Pit sediment, near the sediment surfal.:e, so that the quality ur"
water on the reduction side of the boundary wiU differ from that in the pit itself, which '.':iii
be o.~idized with respect to the HS"/SO/ interface. All oxidation-reduction boundary cau IJ
separa1e the dissolved ionic species in the pit water from those in the underlying groundwater
(but allowing duwi1l1uw I r~dul:tion :u1d S'o.lHidation) such that the lower groundwilter would be
of better qualiry due to the decreased solubility of metal ions from a reduced sulfioe
environment. The o,udation-reduction boundary is likely to bave developed in the pit
sediment due to both the interaction of pore water with underlying sulfidic minerals and
solutions, and the likely microbiological reduction of sulfate to Conn sulfides. The fonner
process is similar to supergene enrichment in sulfide ore bodies where descending solutiof1s
from surface oxidation re:1ct with tl1e lower levels of hypogene sulfidic mineralisation to form
a region of enriched sulfides. Some ores which have been mined economically are attributed
to this e:uichment process (tb..is includes part of the original Butte ore body as described by
McClave: 1973). The proposition of oxidation and supergene enrichment of sulfide ore bodies
started with the work of Whitney: 1855, and by the 1960's tl1e paragenesis of o,udized and
enriched ores was well esublished. Accounts of the process have been published by Bateman:
1950, and Anderson: 1955. ""'lUre recem treaunents of the hydrology and geochemistry of
these processes are presented by Brimhall et al: 1985, and Brimhall and Crear: 1987, and
some related chemistry for tailings inter:1crions was proposed by Robins: 1992.
The likely mediation of sedimenCMy reactions by microorganisms depends to some
extent on the presence of organic carbon, altbough tbere are otbcr energy sources tbat suppurt
the wide range of org~isms that are encountered in the reduction of sulfate to sulfide. To
date it appears that no analysis of Berkeley Pit water (or any other waters in the OU) has
included the detennination of organic carbon, although it is likely to be present from various
sources, which include a huge vegetated water c:1tchment (> 5 square miles) [0 the north in
which humic substances are certainly being generated. AJgal blooms which occur regularly in
the water at the North of the Yankee Doodle tailings are evidence of organic materiaJ, which
in that region at least could support bioreduction of metJJ ions. Recycle of contaminated
water [0 part of this tailings area in order to form sulfides is wonh consideration. In the pit
itself it has b~en 5~d (without any evidence) that there is not m:~ly to be l1lY blOreduction
due to the "extreme" conditions in the water (acidity and meta! ion concentrJbons). This is
not cOrTect, and in similar mine waste pitS, such as at Rum Jungle in Australia, reducing
. organisms have been repurted at deep submerged sediment (Babij et aJ: 1980)
The comprehensive monitoring program which is being proposed should include 1
Strong microbiological study.
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So. it is suggested here mat the Berkeley Pit and surrounding ar~ could betome
enveJopeu by a sulfidic banier such tbat the underlying groundwater is in a reduced condiuon
where me mew ion concenrrarions will be considerably lower than in the pit water. There is
some evidence that this is me case (MBMG data, counesy Ted Duaime). In the West Camp
me Travona shaft water is sulfidic, and although the ground water at that location is more or
less cross-gradient to the Pit, it shows that the condition of reduced ground water does e:-:ist.
It also suggestS the use of West Camp water (or similar water) to suJfidise other waters in the
system. Water samples from the Belmont mine shaft, which is downgr:1dient of the pit, show
metal ion concentrarions considerably lower than in pit water. Water samples pumped from
the up-gradient Kelley Mine shaft (MBMG: 1992) indicated that both pH and ~ decreasea
with deptl1 (pH: 5 to 3, and Ea: 380 to 360mV), which could mean that the Kelley is isolate~
from the Pit by a redox (ox/red/ox) barrier. Carion concentrations in the Kelley appear to be
generaHy higher than in the pit, but this is probably due partJy to enhanced and localiseli
oxidation caused by the more elevated temperates which exist in the deeper water levels.
There is other evide:1ce of sulfidation actually occuring in the Pit: Le:ld weights used
to anchor a sampling platform in me Pit were noticed to be blackened on recovery (personal
communication: J. Medisb, MBMG). Trus was probably due to the presence of a coating of
?bS formed by sulfidation; A copper bar lowered onto the pit sediment in September 1993
bad a sulfide coating when recovered one month later (personal observations).
Another consideration is the influence of the au groundwate~ on deep groundwater,
and the fate of that water. A complete water balance on the whole pit system is not reported,
but could add perspective to understanding the likely outcome of any chosen remewaJ action.
For example, the IDa.:,
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.-\ tJownrlow of water over geologic time is evidenced by the Anaconda Company
maps (McClave: 1973, Figures K-l to K-3) showing the position of the zone of supergene
enrichment which lay in the volume that is now the Pit itself, and still exists in surrounding
areas . These diagrams show a downward extension of the enriched zone at faults :Lad veins
(eg. to levels at an elevation of 3800 ft in the Middle Fault at the Kelley shaft), where there
would have been a downi1ow of surface water. A downilow of pit water (beneath the pit) wlil
still be presenr and wiil be funhering the supergene enrichment process and carrying reduced
solutions with lower mew ion concentrations to gre:lter depths where enonnous dilution wiil
occur with circulation to depths of 1-2 miles (Blackwell and Robertson:19i3t
~Cont.1minated" water from the au may never influence surface ground waters.
~1y comments on the preceding pages lead to the following eight recommendations:
1. That a comprehensive monitoring program be quickly set in place.
2. That a pit sediment study be part of the monitoring program.
3. That a microbiological study be a part of the monitoring program.
4. That there be detAiled considerations of geochemical arid microbiological inter;"..:;ions in
the pit system.
5. That an overall monthly water balance be used to assess both up-gradif!1' water control
and recycle possibilities.
6. That system-outflow water quantities and patterns be assessed, with some monitoring to
suPPOrt any conc!usions.
7. That in considering chemical tr~tnent options, due consideration be given to recycle
of "contaminated" waters as well as the integration of waters from different sources.
8. That all of the above activities be supported by an ~ "advisory-and-review' panel
consisting of persons outside the commercial consultancy organizations.
Most of these recommendations relate to the proposed "comprehensive monitoring program"
which, if carefully planned, could well lead to the fonnulation of a more cost-effective
strategy (embodying in-situ immobilisation of contaminant metals) than for Alternative 6/7.
I have not addressed the detail of the tre:1tment methods (chemistry) that are proposed
to be introduced at the time of suspension of mining. These methods are fairly standard and
reasonably well understood. However there is one aspect that is not understood at all, and
that relates to the inter.lC~"11S of treaDneat sludges with the environment into which the
sludge is disposed, particularly if that was to be the pit itself. If treatment sludge was added
to the pit it would dramatically affect the pit secLiment and the reactions occurring in the
sediment and surrounding groundwaters and perhaps deep grollrtdwater. These possibilities
should at least be considered, and preferably investigated in some detail in a pilot e:tperimc::nt
that could be carried out on site.
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The environmental siruaaon in the Berkeley Pit Operable Unit Systezn offers J
Te~::::dous ':;;po~r/ for s.;ienafic StUdy which shouid not be .lost, and which will certainty
be useful to omers in futUre ames and other places. There are presendy similar situations
internaaona1Jy, where detailed investigations have been in place for some years, but these do
.Dot appear even to have been idenafied during the feasibility StUdy, let alone taken as
example. In me near future otber mine operators will need to deal with situations similar to
tbose at the Berkeley Pit and a weJl documented activity will be appreciated. In L'ie
immediate future me WTSMUT mines in Germany (especially tbe Ronneburg Pit) ''!dil
commence to flood and will take about 15 years to fill.
One funber suggestion that I would like to put forward is about funding of L'ie
comprehensive monjtoring program. I think that advantage should be taken of sources oth:r
than EPA and ARCO. There are funding programs available through the National Science
Foundation, and others internationally, where large grants are given for environmenUl
projects. Locally, there is at the present a caB for submissions to a . Reclamation ami
Development Grants Program" from the Montana Department and Conservation. EPA shouili
coordinate a grants applicJuon scheme with tbe local instituaons and others. My close
association with tbe Academics at Montana Tech, over more than ten ye3fs, makes me realise
tbat there is a great potencial for more involvement in the au problems than at present.
I will be in Butte from 5th March to 9th March 1994 and will attend the public
meeting to be held at Montana Tech on the evening of 8th March. I would enjoy talking with
you or any of your coJleagues during my Stly, and in the meaname I could be contacted
through the Research Office at Monuna Tech (406) 496 4102.
Yours sincerely,
'Bon Rohins.
Attachment: References to publications cited.
Inclusion: Paper on sulfide tailings.
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REFERENCE~
MBMG~ Unpublished data, 1991, 1992.
ARca, Unpublished datil, 1992.
A. Davis and D. AShenberg, .The Aqueous Geochemistry of the Berkeley Pit, lutte.
~tontaI1a, U.S.A: Applied Geochemistry, Vol. 4, pp. 23-36, 1989.
M. K. Botz, ~Hydrogeology of the Upper Silver Bow Creek Area, Montana~,
~fBMG Bulletin i5, September 1969.
M. McClave, ~Control and distribution of supergene enrichment in the Berkeley pit, BUlte
district,- Montana" i.n: Guidebook for the Butte Field Me:ting, R.N. Miller, ed.,
Soc. Econ. GeologistS, The Anaconda Company, 1973.
J. D. Whitney, ~Remarks on the changes whi~b take place in the structure and conJposition
of mineral veins near the surface with particular reference to the East Tenness~ Copper
Mines",
Amer. J. Sci., Vol. 20, pp. 53-57, 1855.
A. M. Bateman, .Economic Mineral Deposits~, 2nd Ed., J. Wiley & Sons, 1950.
C. A. Anderson, .O:ddation of Copper Sulfides and Secondary Sulfide Enrichment",
Econ. GeeL, pp. 324-340, 1955.
G. H. Brimhall, et al., . Analysis of Supergene Ore-Fanning Processes and GrOllud-Waler
Solute Transport Using Mass Balance Principles",
Econ. Geo!., Vol. 80(5), pp. 1227-12.56, 1985.
G. H. Brimhall and D. A. Cr~, .Orefluid: Magmatic to Supergene.. (part III),
in: Reviews of Mineralogy, Vol. 17, pp. 235-321, 1987.
R. G. Robin~,. . Chemical Interactions in Sulfide Mineral Tailings.
Mineral Processing and Extractive Metallurgy Review , Vol. 12, pp 1-17, 1993.
T. Babij, A. Goodman, A. M. KhaJid and B. J. Ralpb, "Environmental Studies of Flooded
Open Cuts", in: BiogeochenJstry of Ancient and Modem Environments; Trudinger, Walter,
and Ralph, Eds., Aust. Acad. Sci., pp 637-649, 1980.
D. D. Blac!c\..'ell and E. C. Robertson, .Thenna! Studies of the Boulder Bathc~'."l and
Vicinity, Montana., in: Guidebookfor the Butte Field Meeting, R.N . Miller , ed.,
Soc. Ecan. G~oJogistS, The Anaconda Co., p D-3, 1973.
6
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Excerpts of Council of Commissioners Regular Meeting
April 6, 1994
PUBLIC HEARING
COMMUHICATIOR RO. 7891
FOR THE PURPOSE OF OBTAINING CITIZEN INPUT ON THE REMEDIAL
PLAN ?ROPOSED ?OR T~E BERKELEY PIT BY EPA. Proof of
publication Has ?resented and placed on file.
Mr. Lynch invited anyone who wished to address this Council ~o
step fO~Nard to the microphone, and limit their comments to
five minutes. Er. John Ray stated that the purpose of
- Superfund is to clean up sites of contamination, permanent
- cleanup remedy, ~ot moving contaminants to another site. The
law directs EPA to protect citizens and make superfund sites
clean. Any remecy for the pit should be a cleanup remedy.
The superfund law emphasizes (1) cleanup, (2) to reduce
':oxic:.~y '/olti.me and mobility. of hazardous substances and
pollutants at the site, (3) must be permanent, (4) must not
move hazardous material, and (5) cost should not be a major
factor.
Mr. Fritz Daily supports a cleanup of the Berkeley Pit and
congratulates the Council for presenting this resolution to
EPA. The Berkeley Pit issue is the most serious issue facing
this community. It - has the potential to destroy this
community as corrective action is not being taken. This
decision that is being made regarding the Berkeley Pit is one
of the most important decisions that will ever be made. He
feels there is no doubt that the critical water level, as
established by the EPA and ARCO, is wrong. At the last.
Legislature, we passed two resolutions about the Berkeley Pit
issue and I have passed them out to you. . We need to turn this
liability into an asset with the help of private companies.
To strengthen this resolution, he wants to include something
in the document that addresses active mining and to say that
active mining continues. He would also like the Council to
consider the treatment of Horseshoe Bend Water.
Dr. Irving DeVoe of Metanetix spoke on the proposal by the
EPA. He sa~d that chemists knew about this sludge treatment
in 1820, and that this technology is so old, our dumps are
filled with sludge allover the world. His company is looking
at cleaning up these dumps in the future. To start another
one here is not the answer. We received another private grant
which will allow us, in a commercial operation, to take the
materials from the mine water with zero waste. This
technology has been accepted by the Czech government as the
technology to clean up the Czech Republic soil. According to
an article in the SITE Techno10QY Profiles. Sixth Edition. the
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with the heavy metal process effectively treated samples of
contaminated soil from the Port Industrial Area, :ead
contaminated soil, from a lead smelter site, harbour
sediments, municipal sewage sludge. These soils could then be
taken back to their original sites and these materials cou~d
be recycled. Our philosophy is to recycle the metals.
~epresentati~e Joe Ouilic~ said he spent time today at ----
and talked about ~lning ~aste. There are some things in :~e
EPA proposed plan that are good. There are problems with :~e
SPA plan and those problems ~ere addressed in this proposea
~esolution, and he encou~ages the Commissioners to adopt :~i~
~esolution. :f ~e can get the parties involved together, :~e~
we can resolve the dif:e~ence between the two documents ar.c
then the problem with the pit can be resolved. We do need ~
~ definite date on the treatment plant, and we need answers ~~
these questions and the people of Butte-Silver Bow need to =e
protected.
Georqe Warinq said he is involved in a petition drive for the
Clark Fork Coalition. People are very willing to sign this
petition and that people are fearful that EPA and ARCO are
doing something bad to our community. People, who. are signing
his petition that he is circulating for the Clark Fork
Coalition, want something done now about the pit, not wait 25
years to have something done. People want something done now
and they do not like the EPA solution.
Rose Brock stated that there are many wells in her
neighborhood and she would like a guarantee that the 'Nell
water is as clear in the future as it is now, and feels we
need to address the aquifer issue. She objects to filling the
pit with sludge. She drew a parallel between the situation in
Utah, Nevada, and Idaho, after facing many years of nuclear
testing and bein. -:old i -: 'Nas okay, and now find that there
are different results. She acclauds the efforts of the
Council. . .
Albert Molignoni passed out two documents and said there are
other preferred alternatives other than what EPA presents :or
this community. There are more innovative ideas. :he
preferred alternative as proposed by the EPA and MDHES should
be unacceptable by this governing body and this community. We
can't totally rely on expert opinion on this issue because
nowhere else in the world has a cleanup of this magnitude
taken place before. A little common sense will go a lot
further on this cleanup issue.
Representative Bob Pavlovich said that one person who deserves
a lot of credit 1S Mr. Fr1tz Daily, as Mr. Daily has fought
hard at the State Legislature for this issue. Mr. Pavlovich
owns a business and :here are 7 wells on his property
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"'.-
monitoring ~he gas station across the street and yet we only
have 5 wells monitoring the Berkeley Pit. We need the two new
wells in this town. We need to clean this area up, and soon
and we need help from the State Legislature and we need your
help to do it.
3arbara Archer said we need to use the best technology, look
3~ new and better technology, and to begin the treatment ~~
:he pit and we need to do it now.
At 8:55 p.m., the Public Hearing recessed and reconvened a~
9:10 p.m. Roll call was taken and there were 10 present and
2 absent.
Mary Kay Craig of the Clark Fork Coalition, said that she very
. mucn supported th~s plan. She wOUld l~ke to add two ideas to
- the plan, and that is that we reduce the amount of water ~~
the pit now and clean it up now. Ms. Craig read a petition,
that she circulated at one store in one day and collected 750
signatures, to the Council which asks the support of President
Clinton, and Congressional Delegation to reduce the water
level in the Berkeley Pit and to reduce it now. Dust is an
area that hasn't been addressed and the air quality was just
one of her concerns that is not addressed in the EPA plan.
Mr. Lynch asked for a copy of the petition, and she said she
will provide a copy of this petition with signatures when they
have finished circulating it.
Sandy Stash of ARca said one point that has been missed is
that we have a solution on the table and a $6 million study
and that there were a variety of parties in agreement with the
study. She stated that ARca ~s one of the two companies that
will be asked to pay for the cleanup. ARca is in favor of the
plan that was prepared by the EPA, and other supporters
include the Department of Health and Environmental Sciences,
the Bureau of Mines, and Montana Resources, Inc. and ARca.
There is agreement and disagreement on this whole issue. As
far as the critical water level, the critical water level
includes a 50 foot safety factor. An appropriate time frame
will require a couple of years to get a plant built, and that
two "o~rs befor= -~: ~=~:~~Q~ ~ater ~evel is reached is the
time to start construction of the plant. This should not be
triggered by a water level. By the time the pit reaches the
critical water level, it will not be rising at the same rate,
but will be far less. It rises at a level less and less each
year. We need to tie the extra level of protection into the
number of years rather than the water level. Regarding the
wells on monitoring one more well makes sense if it is
properly placed. We have done much in the way of public
education on a very difficult subject, and we agree that
public education is a key issue and we will work with you on
getting this done and doing a better job on public education.
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The technology :.hat EPA has accepted is proven and this
particular technology is a Butte solution that was .developed
at Montana Tech and, at this time, is the only technology that
meets all the superfund criteria and we tested 19. This is
the technology we have in the current plan. We have a great
deal of time to look at other innovative technologies. If
someone can come up with a technology that is proven and COSt
effective we will certainly be willing to accept it. On t~e
issue of the bedrock aquifer, EPA is suggesting that it is
impractical to fix, and we agree. The wells that are drilled
at the pi~ COSt SlOO,OOO each, and we question whether this is
:.he type of aquifer that is the source of water for the
community. ARCO commends the Council for making the effort on
this issue.
. :ames Riley worked at the Anaconda Company for 36 years and
BSB 4-L -. feels we could run the tailings through the precipitation
plant. :J:e said if the Berkeley Pit water is contaminated,
what about the miners who worked there. He wants to know what
is being done for former copper workers.
Eileen LaBreche lives on Texas Avenue and wants the Council to
know what ~t 1s like to live by the pit. The dust in the
morning is horrible. While considering digging a well, they
were discouraged because of the close proximity of the pit.
They cannot sell the house because of the proximity to the
pi t . We need to do something now, not when it becomes
critical.
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Dave Curry has a few comments and suggestions. He feels there
is a conflict of interest because we want something done now
and at the same time we want to see some innovative technology
used. If we do something now, the technology that will be
used will create the sludge and he doesn't feel the people
want that. He suggests that we do something that is best for
the community as a whole. He feels we should try to recover
those minerals and sell them. He feels the document was
extremely well written. We have discussed an earthquake, but
just how large an earthquake would affect the pit. The plant
is likely to be destroyed in the pit from an earthquake. The
water level in the pit is set in concrete by EPA, but Mr.
Forba told him that the Council could address the socio-
economic issue. As far as the treatment plant he feels we
should adopt a hurry up and wait attitude. The cleaning up
now is not going to be a permanent cleanup. We will be
creating sludge ponds. He feels we need the right technology
and should give Metanetix and MSE enough time to come up with
a plan for the technology. It is in our best interest to try
and force a permanent cleanup. We need to be sure the right
technology is used. He is concerned that we can affect the
current active mining and it is in our best interest to
concentrate on the best type of clean-up possible.
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Mike Thatcher felt we don't need to compromise and this
pos~t~on ~s premature and feels the Commissioners' role is to
let EPA know how we feel. Our proposal is well substantiated
and doesn't feel we should throw the towel in.
Mr. Curry is proposing that the community scope be what :s
~est :or :~e community and feels that because of the
EnviroIll'nental Protection Agency Act, this whole issue has been
:orced. His concer~ :s that EPA has come up with technical
infonnation. We need to put our efforts toward the best
result ~hat is available to us.
Mr. o'Learr placed a question to Mr. Russ Fcrba of the EPA i~
Helena. ...f a new t:!chnology comes alone; ~n the next few
~ years, how will this new technology be used? Mr. Forba
responded that they would like to see the market forces
control this. If there is innovative technology that can do
the cleanup more cost effectively, in terms of recovering
materials, and in meeting specific discharge standards into
Silver Bow Creek, or for use in the concentrator, we will be
the first people to amend our proposal. It will be the
responsibility of those companies and the PRP's coming forth
to us and saying that they have something better. We will
then amend the order in public court.
Mr. Thatcher asked about the time parameters relative to
dialogue tonight for a final decision. Mr. Forba said public
comment ends April 29, a formal public hearing is scheduled on
April 26. They will also schedule a day long recording for
people who want to comment but won't get up in front of a big
crowd. It will then take several months to go through all the
public comments, make the necessary changes, and will be ready
hopefully before October 1.
Mr. Kerns said that the term cost effective is constantly
be~ng used. What does cost effective mean to the people of
this community ten years down the road, does it mean that
after the metals are taken, that we are dealing with today's
dollars or ten years from now dollars?
Mr. Forba would like to see it market driven. The actual cost
involved is unknown, because we don't know the cost of some of
the technology because they aren't proven. The present dollar
we are using is the 1992 dollar. Mr. Kerns asked if there was
an escalation factor built into the cost of the plant. Mr.
Forbasaid yes there was.
Dr. DeVoe asked if innovative technology has to be proven by
April 29 of this year? Mr. Forba said they can amend anything
in the future. They will be a proponent of anything that is
cost effective.
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BSB 4-R
BSB 4-8
~s. DeVoe said that wha~ is being proposed is not a solution,
lt 1S a postponement that ha to be dealt with down the line.
~herefore it will cos~ more money. If there is a permanen~
solution now that is as cost effective or even a little more
expensive then is it not worth getting involved with it. Why
does it ~ave to be more cost effective? .
Si~ce there were no more comments, Mr. Lynch thanked everyo~e
for comir.g and speaking and taking the time to lis~en. -
said he and the Planning Department staff will review ::-.:
comments ~: ~his ?ublic ~earing. We will present this dra:~
to the =:?A in a resolution form. The draft put fort~ :.":
Butte-Silver Bow has been given a lot of thought. If the goal
for innovative technology can be realized, the plant may never
have to be built. He said he finds disposal of sludge in t~e
- ?it as totall.y "Jnaccep~able and hopes that the communi~y
agrees with him. There has to be a better way of disposing
of the sludge. Our objective in putting ~ogether this draft
is to involve the community, to seek and get together in how
to solve this problem. We need to give this community some
assurances. We have legitimate concerns and needs. He has
asked that the recording secretaries make this public comment
in transcription form and that it will be presented to the EPA
at the Public Hearing.
Mr. Brooh~ said we are here to listen to these people. The
matter of mining and the safety and health of our citizens can
be compa~ible. He moved that we request the Chief Executive
and his staff to prepare the commen~s of this meeting, revise
Butte-Silver Bow's document accordingly, and submit them ~o
the Committee of the Whole on April 13th for review so tha~
the final document can be submitted to the Council on Apri~
20th, and a resolution of support be passed at that time, and
that Communication No. 7891 be placed on file. Mr. Kerns
seconded. The motion passed with Mike Sheehy opposing.
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The purpose of Superfund is lo clean up hazardous w2I,le sil~ which are 21
threat to human health and the environment. Remedies under Superfund
should provide a permanent c!eanup remedy not temporary containment or
simply remoyal to another site. Simply cleanup is the "act of cleaning up:
and the term clean means "pure,free from dirt, contamination. impurities."
According to the EPA publication entitled Sucerfund: Environmental
PrOQress the purpose of SUGerfund is to achieve "1ong-term. cleanup goals
for sites" and to remove "contamination from the environment." p. 1. The
document -,.,..ther states that "the law directs EPA to protect public health
by meeting-strict cleanup standards at each site." and "Reduced to its
environmental essence. the New Superfund mission is 'make sites safe.
make sites clean, and bring new technology to bear on the problem.M p. 3
According to the law any remedy for the Pit should be a cleanup remedy.
If one examines the major Superfund laws and regulations
(1. CERClA-ComprehenSive Envi ronmental Response. Compensati on and
Liability Act, 2. NCP- National Contingency Plan and,
3. SARA-Superfund Amendments and Reauthorization Act),
one finds that they A 11 of the above emphasize:
1. Cleanup.
2. The reduction of toxicity. volume. and mobility of hazardous
substances.pollutants. and contaminants at a site.
3. Cleanup remedies must be permanent.
4. Discourage EPA from simply moving waste for one spot to
another. Is this what will be done with the sludge which will
result from treating Pit water?
5. Cost is not the major factor. Cost is secondary to protecting
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in light of the above should we be comfortable with a proposed plan which
would allow the volume of toxic/contaminated water in the pit to more
than double before anything is done (from 25 bil1ion gallons to 56 bil1ion
:ai~ons) T~:s pra:c:~c ;:;!an....:~jd allow a :urface area of contamination
J '
.;f 487 acres. is thIs a clean up remedy? is this a remedy with reduces
the toxicity, mobility, and volume of hazardous waste? 1$ this a
permanent ~emedy or a remedy with will leave us with a perp':.:'.Jal
environmental crisis?
Unfortunately, past Superfund efforts have not met these goals of
permanent cleanup. The Office of Technology Assessment (OT A) has
conc1uded that Superf~nd "~emains largely ineffective and inefficient: and
"is not working environmental1y." OTA has concluded that the Superfund
program has too often :eU:ed for remedy technologies which would not
reduce the "toxicity, mobility or volume" of the the hazardous waste. All
too often Superfund has seUled for remedies short of cleanup. Given the
serious nature of the contaminants at the Pit we cannot al10w any remedy
short of cleanup. We must clean up the prob!em so t~at future generations
don't have to deal with it.
Specific comments on Butte Plan:
1. Needs to be stronger on demand for cleanup
2. Needs to spell out what appropriate/new technologies need to be
considered. Now it is too vague. Relates to real cleanup.
3. Sludge disposal-Need to also be concerned that if we dispose of 'sludge
near the Pit that we are not creating a new Superfund site of the future.
How would this near site sludge removal meet requirements of cleanup
listed above?
John W. Ray 915 West 6a1ena St.
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THE
Clark Folk
PendOrei1Ie
COAI.ITm
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MiaauIa. MT 5987T
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P.Q Bee Cl8 I
Butta. MT 597C2 .
40&'72304081 I
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P.Q. Bee 1096 '
Sandpoirt. ID 838IM I
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.\pril II. 1994
Mr. jack Lynch
Chief Executive
Butte-Silver Bow County
Butte. MT 5970 I
Butte-Silver Bow Council of Commissioners
Butte. MT 5970 I
Re: Berkeley Pit County Resolution
Dear Jack and Commissioners:
Butte people appear to be very unhappy over EPA's disregard Cor
their Berkeley Pit concerns.
. .
Enclosed is a packet of 2.1.D.3 signed petitions requesting the U.s.
: - EP A reduce the water level in the Berkeley Pit and clean it now. Butte-
Silver Bow residents total~ signatures; the remainder are concerned
Anacondans and residents of other cities. Approximately - Butte High
school students signed the petition yesterday. The petition now has a liCe
of its own. We estimate another thousand or two will come in beCore end
of the comment period even if we did nothing more toward gathering
community input Note that some of the attached signatories are
youngsters who listed their ages to convey their desire not to have to
worry over unforeseen fuU-pit problems in the year 2.022.
The strong desire of the people of Butte can be known by the fact
that most of these petitions (about 1,400) were gathered in less than two
days at [-Mart (Saturdays. Apri12nd and 9th). I believe somewhere
between 90 and 98 percent of those who were asked did ~ian the petition.
Those who did not were usually in a hurry. As you loot throup the
petition sheets. you'U find many of your friends and constituents believe
. a lowered pit level is bes~ Cor Butte. and that cleanup should start quick1y.
Butte-Silver Bow's draft resolution is very wen done. It has
CoaJ,ition support for the most part We understand the reason it focuses
mainly on technical issues is in answer to EPA's chaUenae that this must
be done to obtain any changes. However, social and economic issues oC a
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BERKELEY PIT
This enormous ~eep hole can be turned into one of the best
assets our community has. I will now t.ry to describe in simple
terms its cycle of operation. The sooner this project is put into
operation, the greater the benefits wi) I be for our community.
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1.
Start a massive tree planting operation in our area to .
supply the water purification plant with one of t~e main
ingredients for the water plant cycle of operation.
After 25 years some of the trees can be harvested on an
annual basis to provide the w~ter plant its energy and
~ purification material needed for its operation cycle.
2.
Create a large water and ice storage reservoir above the
town of Walkerville. This high elevation re,servoir will
supply our community wi th a cheap abundant supply of
clean high pressure water for domestic and fire pro-
tection. Also some of this water supply can be used
for tree growing, agriculture, mining, recreation, and
industry. .
3.
Design and build a water purification plant that will
process fifty million gallons of water per day. With
over twenty billion gallons currently in the Berkeley
Pit, it will take about 25 years to drain the pit. The
lowering of the pit water will improve the water project.
4.
Take all of the water from the metro sewer plant as well
as the storm water runoff that is now going into Silver
Bow creek. Install a water main from this' water supply
over to and down the Berkeley Pit wall to the present
water elevation of the pit. Because the pit water
elevation at the present time is much lower than the
metro sewer plants water outlet, the water will siphon
into the pit. Put a hydroelectric generator on a large
barge, the reason for this is as the water table drops
in the pit additional ":ater main can be added thereby
creating a higher water pressure source to generate
more electric power to be used by the community or
sold at a profit to the Montana Power Company~ After
this water leaves the hydroelp.ctric generator it is
captured in a large floating vessel and put through
the water purification plant. A note of interest is the
current cost of electricity to pump water from the
Big Hole River at Divide, Montana into Butte, Montana
(about $150.00 per million gallons). If we pump an
average of eight million gallons per day, the cost is
$1200.00 per day or $438,000.00 per year. With the
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WATER PURIFYING PLANT
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A simple, very tall, highly inzul~ted vessel like an immense
thermos bottle can be installed at an angle near the present water
elevation of the Berkeley Pit up to the highest pOint of the pit
wall. Wood chips or wood shavings are gravity fed by a hopper into
the vessel about one hundred feet from the bottom of the vessel.
Near this same point the contaminated water is inserted into the
vessel. Near the bottom of the vessel, hot clean gases from the
combustion process of dry wood chips and the air dried carbon
fi1 ters that were removed from the water purifying system are
inserted into this vessel. The combustion gases are kept below' the
burning point of wood or about 250 degrees Fahrenheit. Water:is
preheated by the combustion process to keep the combu~~ion gases' at
250 degrees Fahrenheit. This is the same water that is inserted
into the ~vessel. As the hot gases are driven up through the vessel;
the high in moisture wood chips are separated from moisture' by .
evaporation. The hot gases and heated '-'later vapor will continue' to .
rise in the vessel. to the top of the pit wall at its highest point
and at this point of discharge 'from the vessel a condenser." is
installed. This condenser or heat exchanger has. cold liquid"-
ammonia in it. The hot gases and vapor heat the liquid ammonia
enclosed in pipes to a high pressure gas or vapor. This action-
turns the. hot gases to cold gases and hot water vapor ~.to cold
water. The hot high pressure ammonia vapor is used to drive a
turbine or engine to generate electricity to pump the condensed
.water to the high elevation reservoir, pump contaminated water into
the water purifying vessel and to run the air blowers of the water
plants system. At the very bottom of the vessel the hot dry wood
. chips wi th the contaminate in them are taken to the combustion
chamber.
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Some of the water from the high elevation reservoir can be
brought by pipeline to and down a mine shaft close to the water
elevation in the mine shaft. A water turbine can be installed to
generate electricity because of the high pressure water from the .
reservoir. If this water has oxygen' put into it t~ produce acid
- that will solubilize the metals in the ore body of our area. After
many years of this water mining the contamination of metals to our
ground water should be eliminated. If this water that is high in
metals 90es into the Berkeley Pit it can be processed in the water
purifying plant.
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THE USE OF SOLAR AND WIND ENERGY
1.
Trees can be planted around the Berkeley Pit walls at
each bench level. The trees will absorb solar energy and
moisture from the soils. After many years of growing,
the trees can be harvested on an annual basis in this
area. This factor will reduce the transportation cost
from tree farm to water purifying plant.
2.
Solar collectors and solar cells can also be used for a
heat enhancer and to generate more electricity. The
glass products needed to make solar collectors can be'
taken from the garbage waste that now goes to the
landfill. This glass product can be manufactured locally
creating more jobs for this area. A note of interest,
large amounts of copper are used to make solar collectors",
and arsenic is used in solar cell construction.;;-~,:.;'::~:.:;'~:' ,. ",' .
~Because our ,area o! this c?mmunity is~urr~~~~~
tall maunta1ns, w1.nd turb1nes can be 1nstalled~on""'the',::"~:.,,
tops of these regions that can be used as an t!1eetrlcal ::'~-0:";'::
supply for the melting of glass and metals usediD:the
solar collector and solar cell manufacturing proceSB~'~:" '~~',',
. . .'-.~..:. .". :~:.~~.
Many other combustible products can be taken from oUr'
garbage waste stream such as paper, tires. and used, : '
motor oil. Also, the many plastic products can ,be Used
for insulation products and material products for 'solar
collectors construction.
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EFFICIENCY CYCLE WINTEH AND SUMMER
By changing the flow path of the ammonia liquid and vapor this
water purifying plant will have an efficiency ratinq of over eiqhty
percent. The wood product will cost about fifty cents per one
hundred thousand B. T. U. This efficiency rating will give us SO, 000
gallons of clean water at the high elevation reservoi~ for $ .~O.
The people of the present water system pay close to $2.00 per
thousand qallons of water. ,
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SUMMARY
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The sooner the E . P . A. ,HDHES, . Arco and the communi ties. . of . '
Anaconda, and Butte Silver Bow accept the project design and ideas
I have described in this text the sooner the region can have the .
vast array of high-tech, hiqh paying jobs that are now needed in
our area.
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POWERSHAFT
LIMITED
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proposal /,.1':
'Albert J. Molignoni
I.' Creation of Water Storage Systems
Creation of High Efficiency' Electric Generation
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;:r:;uct~:eation of Water Storage Systems
/ ::; ,;~IJ lIving D.na U:-aveltng in the stale of McnU:lna, i have wItnessed
: I/.~ e:(ploltalion of the state's nuneraL and [o:sll fuel resources. from
: l~::se observations, [ have concluded thatth(~ inevitable depletion of
h~se natural resources wlll result in a con~~lderable reduction in the
":..::\.8'5 ','reallh The following proposal has been educed as an
'!\':)rnaUve source of monetary and energy needs for the state of
',fontana. Development of this concept was derived only after
(;.~Lensive research on wind energy, solar energy, and
~hGrrClodynamics.
The projecL I propose is the c:-eation of a water storage system. This
:.;ysLem Ylil~ utilize ~'fontana's land, water, vvind, cold and heat, to
uitimately provide a renewable energy source. Its success can be
achieved with the combined efforts of the federal, state, and LocaL
EovernmenLs. Farming, ranching, Limber, rnining and recreational
groups will also be required to participate in the deve1?pment of this
proJect. .
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The slale of Montana has a very unusual land siluation. Many of its
i'!J"eas are mountainous terrain; therefore, there are Land sites in the
';;Ulle that are not suitable for agricultural production or recreational
purpose. Areas ,of non productive soils, such as those left over from
n\ining, cornmonly take up one hundred acres or more in this slate.
Tirnber areas and other smaller sites can al~:1) be utilized for the
creation of this project.
. i1/ater
'Vi ~ler is a nalural resource that this state hflS a great abun.dance of in
':crtaln times and very little of during a drought period. The
c~:ltromng of this resource in the past has been with the use of dams
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'£li c:;:se! ';""on, ihese methods of 'dsl' management worked in
.' ,~:(:? ::8.::" ':-::'''';'. ~;-~sent and fulur-e demand !or water will increase if our
'':~8.Le !S 1.0 con t:nue a growth period for SlJ'::h indusLries as agriculture.
:_l~ltber. rninlng, recreaLIon, Industrial and domesltc, The following
paragr~phs on wind, cold and heat will glVC a general description on
:'\0'''' thG project can be successful. '
W'lnd
This re~tJurce of energy is one of the prim~ry sources that will be
'_ised to place Lhe waLer on the lund mus:; thDt "tIus described earlier in
. lhe.texl (See Land). The reasons for using this 6nergy source are the
following:
I. 10 supply electrical energy for pumping the water from a supply
source to the land storage area,
2 10 S'~lpply electrical energy in the non .'producing water storage
:'11onLhs that can be SOld, or used as a credit at a laler dale for
;Jllrnplng of water to the land storage in the producing months. This
c:Li"cum~;Lance will occur when the wind energy is not sufficient to
:')r'odllo~ electrical energy during the waLe!' sLorage months.
j \Nlnd 15 one of the most reliable energ'/ :;ources that Montana has.
!hls IS [-'roven by past studies conducted for the state on wind energy
. .
Cold
P-. natuI'Cll event lhat takes place in our state at certain times of the
, 'lear during our fall and winter months, Some people curse it and
others t.hink its wonderfuL, but it is also one of the main ingredients
for the project design. Wi~h the cold. wind, water and land. massive
ice storage systems can be created for our stale lo insure an adequate
\vater supply for fulure use. The system design will place the water
on the land storage area (See land). The massive blocks of ice are
created by putling the water on lhe land when the air temperature is
below freezing, In return. the waler will freeze frorn the bollom up,
This process is ~nlike the one that takes plnce on Lakes, rivers or
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,;tt:reams"wnere water ;;-eezes from the top cowrn...ard 'When the
. -,,'ater is rrczen from the Doltom up, the Ice struc:lure created 1S one of
~he [Clost stable forms for the storage of the water. The benefits of
:tonng water in this Lime frame and manner are:
l 'Ha~er used to cre,lle the ice storage unlt.s in the winter months
;':Cln te ~IJpplied by lakss, rivers, streams (;1' well:;. In this time frame
:.~C cemand [or the sLates water is at its lo"':est level.
2 If the water used to create the ice storage uni.ts is supplied by a .
underground pipe line. or a self draining pLpe line and stored at high
!;ievations, it It/ill create a water line with high h(~ad pressure when
the (ce melts in the spring and summer months This energy source
can be used (or hydroetectric and high pressure sprinkler systems.
3. By using a geothermic water supply I Lhe ther-modynamic principle,
and. cole air temperatures, an energy source is created to supply the
pumping of water in this time frame. Solar can also be used as a heat
source.
IL These large stable ice units can be used in the winter months with
snow cover for such winter lime activities as skiing and snowmobiling.
r; SLoriJlg water in this manner will provvif; a gr-adual water
(!Ischarge during the spring and summer rClonths for the support of
c~gncultural, timber. mining, recreation, industrial and domestic
needs
lle8t
711e last natural resource that is needed to complete the project.
design is heat. The heat energy source will accrue during the spring
a nd summer months. This will provide the means of melting the tce
storage systems. Therefore. an ample water supply will be created for
the growth of our slate. The heat from the sun in the spring and
summer months, coupled with the cold waler from the ice storage
units. b6nefits in creating a energy source by the use of the
therrnodynaffiics principle. It will a1so be noted that if a high
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: 8XC<3S::; '(later "'fill be ind\lCed inlo Lhe sLate's aquifer for storage. The
'.,'aler can then be used aL a later date vlh~n. needed: such as in the fall
'_:'..ln~.g ~he non -producLive months of L:-:e Lce storage systeros.
5ummarv
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Upon reading the previous text on. the general descnption of the
pro j ecls design. iL can be understood by the average layperson that
lhis process is already taking place in our sLate with the four seasons
of spring, summer, fall and winter. With the added technology of the
~;Lale's uruversity system and people with the expertise on the project
design Clnd development. the project goall~~ obLainable. The spin off of
rtLgh -~ech as well as olher jobs associated with the project design and
construction are Loo numerous Lo mention. The additional benefits of
Lhe project are: .
~. An i'1c"ease tax base for the state clue Lo the taxable valuation of
'.he prcjects components and addition~1 ~j(dl under culti~ation by the
"Nater
2. An indusLry created to design and produce the components of this
project design to other areas Lhat have the same or similar
-;eographicallocation and climatic condition..
3 The abundant supply of jobs to maintain the system as well as
other jobs associated with the incr~ase of water and energy suppLy.
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/ '~he pnme sources of elect~iCJI generation In Montana are
: I ydroelectric and steam. Vvind generallon has also been used in small
'~uanlilies Lo produce electricity.
Creation of High Efficiency Electric Generation
:-iydrOelectric production is sOlely reliant on mother nature to
produce enough moisture from the snow and rainfall to fill the
:-'eservoirs with water for genera Lion. In addition to providing a clean
supply of electrical energy. hydroelectric dams manage the water
';upply to the consumers in the state.
~jleam generation is produced by the burning of our state's coal
~;upply. The efficiency of this type of electrical generation is around
'-hirt y percent. This means that seventy percent of the coal's heat
!)nergy is wasted. Coal is not the only type of fossil fuel that is used
ineffICiently in Montana. Gasoline and diesel fuels in today's internal
combustion engines. such as automobiles, trucks, tractorsand trains
very seldom reach a efficiency of forty per"cent.
Montana's extreme temperature variations, seen throughout an
. nnnual period, is another source of clean energy. Water, cold weather
In the below freezing months. and hot weather in the late spring and
:::ummer months, are the basic resources needed to create massive
rlmounts of energy inexpensively. For the past several years. I have
desIgned and patented a unique high efficiency engine and heat
':;xcha,",:'l'"'g s:":..::-.-". This ~y~i..em oc;;sign, with the usage of ammonia or
rreon, produces a efficiency of eighty percenL. Adoption of this type of
energy system, in conjunction with the ice storage units, WOUld
:>roduce extensive amounts of water and energy cheaply. The
~ollowing text will give examples of how this type of system can be
lised in our state. .
C;tiesand Towns
Present sewer and garbage disposal systems are abundant supplies of
energy needed to make the system successfU.L The heat energy
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r H:'edeci for the s"fstem would be derIvec! f i l)m 'dar-m waste water in
.' ':ommunil y se'rter dlsposal systems, and U 1'3 hIgher temperature heat.
';0urce lhat. can be supplied by ether inClr)(7ratii 'g garbage or the
:-::;urning ot meLnane gas produced by our ::ewer plants. Cold air is the
':sndensing agent needed to complete the en.ergy cycle of operation
:.:ullr.g :::e c8:d 'rleather months. Processed water from the sewer
olant C'-lrino the cold weather operation 'dIll be used in the ice storage
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:;'(SLem. This cOld water supply is used as (l condensing agent during
~he hot 'rleather cycle of operation. Local governments could realize
(lddiLional income by selling the vast amounts oi electricity and water
produced by the system.
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Timber Indus! ry
The wasted wood products that are not used in our state'.s forests is
unbelievable. The simple economic reason is the wasted wood
products that are created from loggi~g, lirnber thinning, and trees.
Lhat insects destroy are not in demand. Present use of waste wood is
by home owners to help heat their dwellings. The high cost of home
heating c:-eated the demand for Lhis type of wood burning.
New technology for clean burning of wood prod..lcts, combined wilh
Lhe high efficiency energy system design v/ould create a large demand
!or wasted wood products. The lumber industry already has the
cquiprnent needed to bring the wasted wood to a mill or a convenient
site for the burning of this product in the high efficiency eoergy
sysLem. Adoption of this system design would create an. abundant
supply of cheap electricity, jobs, and addilional cash flow to the limber.
Industry.' . .
Agricultural Industry
. Farming and ranching industries face a very unfavorable growth
period in Montana because of the increased demand for waler by
agricUltural, commercial and recreational groups. The stale's present
water pOlicy is unfavorable because added storage was not develop to
Insure a adequate supply of water for the growth of agriculture.
Ranch and farm industries already have enough problems with
-------
I / . '" h . Lh" '
/' :.iCU~L1~ l:J.sec:.:; ~QW crices ana nlg Laxes La rn(:u~e elr OUSlness
. 0' ,~
1JnprOflLable.
A n10bile unit can be used for this type of eL'lerg"/ production. The uniL
can be moved from one location Lo another" for the ice and energy
~)roducl1on, Also, if there is a major malfunction with the energy unit.
::: clfferen.L unit can be broughL in to produce the energy while the
original unit is being repaired. The automated unit would require
very liLlIe time and effort from the operator, thereby releasing the
person for other duties that are required for the farming and
ranching operation. Additional cash flow from the sale of electricity
frorn the unit would insur-e the usage of thl:; sys~em during high
periods of precipitation to increase the wat.er table of the state's
aquifer.
Utility - Public and Private
The vast. untouched natural resource of MontanJ.'s heat and cold is
. almost impossible to described. We have failed in the pastlo utilize
this abundant source of energy. Public and private utilities of this
sLaLe, with the systern design, would be able to produce large blocks of
E:lecLrical energy that can be sold to other sLates, thereby increasing
the cash flow into our staLe. If exporLatior. of electrical energy is
Laxed. the added income would benefit this state The sale of this
energy at a reduced raLe within the staLe would entice industry, that
consume large amounts of electrical energy, into this sLate.
I1lnlng Industry
Mining concerns have one of the best potentials f0r the system design.
Energy generation and ice storage will creaLe an abundant supply of
'in.expensive electricity and water for mining. The increase of demand
[')r lime and phosph~te for fertilizer by the agriculLural industry
\dould reopen old mines and create new ones. Copper and aluminum
ii:ldustries are also great benefactors, because of the large amounls of
copper and aluminum metals in Lhe enerfr,.- syst.l3m's parts.
-7-
"
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#creatiOnal Industry
/ The added wC1t.er supply would insure a lncrease in the recreational
: L1d~stry, in Montana, A sufficient w~ter supply would incr~~se the
f'3ea precucls [or the big game and fishing mdustnes, Additional
cuanUtles of 'dater would also tenefit such industries as boating,
-:-':~":1ns, 8nd other related act:"'llties heavily I"eliant on an adequate
'.','ater Si..lp~J./. The potential of the state's Ice storage units is 20
i'i'lIltion or [£lOre in acre feet of water.
(.~, .,......, ,~,...
_".'1 .. ,m~/. y
Upon the sLates adoption of this type of ice storage and high efficiency
(:':nergy system, a meeting should be set up with a group of
professIonal people with the expertise on this subject maLLer. The
meeting would have to be held in stricL confidence because of many
!deas I have 00 the subject matter that fClay be patentable,
Coropensation is also a facLor that has to be deal~ with due to the
rnany years of time, effort, and expense t.h:1t were necessary to create
this system.
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ARCO ~ ~
: ..:.: --;". .
..
B8
BSB 11
-7 ~:"''':'''~ ~.:~ ~-:; .:"
: .::~,r- ~ ';.:'5 :-:: :':-::
- - 3 -: : - ": a .~,...... -: .. ~ ::-....
April 6, 1994
~fr. Jack Lynch
Chief Executive
Butte-Silver Bow Coumy
Counhouse
Butre, ~ft. 59701
Council of Commissioners
Butte-Silver Bow Coumy
Counhouse
Butte, Mt. 59701
Re: Response to Butte/Silver Bow Government's Draft CommentS on the Mine
Flooding Remedial Investigation/Feasibility Study (RI/FS)
Dear Jack and Commissioners:
The following are ARCO's responses to Butte/Silver Bow Government's (BSB) draft
comments on the Mine Flooding RIIFS. ARCO's responses follow the same four
headings that BSB's comments addressed as follows:
1.
Assurances/Scheduling for Construction of Tr~tment Plant
Comment: BSB states that there is "no absolute guarantee" that the Critical
Water Level (CWL) of 5,410 will never be reached and as a result, a tirm schedule for
building a treatment plant should be made a pan of the Record of Decision (ROD).
Response: There is indeed a very definite Uabsolute guarantee" that the C\VI.
will never be exceeded because the PRPs have signed a consent order in which they
have agreed never to allow the water level to exceed the 5,410 elevation or violation of
that order would result in penalties of 525,000.00 per day. Additionally, the EPA, as
pan of itS Remedial Design/Remedial Action (RD/RA) process which will immediately
follow the ROD, will require the development of a detailed schedule for treatment plant
design. construction and a shake-down period. It's imponant to remember too that the
5,410 CWI. already includes a 50 foot safety factor.
Comment: BSB believes that a reversal in gradient and ground water t10w
could occur at a We3th~:ed t:~drock saddle at the 5,350 level and therefore, this level
should be used as a staning point to trigger action.
..,llnllC Rel"''''' ~"'tnOl",-,
-------
Response: .;RCa suggests that rather than basing this "trigger action" on an
elevation such as the 5.350 foot level (a point at the top or weathered bedrock as
suggested by aSB), it should be based on a given period of time (i.e., )-5 years at the
then current rate of water ievei rise) to allow enough time ior design, construction and
shakedown of the treatment plant.
Comment: An additional buffer of 15 feet should be added to the CWL to
accommodate the tailings that couid r10w into the Pit after a large eanhquake.
Response: The RIfFS analysis performed by Harding Lawson Associates on
the Yankee Doodle Tailings Pond (YDTP) determined that a release of tailings to the
pit should not happen even under the" maximum credible eanhquake" scenario. The
State of Montana. specirically DNRC. will monitor the YDTP to ensure itS safe
operation into the future.
Comment: The CWL should be lowered an additional 75 feet to take into
account the period of time needed to make a treatment plant fully operable.
Response: ARCa agrees that a "shakedown" period is needed to make the
treatment plant fully operational; however, the two year period will vary depending on
the type of treatment plant chosen. Also. the water level rise in the future will be much
slower than the current rate of 25 feet per year because the hydraulic gradient will
continue to decrease and the volume of the pit available for filling will continue to
increase. Also. see response to the second comment above.
.,
..
Enhanced Monitoring Program/Public Education
Comment: aSB recommends that two additional monitoring wells be drilled in
the region southeast of the Berkeley Pit and one adjacent to the East Continental Pit.
Response: ARCa agrees that the bedrock aquifer contours need to be extended
south and east of Well "C". However, ARCa believes that one additional bedrock
well, if properly located, will provide verification to the bedrock aquifer contours that
no water is migrating south and east of the Berkeley Pit. During a recent conversation
with BSB representatives, it appears that the second well requested near the East
Continental Pit is no longer necessary because two monitoring pointS already exist, a
shaft and a sump, in which Montana Resources monitors water levels both at the nonh
and south ends of their operation. ARCa does not agree with the basis for the third
well requested between the Berkeley Pit and the East Continental Pit because it falls
inside the outer wells verifying the inward gtadient, including the n~w Well "G"
southeast of Well "C".
3.
3.1
Innovative Technology: Call to Action
Technology Alternatives
Comment: BSB suggests that an evaluation of combinations of the 19 remedial
-------
technology" research on waste remediation being done in Butte through a variety of
business ventUres.
Response: ARCa believes that any combination of two or more technologies
that individually did not work (for one reason or anOther) wiil still result in a combined
technology that would be screened out in accordance with Superfund criteria.
~ "
J..:.
Selected Tech::oiogy at Odds with ~1eta1s Recovery.
Comment: BSB does not like hydroxide precipitation because it precludes
future recovery or metals.
Response: The fact that a hydroxide precipitation treatment technology was
selected as the basis for the RIfFS costs does not mean that this type of treatment plant
will b~ constructed in the future. The RI/FS process only requires that a technology
exists to meet all of .he current discharge requirements. However, ARCa is interested
in any available technology, future or present. if it is more cost effective than the
technology found to be adequate in the RIfFS.
. 3.3
Sludge Disposal - Not in the Pit
Comment: BSB says sludge disposal in the pit is unacceptable.
Response: ARCa is open to other options for disposal of sludges that are
equally effective. However, there will be many regulatory and legal "hoops" to jump
through, which will involve local government's help and leadership, to find another
suitable location.
3.4
Better Analysis of Non-pit, Sludge Repository Options
Comment: BSB wants the FS to better define the tasks of siting and designing
a non-pit repository.
Response: ARCO agrees that it is not easy to site a repository for treatment
plant sludges. However. until a treatment plant technology is tinally decided upon and
pilot scale testS have been conducted, no decision should be made at this time.
3.5
Loss of Orebody for Future Resource Development
Comment: BSB is concerned about the loss of future tax revenues.
Response: Any future mining of the Berkeley Pit has to include the costS of
dewatering and treating water to discharge standards along with other mining costs. just
as any other mining company does when they develop a new ore body.
3.6
Conclusion re: Innovative Technology
Comment: BSB suggests that the use of innovative technologies be written into
the ROD.
'\
{ \
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Response: To date, any proposed "innovative technology" has failed to meet
the Superfund screening criteria or impiementability, effectiveness and cost. ARCa is
not opposed to using an innovative technology if it mee~s all of these and other criteria
used to select the best alternative. ARCa is always open [0 looking at COSt effective
::reatment alternatives that protect human heaith and the environment.
Comment: BSB does not want additional waivers for restoration of
contaminated aquifers.
Response: The EPA has stated. that it is technically and economically infeasible
to remediate the contaminated bedrock aquifer. In addition, it may be appropriate for
no relT'ediation of the bedrock aquifer to occur for the following reasons:
-1. the bedrock is a tight system and doesn I t yield sufficient quantities of
water suitable for well development;
the bedrock is very expensive to drill for domestic well purposes:
the bedrock aquifer has not been utilized in the past and is not earmarked
for use in the future; and
given the adequate surface water and groundwater supply in the region
and the relatively flat population growth, the current water supply is
more than adequate for any reasonable foreseeable future growth.
.1.
Waiver of Requirement to Restore the Bedrock Aquifer.
2.
3.
4.
If you have any questions or commentS on these responses, please feel free to give me
or David Sinkbeil a call at 563-5211.
I'
/.
D. E. Sinkbeil, P. E.
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BSB 12-A
BSB 12-B
rlY
BSB 12
7.
Excerpts of Council of Commissioners Regular Meeting
April 20, 1994
COUNCIL RESOLUTION NO. 1635
A RESOLUTION AUTHORIZING THE SUBMISSION OF FORMAL COMMENTS TO
THE U.S. ENVIRONMENTAL PROTECTION AGENCY REGARDING THE
:\EMEDIAL INVESTIGATION AND FEASIBILITY STUDY FOR THE MINE
?LOODING OPERABLE UNI~, WHICH INCLUDES ~HE 3ERKELEY PIT .;ND
UNDERGROUND MINE WORKINGS; AND PROVIDING FOR AN EFFECTIVE DATE
HREREIN. Chairman Brophy moves that Resolution No. 1635 be
place on its final passage and passed. Commissioner Heard
seconded the motion.
At this point of the amending motion, Chairman Brophy moved
that the Co~ncil amend page 5 of Exhibit A or Resolution No.
1_635 in accordance with the attached memo from Jon Sesso,
Steve Blodgett, and Mike Fitzgerald. The motion was seconded
by Commissioner Heard.
Jon Sesso requested to add the italicized paragraph on the
attached memo and also requested that No.3 not be associated
with Resolution No. 1635. He also noted that several items on
the reverse side of the attached memo are cause for concern.
It is his intent, on behalf of the county, to submit these
addi tional comments and questions to the EPA before the
comment period is closed.
ReDresentative Fritz Daily addressed the Council and stated
that the Critical Water Level is the real issue, but we cannot
change it, so we should look for the next best thing, which is
to corne up with another solution to the problem. Mr. Daily
further stated that the electricity involved in pumping will
be the major expense in EPA's present proposal ~- EPA and ARCO
have ignored this. It is important that EPA knows that we
support active mining.
Marv Kay Craie of the Clark Fork Coalition stated that she
thinks we can change the Critical Water Level. Ms. Craig
requested to submit 4 documents. The 4 documents are as
follows: .
1.
An ad, which was run in the Montana Standard on April 8,
1994, called "Clean Up the Berkeley Pit-, as it lists
some of the community's concerns.
2.
An invitation to the children of Butte to the Pit Rally,
on Sunday, April 24, 1994 at 1:00 p.m. in the parking lot
of the pit. .
3.
A letter from Barbara Archer addressing her concerns
about the Berkeley Pit.
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BSB 12-C
BSB 12-D
BSB 12-E
BSB 12-F
BSB 12-G
BSB 12-H
BSB 12-1
4.
A letter on addition, which Ms. Craig read to the
Council. She would like to recommend a new plan on the
pit Resolution.
Frank Ouilici addressed the Council and stated that he thinks
we should fix the pit for our young people, we should clean it
up.
Dr. John Ra~ stated that we need a strong statement regarding
the use of lnnovative technologies. Dr. Ray al~o stated that
he thinks there is too much emphasis on cost rather than clean
up. Dr. Ray also urged the Council to leave the strong
wording in the Resolution.
Stephanie Jennings from the EPA addressed the Council to
inform them that the~e would be a public hearing in the Butte
EPA office, Monday, April 25, and Tuesday, April 26, 1994 wit~
an open microphone for anyone who wishes to make a public
comment.
Dr. Georqe warinq addressed the Council and stated that the
only people who are able to have any influence are the elected
officials. He used to teach Commissioner Laramie at Montana
Tech, and that he was a little jealous of him for being able
to cast a vote on such an important matter. Dr. Waring also
stated that he feels that the Council is being swayed by the
PRP's.
Matt Casick addressed the Council and requested that each
Commissioner state how they intended to vote on this
Resolution.
Commissioners Heard, Curry, Brophy, Kerns, Thatcher, Laramie,
McClafferty, Lee, Kerner, and Donaldson all stated that they
are in favor of Resolution No. 1635.
Commissioner Heard is for the proposal that is prepared for
the Commissioners by Mr. Sesso. It is the best route to take..
Commissioner Curry supports the resolution as it is the best
offer. Chairman Brophv said they are concerned with the
future, and that they had to add a little common sense and
good judgment. They are a1so concerned with the economic
welfare of this community, and have tried to balance their
decisions. He makes no apology for voting in favor of this
resolution.
Commissioner Kerns stated that they must be very cognizant of
the people who rely on the mining jobs. The water levp.l was
addressed, while coming up with a solution that will protect
the best interest of Butte. He supports the resolution.
Commissioner Thatcher feels that the proposal is a viable
solution. He is frlghtened by the dec:.sion that is being
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BSB 12-J
BSB 12- K
made, and he supports with some reservations, because it is
~~e best of:er now.
~o~~i=3ioner ~aramle supports this resolution, due to the fine
plannlng or ~ne s~aff, the input of the public, but also has
some reservations. Commissioner McClafferty supports ~te
resolution, as this is the best solution now. Commissioner
:ee :eels ~~e major issues are addressed as far as the clean
up.
Co~~issioner Kerner supports the resolu~~on as presented ty
t~e staff. She feels the new amendment leaves the cleanuD
ODen ended. .Commissioner Donaldson will vote in favor of the
resolution, and agrees with Commissioner Heard's comments. He
said that Mr. Forba mentioned cost-effectiveness three times,
",.,d he does have a problem with this. This resolution
addresses those concerns.
Chief Executive Jack Lvnch stated that the situation calls for
enhanced monitoring and innovative technologies. Mr. Lynch
further stated that we do not want to force an issue that will
result in the closure of Montana Resources, Inc.
Commissioner Heard stated that he feels confident that the
Council of Commissioners accepted the best available
technology information and that it is a misconception that the
Council did not look at all the information.
County Attorney Bob McCarthy suggested that the Commissioners
consider amending exhibit A, on page 5. Mr. McCarthy stated
that if it meets with the Council's approval that the words
'and proposed plan' be added after the word study on page one,
lines 3, 11, and 20, page two line 23, and on page 3, line 10.
Also he suggested adding the words 'City aDd County of' in
front of Butte-Silver Bow on line 24, of page three.
Chairman Brophy moved that the amendments be passed.
Commissioner Heard seconded and the motion passed with 11 ayes
and 0 nays.
Chairman Brophy moved to include the bold and italicized
portion of the attached memo in Resolution No. 1635.
Commissioner Heard seconded and the motion passed with 11 ayes
and 0 nays.
-------
'"
~here being no further business to come before the Regular meeti~g of
the Council of Commissioners, it was moved by Commissioner Bro1?hy.
seconded by Commissioner Heard and carried by unanimous vote to Rise ~o
the Call of the Chair.
~he ~ee~ing adjourned ~t
APPROVED
3Y
THE
COUNCIL
ATTEST:
- ::.m.
OF
COMMISSIONERS
I 1994.
THIS
DAY
CHIEF EXECUTIVE
CLERK AND RECORDER
4
.JF
\ ~
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T
.y~ .~'? 94 'l(wh6}'
810
BSB 13
'IOXT.\X.\ noes}: Ot~ nt:Pl~t:SEXT.\TIYES
REPRESENTATIVE FRITZ DAILY
-'JuSE C!S';'RIC':' 69
"ELENA AOC~ESS:
:;'PITOL S':'ATION
"'E~ENA. MO...TANA ~9620
Apnl 19. 1994
;.-tOMe Aoo~ess:
'C57W STeeL
9UTiE. ~ONTANA ~970'
Jack Lynch. Chief Executive
Butte-Silver Bow Counhouse
Butte. ~IT 59iO L
Dear Jack:
I am writing this letter in response to the revised county resolution concerning the
Berkeley Pit RIIFS. I would like to still go on record as being supponive of the general
thrust of the resolUtion. However. I would like to address some of the changes that were
made. and also to readdress some of the suggeStions I made at the public hearing.
~ty main area of concern has to do with the changes made to the section dealing with
the construction of the treatment plam. TIle primary objective of the RI/FS was to establish
the critical water level. However as you know. the critical water level was established at an
elevation of 5~ 10 feet before the RIIFS was ever started. While this level mayor may not be
accurate. it probably will not be changed withoUt the benetit of another scientific srudy. This
number was eStablished with a consent decree. and truly is the only decision that is caSt in
stone. I would advise the local government against getting caught up in thenumbers game
the PRP's and the agencies so admirably play. I believe your original decision to have a
construction plan available when the water reaches the bedrock-alluvial imerface is still the
best and safest solution for the conunwuty.
I am sad to say, but I have reached the conclusion. the only way this problem will
ever be solved is with the benetit of an independent party. Eventually Metanetics. Montana
Technologies or some other similar company, will develop a method to turn the liability into
an asset.
It is also stated the scientific work performed by the Montana Bureau of Mines
indicates the conununity is safe for the next several years. I have been advised by the
admilustration of Montana Tech and personnel from the Bureau, that they are not decision
makers, but information providers. The information they provide is used by the various
parties to make the decisions. If you have documentation which indicates the Bureau
-------
I also testified at the public hearing that I felt a strong statement should be made in
rhe resolution indicating the imponance of the continuation of active mining. As elected
officials we are forced to walk a rine tight rope when it comes to making decisions in which
we have to balance one of our main economic resources against the safety of our commWlity.
Every anempt should be made throughout the process to assure the continuation of active
mining. Every anempt should also be made to assure the economic. social and environmental
safety of LtUs cammumry. I regret Montana Resources did not suppon the legislation I
proposed dunng the last two legislalive sessions. TIlls legislation would have provided the
impona.tlt safety net this commwuty is now so desperately seeking.
Again. r conunelld you ior the pro-active roll you and the commissioners are taking. I
would make myself available !o answer questions or concerns you might have. I look
forward to COntUluing our work in rrymg to develop a responsible solution to this very
difficult pro~lem.
Sincerely.
Q;;i
cc Council of Commissioners
Don Peoples
-------
7HE
Clark Fork
Pend Oreille
COALITICN
~
......-~
. po. Box 7593
Missoula. MT 59807
406I542-G539.
PO. Box 4718
Sune. MT 59702
J06I723-4061
PO. Sox 1096
SandDOlm: ID 83864
2081263-4347
811
BSB 14
:"pnl 20. ; ',:',14
\lr. "Jack L V~C:1
Cuef E!ec:Jt:':e
:::"..o-,ii",-Q.. ':).......... ......~:._...
-' .............. - "'. ~.... -....'" ..,...,1...,,,,....:
:u~:e. \rT 59~Q I
::tme-Sii";e: 3aw Caunc:l ai C:=::l~~iane;~
3utte, \IT yr;.o I
Re: Berkeley Pit County Resolution -- Addition
Dear Jack and CommissIoner~:
T~e Re~olution vou have before you tonight in many respects
sImply puts a schedule to the EP.\-.\RCO plan to delay until 2.022
c!eanmg and jisc~arging pit water :0 Silver Bo~. Creek, Our c:11culations
from the information in the Resolution presented last Wednesday indic:1te
~t '7I.'i11 ;,e 2.01:' ~efore anY~hmg would happen under the Butte-Silver
30~' ResolutIon. Perhaps that 15 the same schedule ARCO and EPA ~.ould
choose. '{our Resolullon does not :ake J stand in favor of action no~. u tt
sImply asks [olks not to focus on that. The people of Butte. especially
youngsters. prefer quicker Jction and ~'ould like you to advcc:1te such for
them.
So. rather than ~;ait near~y 30 years and hope and ~'ish for ~ew,
inexpensive technology for cleaning :he pit ~.ater, and rather than.
compiain with no solution. let's force ne~. technology to come forward
~o~.. There is nothing like a deadline to get things off dead center.
Competition. capitalism and market forces ::m bnng for~.ard the needed
,=ost effective tect.:lology and get it up and running within eight years.
Here is an alternate plan for you ~.hich Jppear~ ~atisfy technlcal Jnd non-
technical citizens of Butte:
An Acceptable Plan:
Require that the cleanup work forward from today, not
backward Crom 2.022. The Record of Decision could caU Cor EP A
to work with the Department of Energy and Butte's MSE Pit
Resource Recovery Program. MSE could send out a call
immediately, internationally, that any organization interested
( "
-------
in a piece of the Butte minerals pie must come forward with
their technology by a deadline date -- within two to three.
years. Companies can obtain investors to help them refine
their technologies now. If they are unable to finance the
needed work, they can take a chance that MSE will choose their
ideas for testing, using dollars from the Department of Energy
and, possibly, the new research dollars that Butte-Silver Bow'
asks CPA to provide. By the two or three-year deadline. MSE .
would have decided which -- one, two, or more -- technologies
should go forward into a pilot program. Also at that time,
work should begin on the pumping plant. because it would not
~have to be changed depending on the technology selected.
Within the following five years, the best technology would h~ve
been selected and implemented -- so that by the end of a total
of seven or eight years. a pumping and treatment facility would
be operational for the Berkeley Pit in Butte.
We continue to receive Pit Petitions daily and could easily obtain
any number of ~ignatUres -- at :east 90~ of all Butte citizens want to sign
it. We !)elieve ~he over 2300 signatures we gave you last week proves
~hat point. SInce !nore than 1400 came from the t\\.o days u:e had it at ~-
\tar!. ~'our c:::mtituents Jnd their c:lildren :lJve eIhibited great concern
that the EP.~ ~lan is not acequatelv protective of human health and the
environmem ::1 ~tat it poses a per;etual thre:lt of release of
contamination. 7~1ey ~'ant the ~'Jter to begm to be cleaned at the earliest
possible ~ime. .\nd they need your jelp. P!ease inciude in your
Resolution a request that EPA work today - ~ot in-2.022 - to cleanup the
Berkeley Pit.
You elre invited to a Pit Ral~y this Sunday. .\pril 24th at 1:00 p.m. at
the Berkeley Pit. Children and parents will sign a -Get Well 500:'r card
for the Berkeley Pit ~'hich will be presented to EP A.
Yours truly.
~0-C7
\1ary Kay Craig
t:pper River Field Representative
cc: \tT Congressional Dele~ation
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812
BSB 15
..l.pril 10. 1994
To: Council of Commissioners
From: Barbara r Archer. 302 W. Galena.
RE: C1~an.up of the Berkeley Pit
Bune. :V!T 59iO 1
The primary concern is not who pays and how much. but is rather the heaJth of
our citizenry and of the water.lhed. which :lI'e inextricably intenwined
The EP-A must begin the process of physically addressing the problem of 27 billion
gaJIons of toxic Water now. rather than puning it otffor 20 or 30 yem-s on the
premise that expens have assured them and us that the pit water is not a problem
and won't be until a certain critical water level is reached. That critical level has
somehow been established through modelling and interpolation of data and if
mcolTect. may have dire and pennanent ~onsequences on the groundwater system
of the entire valley.
Too many times "~xpens" have been proved \\Tong. We are dealing with a
~ompiex hydologic struCtUre and countless other variables. \\iluu are our
assurances when ~ven the experts :lI'e in disagreement about the dangers?
It is always easy to use 20-20 hindsight to detennine how to rectify miscalculations
and erroneous hypotheses. But 20-20 foresight is best achieved by erring on the
side of caution. Caution in this case means beginning today to fonnulate a plan of
action based on the best available technology, that being the technology that works
best.
A suggestion: .
( 1) begin immedWcJy and take 2 or 3 years to solicit rechnical solutions to cle:uting
U!' 1tte water.
(2) within 3 years. using market forces. have someone (1v{SE~) screen the
proposals and choose 2 or 3 to pUt into a pilot progr:un.
(3) test for d1rcc ycan
( ~) fifth or si'Cth yeOU'. begin pumping plant with the best available tccmology md
work out bugs in the system.
(5) seventh or eighth yeOU'. project established.
To begin doing what needs to be done by tl1e end of the centUry is a realistic goal.
If we can go to the moon. ~tc.. ifwe can ~ommit :5500. billion to bailing out the
S & L surely we can I.:ome up with a workable solution to the Water in the
Berkeley pit this centUry. ~ / .-
-.e-:t~-l'£'f:.« c.. - {r...L~A-
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,
~
I 1
:~:'JI;1G~~"1ENT AL
PAOT~CiION AGENCY
MAY
6 1994
MOt-IT ANA OFFICE
::,:s.i' i a ;"01' all1S
4280 Tl'a i 1 s Snd R,:>-::rJ.
14i ssou 1 a. :'!T '5980'3
i-Tay 4. 1 ~ ~4
?am Iii 11-=1""/
U.S. Environmental ;:~'ctecti')n Ayency
Federal Office Euildlng
Dl-awel- l C"l',II)
300 South Park
He lena. :IT :: ':16 :5-(";::: I)
Dear Ms, Hillery:
-:-11.)n).: you f",!' ,''?tul'nin'1 my dl-aft l'':\!)('l"t regal-oiinq t.hl:!
Bel-!l-:>y r'it. Mal'y i':~y had sent it olung. nfjt l-ealizing that th~
~nt ire /""O:>OOI-t ~ias ",:,r. ::uopost?u tJ' 9'-' t,) i:he EFA. I hope that you
will CI':C,,"pt: I:h0:>500> ':','IIUlll:!nt:s 'jrt the Nine Fl-:'oding Operable UnIt of
the 3ilv~l- Bow CI-:--=;-:iButtt? i\1""~'3. Superfund site. in lieu of the
report. Thanks aga i rl ,
I int'?r'lie\,olp.d .:, nl.tnlb~r' .)[ sr:-ip.!\tists regarding the IJpp.rable
unit: thoO>se includ,=, ,J,j!1nrlle ivY':")l'€, allll Bill Woessner at the
Univl:l-sity .)f M1:.nr.ana. and ~1al'V Hi ll/?r i:lnd Ted Duaine at M.)ntana
Tech. I interviewed R~pres~ntat:ivp Fritz Daily. St~ve Blodgett. a
CERCLA technical ::::~).:>ci.:\list. BnlCp. rt3rling I)f Trout Unlimited.
and Hark Shapley. a pl-ivate hydrolL""I9Y consultant. Aft-=l"
discussintj the Bo?!'k-=ley Fit: with t:h.:>s~ peo~le. I have the
following l"ec(,mmend-5ti.,:ms bf.Jsed on their concerns and cOlnments.
RECOMMENDATIONS:
*ThaL the pl'e(:~utional-y .'ip~l'.)a...:h dnu a toJid":? margin .:,f safety
be used to protect human health and the o?nvir'0nment. After 100
y~-:\rs .)f mining anri blasting a ("(,mple:< 'j~lji':'(.;ric area. it. s~ems
that there is sc,me -3~fl-e~ment: that thi? (WL should have a wide!"
margin I)f safety t.han 5.410. At this time. the numbel- IJf
monitoring wells does not sepm adequate. A well is useless if it
is improperly nlaced. Bas.;od .)n lhe ":'t)mple:-< faulting and
fractul-ing of t.ile <:Irea.III':'l-e wells .:.I-e neCeSSal"Y to get a
c('mplete I.Indersl.~ndintl ,)f the ilydrl)lr_'gy.
.The [J.:>t:ential e:-:ists fO:'l- (".:.ntaminated wat>:'!" ~l-':'III the Yankee
D(,odle Ti.d 1 incrs Fi)nd tf) t)(\ll!lte the 3i lvel- B.:,w Valli?Y, Sl(IW
nugl"at il.)n .:.r ,;u'l)unti \.;,Otr:i?r c(.uld be a pl-(.i;lem. if the flow 1 ines
stl"ai9ht:.t?n ')I!t: '.: -:,~=' ','Y,:>"'I. T1',:> ,-l-:\m 111':\\'- ,,:1:31-' be unsafe. Watel-
should nat be discharged into the tailings pond.
.All .:'llO:6.n '.-Ia1,':-1' ';lnd t-J-:\ste ...;":1t''?l- fr,:,m t.he minin'J ''''perati.:>n
sh.:'uld be kept .)ut ,:,f the t.ailings iJond and. t.he Berkeley pit.
Pr(.tA,.:tina the envit'o:;nrnt:?nt: slK1uld m~an that any clean watel- be
kept fl-0~ c0ntaminati0n, Under CERCLA. contamination is to be
ro:>duced. C.)ntaminat.:-,l mine W.,:,t.:1' sh,juid !It)t bt~ dlschal-ged intr)
-------
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,
I
,
. ,r ;:;I'~ "'r:tr,~r :';"J~i il'l "iI~ r'il ,-:>IJ,:;ois ,)1'( -=tntl 8tOpS 1'181n';I,
j1:. 3i-l'jlli,j Do? aSSIJIII.:-,j '::';.:.t -,h~ !-,it ::3 di:3('hal'gin~J wato?r and
pUlflPH1'J =:i1ljuic:i fran, :!IUII~dl'il.~i:{, 'Li'I additi,:.n, r:il~ 't25.\jl)l) fint?
si',,)uid ''»111':- int,:, .:-[~.;..:-': .'i:3 th>:, >:-nVll")nrll~ni.. is beIng liegraded. A
""at-=t' i lj,jG..;-~ ,:h;:,r ,',,;'tr.,.:-:':s.,.~' il"M :lIlj-:-;'1 WaT:-:-l' 15 fl'jwi£lg intI) th-=
r'll. w.:..ulrl h~i!-, d~ti:'I~ :";':''.1 1111)1:h wat",,!' n~.:,-is t,o be pump~d ,)ut. 1;:
Wi:ti,'2!I' 1:-:: i-::ajul'lq ':".1,=, ~t', 1:3 1IIlp')l'tanr T., l'~ai i::-,,.o t:.he diffiGu1.t,l
in pl'O:"':ll'l',] that W€1I,-=l' 1'= .:.',:i1.inLl the PIT, ::nd 1'I,:.t:. fl'OIll some (,thet'
:"';'lll'C'?, 11'1 -:L 8y:~t_.::!n 1[;'.'1" r ':1 ":''-l 1"{ 1:,07':'['l'?, !:'''''-'(1 \ ~ ;;nd ,3('i~I\(,~ ':-'\'1
and do ma~e nllstakes, ; ~0ntlngency plan must address this real
possibi 1 i ty,
.AR(f) should "'l::hel' D-:>\rin th~ tl'eatment pldnt NOW. or place
a bond IJp that Inr.!'J.Jes t:.h~ r~l'i,~", .)f th~ tl'~at.IlI>:>nt: plant. ThE'
clti=~ns ,)f Butte Jes~rv~ the assurance that the PRPs will have
r:he mc.n-:,y who:-n it. s needed. A b,:,nd is that assurance. 111\?
inter>:>st should be used t,) "i~[ray the '~',)sts 01: (\1',)re monitot-ing
we 1 Is,
*(ERCLA is SI.l0p,)sNl !'J) l',;>'.luce the amount ,~f pollutil,)n in the
area. The al'ea is sl;.11l bein~l de';rrad~d. ARCO is saving money by
not treatIng the '~0nt.amlnated water in the Pit n,)w. I l'er.;')ml1l~ncl
that ARCa be required to quantIfy the money not being spent and
that this money be used to:
1) pay [')1' nl')l'e 11l,)nl!:rJ!'inq welis to better understand
the syst em and pl-otect hljman hea 1 th. and
2) l'eSeo'll',:h -3nd devel'jp th-:- new technc.ll,)qy that will
ai iuw the profitable removal of the '.Ialuable luetals fl'om the
Pit.
"-:ho? ,::l~o'\n-![p ;=:.'h-:-.ht\'::' ~h"'II!d n,',r, j:,o?
01 the milung '-'~I~!'acion. 711"" ;:::F~
responsibIlity for the cledn-up now.
tiAd to the cessation
shvuld start taking
"'Community acceptance sh,)IJld. be given an extl-emely
pri0rity when sciences. su~h as hydrology and geocheOlistry
very complex systelll. which are inexact sciences at best.
public policy.
high
of a
set
Sl!"'t':erely.
Cok~
C ai' 1 a ALr-arus
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I't"cln' life JI \,. ,,' JIIlJ \\Iij .:,.1\\ Ip':'I,c).ht~1 n,... ~l. r-' I ~;'\
rnaturll~, .. .. " .' ENVIRONMENTAL ~
PholO, ~lichad FI"nc" Pi'" . -''"It+" ""
; '. :,:1' .~..~~Cy
~ 71-u.,,~ - !.2r~./ MAY 6"1994-"' -
~haAvdh' ~~i MONTANA OFFICE
~~;;:; ,,,,(, ~
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13
'f)I~MENTAL
P~".~tl~TION AGENCY
MAY
6 1994
MOl" r ANA O~FICE
Russ Forba
Project Manager
Berkeley Pit Operable Unit
Environmental Protection Agency
Helena, MT
April 29, 1994
Dear Mr. Forba:
I would like to submit the following comments on the Remedial
Plan for the Berkeley pit Mine Flooding Operable Unit. The fol-
lowing comments are based on interviews with a large number of
hydrogeologists, geologists and engineers who are familiar with
the pit. .
-
A precautionary approach with a wide margin of safety should be
used in setting the critical water level for the pit. Based on
discussions with numerous hydrogeologists, geologists and en-
gineers, I am convinced that the number, kinds and location of
wells used in the RI were inadequate to understand the complex
faulted and disturbed hydrology of the pit area. Hence there is
considerable uncertainty as ho~ pit water will interact with the
surrounding alluvial and bedrock groundwater as the water level
in the pit approaches the apparent surface water table level. A
more cautious approach is advised, such as maintaining the pit
level below the bottom of the alluvial aquifer. Given the consid-
erable scientific uncertainty about the pit, more weight should
be given to community acceptance of Remedial Plan since they are
being asked to take the risks. The technical experts interviewed
unanimously agreed that several critical wells were needed to
refine understanding of pit hydrology and that the current CWL
was set prematurely without this information. Given the impor-
tance of the CWL to protection of the area and the controversy,
requiring these wells is not arbitrary and capricious. If ~CO
wants this 5410' CWL, they should be willing to pay for the wells
to justify it. If they do not want to pay for the wells, they
must settle for a more cautious CWL.
All clean water entering the area should be diverted around the
operable unit and discharged to Silver Bow Creek. Clean water
should not be allowed to enter the pit or be diverted to the
Yankee Doodle Tailings Pond. The pond was not designed for this
purpose and the greater level of water in the pond would increase
its instability in the event of an earthquake. In addition,
putting more water in the pond increases the likelihood that
contaminated water will leak from this pond and further contami-
nate groundwater and Silver Bow Creek. Water used by the existing
mining operation should be treated to Montana state Water Quality
standards and discharged to Silver Bow Creek. The existing mining
operation should not be allowed to contribute to the problem at
the superfund site.
-------
./
If the water level in the pit stops rising without pumping from
the pit, then the water is escaping somewhere and the $25000/day
fine should go into effect until pumping starts removing the
amount of water estimated to be entering the pit. A careful water
budget is needed to determine how much water is entering the pit.
This amount should be pumped and treated. Once again, if the pit
level stops rising before pumping begins, the Law of Conserva-
tion of Mass says that contaminated ',yater is escaping and the
fine should be imposed until pumping and treatment corrects this.
The clean up schedule for the pit should not be tied to the
shutdown of existing mining (which cannot be predicted) but
should be based on meeting the Superfund mandate to prevent
;.ncr~asing environmental contamination at abandoned hazardous
sites. A timetable should be es~ablished now to build as soon as
possible a treatment system based on the best technology current-
ly available. New technologies will always be coming or line, and
we cannot wait to clean up sites until some future technology is
developed because we could always wait longer for a still more
advanced future technology. When a new better technology becomes
available, the treatment process will be modified to incorporate
that technology. Existing treatment plants are modified to take
advantage of new, more economical technologies as they become
available. We would never treat any waste stream if we argued
that we must wait until the next generation of technology becomes
available.
It is not arbitrary and capricious to require treat~ent now to
prevent an increase in contamination at this site and to reduce
the chance that contamination will spread. ARCO should be re-
quired to begin the planning and construction of a treatment
plant now or to post a bond now for the cost of such a plant.
This bond will be earning interest to pay for such a plant if
unforeseen circumstances removes ARCO from the picture in the
future. An innovative alternative approach would be to allow ARCO
to delay construction for some agreed upon time (e.g., 10 years)
and invest the savings of this delay in a research and develop-
ment fund that would pay for research into alternative technolo-
gies to treat the pit water. It is not arbitrary and capricious
to require ARCO to act NOW to solve this problem. The action
could be immediate construction of a treatment plant, or a simi-
lar amount of money spent on developing alternative treatment
approaches. Delaying addressing this problem for an undetermined
period (until mining ceases) does not meet the mandate of the
superfund legislation.
sincerely',
v ~ vJ ,.,,+7~
Vicki Watson, Associate Professor
Biology and Env. studies
University of Montana (for identification only)
2
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,."".' of Montana
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14
30 March 1994
Russ Forba
Remedial Project Manager
US EPA
301 South !lark
Helena. MT 59626
ENV!RONMEN.'."l
Pr:lOTECTION AGENCY
APR - ~ 1994
'40NTANA OFFlr,r'
Steve Mietz
624 South 3rd West
~1issoula. MT 59801
1406> 549.3513
Dear Mr. Forba.
Enclosed is my comments to the Butte Mine Flooding Operable Unit's RIJFS. I
hope you find them useful in your decision-making process.
I recently heard that similar reports were released regarding the Streamside
Tailings and Priority Soils in the Silver Bow Creek area. I am interested in
commenting on these projects as well and would be appreciate if you could send me
information about these projects.
Thanks for yoUr help in this matter.
Sincerely,
6t~~ 7;
Yn~!;---
-------
::3teve ~Iietz
Environmental Impact .-\nalysis
Professor Vicki Watson
Comments on Remedial InvestigationlFeasibility Study for
Butte ~line Flooding Operable Unit
I:STRODL"CTION
There are three major areas of concern with the choice of Alternative 6n as
the preferred alternative for remediation ofthe :\1ine Flooding Operable Gnit. The
first area of concern is in the CDM Federal Program Corporation work plan t 1990).
the assumptions and objectives that are derived from that plan. and the subsequent
Remedial Investigation. Another concern is the small margin of safety that the
current critical water level creates. The third major area of concern is that
Alternative 6/7 does not provide a long term remedial action that is permanently
"fixes" the problem. rather than simply de~ees of treatment. nor does it address long
term remediation and funding after the year :2025.
WORK p~~ TOO ~ARROW IN DEFINITION
The CD:\-1 Federal Program Corporation work plan provided the objectives and
CERCU and CFR provided the framework for the Remedial Investigation and
FeasIbility Study. The Remedial Investigation and Feasibility Study were completed
in an excellent fashion following these ~ding documentS. however. I feel the work
plan has defined the problem of human health and environmental risk from the
Operable enit too narrowly. and theretore led to a Remedial Investigation that was
too narrow in scope :md recommendations that are inadequate to protect human
health and the environment from the threats within the :.vline Flooding Operable Cnit.
The work plan limited the scope of analysis of dangers from "off-site emission"
to water only. This ignores a very important threat from airborne contaminants.
The only mention of this important threat to human health in the Remedial
Investigation/Feasibility Study comes in relation to distUrbed soils during
construction of remedial efforts. which was determined to be insignificant.
Moore and Luoma (1990) compiled several studies on disease-related mortality
in the Clark Fork Basin. including Butte. They found that Butte. compared to cities
-------
:: (eve :\1ietz
,)
19.59-1) 1 <.Ind wa::; tirst ..lmon~',)ther disea~e::; than heart and kidney" for the periods
i959-61 and 1969-71. Great Falls and Billin~s. for comparison. r:lnked between :350-
+.50 in all categories,
Trachea. bronchus. ..lnd lung cancer From 1970 -1979 were especially high in
<.Il'ea~ I){ "primary contammatIon', Silver Bow CuUnty had a mortality rate from
lung. trachea. and bronchial cancer per 100.000 of ,55.3 compared to :Montana's 31.1.
~orth Dakota's 20.5. Idaho's ~2.9. and Wyoming's 26.7 I Data from Riggan et al. 1983
in )'Ioore and Luoma. 19901. .\Ioore and Luoma 11990) also found that by looking at
female mortality rares thar the cancer deaths did not appear to be solely from
I)ccupational sources. '!'::ey found that during !he same i970-79 period that overall
cancer rates for Silver Bow County women fell within the highest 4 percent for all
C.S. Counties I Data from Riggan et al. 1983 in :Moore and Luoma. 1990).
The work plan assumes that the only threat to humans is from drinking
containment water from 1;I'0und water. Since past institUtional Controls have
stOpped the citizens ofBune from drinking the ground water. yet these abnormally
high cancer rates persist. it can be assumed that other environmental factOrs are
.putting people at risk. The work plan should have commissioned a more
comprehensive Remedial investigation/Feasibility Study that addresses the other
hazards to human he:lith mcluding airborne contaminants.
The walls of Berkeiey Pit are probably a significant source of airborne
contaminates. Different alternatives will affect whatever remediation might
eventually be prescribed for the walls. Therefore. it is unwise to delay considering the
impact of the pit walls on human r.:..lith. Any mme nooding alternative should
consider the pit walls at the same time. .\ study of the effectS of the pit walls and
recommendations for remediation should be included in a new work plan.
.\nother important area of consideration that was left out of the work plan
includes reclamation for aesthetic values including re-establishment of habitat
qualities. I bdieve that aesthetic values couid be reciaim~u oy establisning a
mandate to study options for ground cover of exposed areas t which would also
stabilize loose soils and decrease particulate pollution) and attempt to reestablish
riparian areas. At the very least. the 5 natUral draina~es to the north. east. and we:;t
of the Yankee Doodle Tailings Pond could be redireCted around the site to prevent the
clean water in these streams from becoming contaminated. Redirecting these
streams will create some aquatic and riparian habitat to replace the portion of the
original Silver Bow Creek channel that was destrOyed by mining activities betWeen
the Tailings Pond and the :VIR Concentrator.
I recommend that a new work plan be developed that 1S broader in scope - that
addresses not only the threat to ground water contamination. but airborne
contaminates. habitat 1~":1litie5. and aesthetic values.
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:3 t~ve .\lietz
:3
CRITICAL WATER LEVEL. MARGI~ OF SAFETY
All Final.-\lternatlve:::: ailow the pit water ieve! to approach the critical water
level. There is no plan to Jddress what happen:::: if there 1:5 a catastrophic event such
J:5 an earthquake or fire IDd the treatment and/or other remediation effortS are
damaged or stopped. The Remedial InvestigatIOn never describes how long the
treatment C:lI1 be ::::topped before degradation of the alluvial aquifer be~ns. As the
cntlcal water ievel is reached. how much or a margin of ::afety is left?
The Remedial Investigation 11994) includes the results from two runs of the
numerical ~ound water flow- model. The first model simulation was run with a pit
water Ie" . 4~ 5.050 ft msi ,feet above mean sea level) to evaluate the current alluvial
ground warer flow system. The simulated ground water levels were sufficiently near
the observable well monitOring points that the model has proven jt is a good tool to
determine the critical water level. The second model simulation was run with the pit
level at the currently proposed critical water level of 5.410 ft msl. The conclusion
from this run of the model was that 5.410 ft msl was an adequate level to prevent the
alluvial aquifer from being significantly impacted by pit water. However. the model
wasnt run to determine at what level the alluvial aquifer would be affected. .
The observed water levels in some monitOring wells are very close to the
critical water ievel of .5,410 ft msl. For example. the .~'IC-5 well has measured an
observed water level of 5,436.7 ft msl. That is only 26.7 feet above the critical water
level. That is a small margin of safety.
It is important to determine the maximum depth of the alluvial aquifer to
.decide how high the critical water level can be set. If the ma.'Cimum depth of the
aquifer is below the critical water level. contamination of the aquifer would be likely.
The .model's predictions of alluvial aquifer water level are based on monthly sampling
of well water levels taken since December 1991. This is not a long enough period of
time to assure that the observed water levels recorded are reflective of the .'uvial
water level's ma.'Cimum depth. Temporary effeCts like drier than normal St .-,ons in
the last few years could affect the data making it appear that the ma.'Cimum depth '2f
the alluvial aquifer higher than it truly is. The model second run was run using
current water levels which may not be reflect true aquifer levels and probably doesn't
ret1ect what the lowest possible aquifer level could be. Therefore. the model's
prediction of no or little effect upon the alluvial aquifer at the current critical water
level could be false.
The margin of safety of the current proposed critical water level is
unacceptable. There is no room for a catastrophic event or deepening of the water
level in alluvial aquifer. The rational for acceptance of the critical water level of
5,410 ft msl was that model predicted little or no impact when the water in Berkeley
-------
.:3 (eVe .\-lietz
4
Pit reached the critical water level I Remedial Inve:5tl~ation. 1994). Given the small
margin of :;arety that leaves along wIth current J.qwfer levels and the lack of data to
'O':3tablish the maximum !l)we:3t J.ilU\1J.l aqwfer water level. I believe the critical water
ievel of 5,4 10 ft msl is t00 high. .
Further re:::earch needs to take place to e:::tablish a more adequate margin of
::afety. All Final Alternatives contain !p"ound water monitoring proVlsions that beglns
Immediatelv. Contmued moniwring of ..uluvial water levels over many more vears will
increase the confidence or'the predictions of the maxImum deepest alluvial aquifer
level. .~ the conrldence I)fthe predictions of the alluvial aquifer water level increases.
periodic readju5tment5 I)f'Che ..::-:ncal water level :5hould be made.
The Remedial Investigation f 1994) describes the tailings pond dam as safe up
to a Richter- ma~tude or' 6.5. but w hat If a larger earthquake happens such as the
6.6 in California and the dam breaks and all the pond water goes into the Pit? Also.
.-\lternative 6/7 plans to divert Horseshoe Bend water to the tailings ponds during
mUllilg. The additional Water WIll put more pressure on the dams and dump more
watp.r into the pit ifthey fail. Since the critical water level will be approached with
.-\lternative 617, there is a large danger that the alluvial aquifer will become
contaminated if the dam fails. .-\lternatives 18/19 do not let the Berkeley Pit water
level to approach the critical water level and therefore are the best alternatives for
protection trom catastropruc events. that cause pit filling.
LONG TERM EFFECTIVESESS QUESTIONED
The claims of long: term effectiveness of all the alternatives are circumspect
because the objective on- which they are based is not ambitious enough to ensure
human health and environmental safety in perpetuity. The claims are based on
fulfilling the objective from the work plan to prevent discharge of mine water to the
adjacent alluvial aquifer and Silver Bow Creek and to maintain the t10w of ground
water toward the Pit by keeping the water level below the critical water level I CDM
Federal P"'Jgrams Corporation. 1990). All the alternatives. except one. meet this
limited ot ~ctive. .
The objective should be to establish a truly permanent solution that doesn't
require maintenance into eternity. The work plan should request an Remedial
InvestigationlFeasibility Study that outlines real alternatives that could lead to
permanent solutions. not just a gradient of treatment options and timelines. If the
original worK plan would have outlined a more ambitious work plan that required the
examination of permanent closure options and treatment options then a reasonable
decision could be made in terms of costS. For example. there is no option to drain the
Pit and cement the sides.. This may be wu-easonablyexpensive. but at least it could
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:::(e'l~ .\Letz
.")
pennanent: solutlons to thls problem. but I;llI1 :sure they exist. just not in this
Feasibility Study. . .
Presently. all the alternatives fail to addre~:5 what will happen after :30 years.
\Vho will pay for the treatment: after :30 years to eternity? What is the life
expectancy of the treatment: system In .-\lternative t5i7? I believe any alternative
that can't effectively address these questIons. cant be trusted to be cost-effective in
the future. Long term effectiveness would ideally be not to have to deal with the Pit
after the remediation efforts. This has not even been addressed in any ofthe 19
al ternatives.
Presently. responsible parties exist to pay for remediation. yet even the most
e.xpensive alternative ( 19! does little more than any of the other alternatives to keep
from pushing this problem ontO future generations. _-\ll the proposed 19 alternatives
are stop gap measures. yet this is not how they present themselves in the report. In
fact. .-\lternative 6/7 was picked for its higher long term effectiveness over the
cheaper Alternative 4/5 /Feasibility Study. 1994). The higher long term effectiveness
is that the Pit water level will stabilize at a lower level than Alternative 4/5. By
choosing the more expensive Alternative 6/7 for this reason. the authors and the
State of:\1ontana are placing a high value on having a lower stabilized Pit level.
Why? 'Nnat difference does it make. the work objective only required the level to be
below the critical water level. why waste 14 - 20 million doUars to have a lower Pit
level'?
The State of:\1ontana and the authors both realize. but don't state directlv,
that having a lower pit level will be desirous in future remediation efforts that wili
have to take place when the treatment efforts become too costly or ineffective. In
addition. a lower pit level ',vill gi\'e a larger buffer against a disruption of treatment or
catastrophic eventS that may cause pit filling. The lowest Berkeley Pit water level
possible would be desired by future generations because if treatment becomes too
costly or ineffective then future generations will search for another solution. probably
a more permanent solution that doesn't require constant care. The less water they
are faced with cleaning up the fewer costS they will incur when they attempt to '
implement a non-treatment solution. A1119 alternatives shift the burden of
responsibility tTom the present living generations to future generations. Given this
~~I.u.<1Liu4L. ... i..Lien i oelieve is inappropriate and immoral. the present generation should
implement the Alternatives that keeps the Pit level the lowest. I.e. Alternatives
18/19.
Present generations should pay for the best available treatment option. if a
permanent non-treatment solution is not available. to establish a precedent of paying
the true price of commodities like metal. Then public support would be strong to
prevent mining that doesn't have a permanent remediation solution and a large
enough bond to properly close the site. For example. what remediation effortS. if any.
-------
Steve ~lietz
t5
company to turn off the pump~ and let that pit fill and become a big problem like we
did at the Berkeley Pit? If no permanent solution exists that can eliminate the danger
and cost to future generations. then we should ban this type of mining until adequate
permanent solutions are developed.
SHORT TERM EFFECTIVENESS
The 5hort term effecrivene5s has curiously been defined in terms of th~
damage that would occur from the active remediation effortS. Again, I aII14sUre the
Remedial Investigatiol1JFeasibility Study report followed correCt procedures in
defining th~ short term effectiveness of its alternatives in this way. Short term
effectiveness should refer to alternatives that are effective in near future. Using this
lo~cal definition of short term effectiveness. Alternative 18/19 are the only ones that
take effective actions in the :;hort term to stabilize the Pit water level.
ALTERNATIVE 6 VS ALTERNATIVE 7 - TO DUMP OR NOT TO DUMP
THAT IS THE QUESTION .
Alternative 6 is cheaper than Alternative 7 because it dumps the sludge and
brine wastes from the treatment process into the Pit rather than dewatering and
landfilling the wastes in a RCRA Subtitle D landfill. Sludge disposal into Berkeley Pit
is not a proven technology I Feasibility Study. 1994). Treatability testing done by
Canonie (1993) has found the sludge to be non-tOxic. The authors assume the sludge
is stable enough not to break down when placed in Berkeley Pit's water. However. the
report recommends more research be conducted to determine if the sludge is stable
eno~h to not break down in the Pit's murky depths. Cntil it has been stUdied in more
detail and conclusive results found, the landfill is the only logical option. Ifit is found
that the sludge breaks down and releases metals. which would concentrate the
contamination of the Pitls water, the sludge should be landfilled. .
CURRENT MINING OPERATIONS - MORE PROBLEMS THAN SOLUTIONS
The role of the existing mming operation should be completely clear. They
~hl)1.l!d !lot be ~Jwed to fcUcw ....."lj' pr:lctices that worsen the conciiuon or delay the
clean-up. Currently, the MR Concentrator overflow ditCh is contributing 0.14 million
gallons of water per day to the Berkeley Pit. This is an unnecessary accelerator to pit
filling that must be stopped. Any water used by the existing mining operation should
be treated at their expense at the treatment plant at the concentrator and
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:3 teve .\lietz
7
.\11 clean water sow'ce:: should be diverted away from the ~line Flooding
Operable l~nit. The ~m Concentrator should not bring in any clean water from
I)utside :5ources like Silver Lake. Silver Lake water should be replaced completely
wIth contaminated water from Horseshoe Bend that will be diverted to the taIlings
pond. Other sources of clean water should be diverted around the area to avoid
~ontamination. The cumulative effeCt of removing: the clean water from the sYStem
and stopping the concentrator from dumping in the Pit wllllower the costs of .
treatment in the future.
If mining doesn't cease in :2006. there should be a plan to adjust to this to
maintain the Pit level below the critical water level. Alternative 6/7 uses mining
procedures in its treatment of Horseshoe Bend water till these waters are routed to
primary treatment in the post-mining,stage (Feasibility Study, 1994). Ifmining
continues longer than expeCted. will the reroute of the Horseshoe Bend water to
primary tteatment still take place in 2006 or is it dependent upon mining activities?
If mining does continue and Horseshoe bend isn t diverted to primary treatment as
per the plan. the final stabilized Pit water level could change. This should be
evaluated and described before a plan is picked and initiated so that target water
levels can be set and success measured appropriately.
MONEY - PAYING THE PIPER
The preferred remedy must state exactly how future maintenance and
operation of treatment facilities will be paid for. All responsible parties should be
found now and formal structures of payment should be designed. I recommend that a
bond be set up that will cover the initial capital requirements for construction of
remediation efforts and for maintenance in perpetuity. The amount of the bond
should be equal to the present value. as it is currently calculated for the alternatives.
In addition. a separate bond should be set up to aid in the development and
implementation of new remediation technologies. This will ensure that the
remediation efforts at the Mine FloodiIUl Operable Gnit remain state-of-the-art. A
mechanism should be set up to decide which new treatments should be implemented
and which are not worthy. I recommend setting up the bonds now to hedge off future
uncertainties such as interest rate fluCtUations. changes in the cost of the project.
and responsible parties folding.
The costs in the Feasibility Study are in present value figures. This type of
financial analysis rewards proposals that delay taking action till the latest possible
time. This has the effeCt of pushing the costs upon future generations (Merton,
1990>. The preferred alternative should minimize the costs in the future by having
the responsible parities pay the full bill now. Then actions that reduce futUre costs
would be preferred. because it would lower the amount of money that responsible
-------
Steve ~1ietz
8
CONCLCSION
The present Remedial InvestigatioI1lFeasibility Study contains tWo major
problem areas that both arise from an inappropriate work plan objective. At the
present time. I recommend e~anding the work plan to include a more comprehensive
human health and environmental protection objective and to expand the alternatives
aVailable for review to include 50me that are permanent solutions that do not require
care and funding forever.
I recQmmend that Alternative 18/19 be adopted because of short term
effectiveness' as I define it) and best long term effectiveness of the options presented.
i.e. it will have the lowest ;5tabilized water level. This will leave the least burden upon
future generations and establish the largest margin of safety. If the pit sludge
proves to be stable enough not to re-dissolve intO the water of the pit then Alternative
18 would be preferred on a cost basis.
Two bonds should be established immediately to pay for the cost of the
remedial effortS. The first should cover the initial building costS and predicted
operating and maintenance costS. The second bond should be a special fund for
upgrading the physical plant in the future.
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S teve ~1ietz
9
REFERE:'\TCES
Cll10rue Environmental Semces Corporation. 1994. '. Draft Feasibility Study
Report. Butte .\1ine Flooriinl?: Operable C nit Remedial Investigation /Feasibility
Srudy". prepared for .-\RCO. Anaconda. .\Iontana. January.
Canorue Environmental Services Corporation. 1994;" Draft Remedial Investigation
Report. Butte .\1ine Flooding Operable Cnit Remedial Investigation/Feasibility
Study". prepared for .-\RCO. Anaconda. .\Iontana. .January.
C anorue EnVU'onmental Services Corporation. 1993. "Treatability Sampling and
Bench-Scale Testing RePOrt. Butte.\fine Flooding Operable Unit, Butte, Montana",
prepared for ARCa. Anaconda. .\Iontana. May. .
CDM Federal Program Corporation. 1990. "Final Work Plan for Remedial
investigation/Feasibility Study. Butte .\fine Flooding Operable Unit, Butte Addition to
the Silver Bow Creek! Butte Area ~-PL Site. Butte. Montana", Document Control No.
7760-005-WP.BGCC. prepared for the GS Environmental Protection Agency, April
..,-
_/ .
.\Ierton. Robert C.. 1990. Continuous-Time Finance. Basil BlackweH. Cambridge.
.\L-\. iOOpp.
.\Ioore. Jonnnie. and Samuel Luoma. 1990. "Hazardous Wastes From Large-5cale
.\Ietal Extraction: The Clark Fork Waste Complex. .\IT". Proc. 1990 Clark Fork River
SvmDosium. Mont. Acad. Sci.. Vicki WatSon (ed).
Riggan. W.B.. J. Van Bruggen. J.F. Acquavella. J. Beaubier and T.J. Mason.. 1983.
U.S. Cancer Mortality Rates and Trends. 1950-1979 U'SEPA Publ. #EPA-600/1-83-
0156. in Moore and Luoma. 1990, Proc. 1990 Clark Fork River SvmDosium.
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15
2312 Hillview #1
Missoula. MT 59803
March 25. 1994
. >.. ""_~I""
~OTF':TIt).. .~NcY
. MAR 2 9 1994
MONTANA OFFICE
E.P.A.
301 S. Park
Helena. MT 59626
Dear Mr. Forba.
I appreciate the opportunity to offer my comments on the proposed plan for the Mine
Aooding Ooerable Unit.
1) Since July 1986. Montana Resources has been operating. open pit mining in the East
Continental Pit. In the milling process. they are using water imported from the Silver Lake
Pipeline. After the ore has been milled. the ournow from the MR Concenuator is being
pumped via the McQueen Booster Station up to the Yankee Doodle Tailings Pond. Along the
way, some of the tailing slurry are being released into the Berkeley Pit.
In essence, MR is using clean water from the Silver Lake Pipieline, contaminating it
in the milling process, and releasing it into an established Superfund Site. Oearly, this
sitUation must not continue and it must be addressed in the preferred remedy. Not only does
it conuadict Superfund criteria which calls for a remedy which will reduce the volume of
contaminants, it also contradicts the criteria that calls for short term effectiveness. MR must
be required to treat its own effluent to State Water Quality Standards and release it into Silver
Bow Creek.
This holds true for all aspects of MR's current mining operations. Current mining
practices must not be allowed to delay or compound the clean up process.
One possible alternative with regards to a water supply for cwrent mining operations
is to have MR negotiate for the use of treated Horseshoe Bend Water.
i
.;
2) In t~e preferred alternative, treatment of the Berkeley Pit water will not occur until
present mining operations cease. The year 2005 has been used for calculation purposes in the
RIlFS. This figure is purely arbitrary, yet the RI/FS offers no contigency plans in the event
that mining operations continue beyond the year 2005. Apparently, MR can wait until the
CWL is reached before they even begin to construct a water treatment sYstem. A water
treatment system generally requires at least a two year "shake down" period before it is on-
line and fully functional.
According to the preferred alternative, the CWL may be reached by the year 2022.
MR has estimated that the ore body in the East Continen~ Pit area . will last until 2015-2025.
As both of these figures are estimates, it is clear that an Unnacceptable situation could arise.
-------
3) According to the National Contigency Plan. the purpose of a Baseline Risk
Assessment is "to characterize cWTent and potential threats to human health and the
environment that may be posed by contaminants migrating to ground water or surface water.
releasing to tbe air. leaching through the soil. remaining in the soil. and bioaccumulating in
the food chain." The BRA that was completed by the EPA and DHES addresses the risks
posed by ingesting contaminated surface or groundwater. However. it does not address the
risk to human health from dust blowing off of the barren. exposed walls of the Berkeley Pit.
In fact. the pit walls have been piaced with the Active Mining Operable Unit. This Unit WIll
not be addressed until mining operations have discontinued.
A StUdy by Luoma and Moore (1990) discovered a higher incidence of disease in
Butte than in comparable cities. This was found in both men and women indicating that the
exposure route was envirorunental rather than occupational. It is likely that windblown dust
may be a contributing factor. Stabilizing the Pit walls should be addressed in the Butte
Flooding Operable Unit. not in the Active Mining Operable Unit. This unhealthful situation
must not t>e ignored until active mining ceases.
4) In addition to assessing the risk to human health. the BRA must also assess the risk to
waterfowl. The surveys that were done by Biosystems Analysis Inc. indicated that waterfowl
usage of the Berkeley Pit ranged from 0 to 26 birds per day. According to a repon prepared
by the USFWS. the elements found in the Berkeley Pit water (with the exception of lead)
ranged from one half to four orders of magnitude greater than the recommended safe.
concentration of the elements in the drinking water of livestock and poultry.
Considering the very brief and rudimentary nature of the study conducted by
Biosystems Analysis Inc.. the potential cumulative effects from heavy concentrations of six
different heavy metals. and the lack of information regarding the effect of these toxins to
waterfowl specifically. it is of primary imponance that the preferred alternative incoqx>rates a
plan for effectively preventing access to the Berkeley Pit water by waterfowl. This will
ensure that the preferred alternative complies with the Bird Migratory Act.
5) The preferred alternative calls for pumping and treating the Berkeley Pit water in
perpetuity. How this will be paid for is of obvious concern to the public. With a company
as large as ARCO. it seems likely that the EPA will allow them to cover the costs on an
annual basis.
The preferred remedy must state clearly and completely exactly how these costs will
be covered - including the possibility that ARCO declares bankruptcy at some time in the
future. The preferred alternative must also include the cost of reconstructing or renovating
the water aeaanent system in perpetuity as well as allowing for the cost of installing new
technologies should they become available.
6) Public involvement in the Berkeley Pit clean up is extremely difficult due to the
immense' amount of technical information involved. Few eople have the time or the expenise
to wade through the hundreds and hundreds of pages included in the RI/FS. If the public is
really going to be involved in this process, EPA must make a more concened effon to .
interpret these volumes of information. However, the interpretation should come from an
independent, objective source; someone who has not already alligned him/herself with a
-------
towards panicipation in this decision making process. Although the state was included from
the beginning, the public was brought in at the last possible moment.
Sincerely,
Bonnie GeString
-------
ftcmuLL -)j~
I I " ,.,
I II I .
v' ,
CO:\l"1E:'IiTS
, \
.)
Since Juiy 1986, \IR has ':een cper:ltlng open pIt r:".ining in an area to the east or" the
Berkeley Pit known as the E:J.St C.;~rine:1rJi Pit. Ore frcm :he EJ.St C:mtinental Pit is
transported to the ~tR concemrator for miiling. [n ,he miiling process, MR uses water
imported from the Silver Lak~ Pipeline. ~:
-------
1":1:S :-toids true fer all aspec:s of ~fR's c:.mem mining operations, Current mming
?ractices must not be allowed to deiay or compound the dean up process.
One ?Osslole aitemative with regards to a water suppiy for current mining operations
:S :0 ~ave \tR ::egot:ate w:th E?A. :0 'Jse :r~ated Horseshoe Bend Water in the milling
;>rocess rather :~an water :"rom ::-.e 5:: ver Lake ?:peiine.
2)
In the Dreferred alternative. :reatmem of the Berkelev Pit water will not occur until
. .
.-:-~::~:U ::::'"ling :;~craticns c~;J..:)c. 7::e :;ear :CC:;; :.as ceen used =:r ::lc'..llation PW?oses in the
Rl/FS. T:1is rigure is purely arbitrary, ;iet the Rl/FS offers no contigency plans in the event
that mining operations continue beyond :he year :W05. In fact, according to Jim Scott of the
DHES, ~R can wait until the C\VL is reached before they even begin to construct a water
treatment system (personal communicauons).
Steve Blodgett or B-SB states that a water
:reatment system generally requires at least a two year "shake down" period before it is on-
line and :ully functional (personal comr.1Unication).
According to the preferr~d alte~ative :he CWL may be reached by the year 202:.
~R has estimated that the ore body in the East Contine mal Pit area. will last another 2 to 3
decades.
As both of these figures are estimates, it is dear that an unacceptable sitUation
could arise. EPA must include a cOntigency pian in the prefeITed alternative that addresses
this situation.
3)
According to the National Contigency Plarl, the purpose of a Baseline Risk
Assessment (BRA) is "to characterize current arid potential threats to human health and the
-------
releasing to tbe air. ~eac:ung t:-.rough the soil, :emauung in the soil, and bioaccumuiating in
:he ;'ood chain' iCanonie, 1994).
The BRA that was ccmpleted by the EPA and DHES
:.icdresses :he risks ;:csed :,y iIlgesring c:Jmaminated surface :r ;:oundwater. However.!t
does not address :;.e r:sk ~c iurr.a:1 heaith :Tom dust :iowing cff of the barren, exposed walls
or the 3erke:ey ?:r. ;''1 ;':1". :::e ~tt ',l/alls have been ?Iaced wIth :he Active Mining Operable
l'nit tRuss Forba, ?ersonal corr.rr.unIcatlon). This l'nit ',11111 nOt be addressed umil mining
operations are discominued.
A study~by Luoma and \loore (1990) discovered a higher incidence of disease
inButte than in comparable cities. This was found in both men and women indicating that the
exposure route was environmemal rather than occupational. It is likely that windblown duSt
may be a contributing factor. Stabilizing the Pit wails should be addressed in the Butte
Flooding Operable unit, not in the Active Mining Operable Unit. This unhealthful situation
must not be ignored until active mining ceases.
~)
In addition to assessing the :isk to human health, the BRA must also assess the risk to
wateriowl. At the request of the EPA and the U.S. Fish and Wildlife Service (uSFWS), a
srudy was conducted to assess the use of the Berkeley Pit by waterfowl. These Studies were
conducted by Biosystems Analysis, Inc. for ARCa.
Biosystems Analysis Inc. observed the Berkeley Pit periodically throughoUt the spring,
summer, and fall of 1993. Each survey consiSted of three 4-hour observation periods
conducted over two consecutive days. The surveys indicated tha~aterfOWI usage or the
-------
.'
.-\ccording to a report ;:repared by the USFWS. :he elements round in the Berkeley
P:t water (with the exception of lead) ranged from one haif to four orders of magnitUde
Jreater than the recommended safe .:oncentration of the elements in the drinking water of
~
::veStoci< and ~uitr: Ie: :-1. FPc. :j94) ,:See Table).
C.:msidering the very ~r:ef :u:d :"Jdimentary :1ature of the study conducted by
Biosystems Anaiysis Inc.. the ;:ote:u:ai -::lmuiative effects :Tom heavy concentrations of six
different heavy meta is. :u1d:he laCK :f :''1formation :egarciing the effects of these toxins to
waterfowl specirlcally. it is of primary importance that the pre felTed alternative incorporates a
plan for effectively preventing access to Berkeley Pit water by waterfowl. 11Us will ensure
that the pre felTed alternative complies with the Migratory Bird Act.
5.
Public involvement in the Berkeiey Pit clean up is extremely difficult due to the
immense amount or technical iniormaIlon invoived. Few people have the time or the
expertise to wade through the hundreds and hundreds of pages included in the RIlFS. If the
public is really going to be invoived in this process, EPA must make a more concerted effort
to interpret these volwnes or information. However, the interpretation should. come from an
independent, objective sourc:; someone who has not already alligned themseif with a speciric
alternative. Additionaily, the public should be brought in at a point more conducive towards
participation in this decision making process. Although the state was included from the
-------
15.
~~e preferred aitemauve c;lils for pumplI1g and treatlI1g the Berkeley Pit water in
;-~rpetUity. :-iow this will be ;:ald ~'cr :s or ODVIOUS ccncem :0 the public. Jim SCOtt of
QHES has indicated that the ?RP's muSt either provide a certain amount of money up frOnt :;0
:hat the compound interest from this :noney wIll Continue ro cover the COSt, or prove that they
~ave rhe whe:ewithai :0 :cve: : 00% of the caSt on a year to year basis. With a company as
:arge as ARCa. it is iikeiy that E?A will allow them to cover the COSts on an annual basis
(Jim. Scott, t:ersonal ccmrnuIlic;lt:on). T;;e preferred remedy must state clearly and completely
exactly. how these costs will be covered - including the possibility that ARCa declares
-
bankruptcy at some time in the future. The preferred alternative mUSt also include the cost
vf reconstructing or renovating rhe water treatment system in perpetUity as well as allowing
-------
I 6
APRIL 21, ~994
ENVIRONMCN', AL
~OTECTION AGENCY
::;.:"RY ~URP~Y
30X 44
RAMSAY, ~T
MAY 0 3 1994
~ONT ANA OFFICE
59748
,:.. TTENT I O~ :
Russ Fc::-t:a
EPA CO~~E~TS
DEAR MR. FORBA:
IF THE DETERMINATIO~ OF WHAT IS BEST FOR THE PIT IS TO LET
IT REACH THE STATIC LEVEL OR ANOTHER LEVEL THAT WOULD TAKE
YEARS TO REACH, ~HY ~OT PUMP THE SILVER BOW CREEK INTO IT FOR A
COUPLE OF YEARS? NOT ONLY TO GET CLOSER TO THE PERMANENT SOLUTIO~,
BUT ALSO TO PERFORM RECLAMATION ON SILVER BOW CREEK WHILE IT IS DRY.
I TALKED WITH THE WATER RIGHT HOLDERS ON THE CREEK AND HAVE
SCHEDULED A MEETI~G WITH THE NATURAL RESOURCE DAMAGE PROGRAM,
THE CLARK FORK COALILITION AND THESE WATER RIGHT HOLDERS: MAY
17,1994, at 7:00 P.M.
THIS MEETI~G WILL BE HELD AT THE Butte LOCAL DEVELOPEMENT CENTER.
:F YOU THINK A DRY CREEK BED WOULD AID IN RECLAMATION YOU' ARE
WELCOME TO ATTEND ALSO.
SINCERELY YOURS,
~~ ;:~~~//
.' //
GAR'Y y,:' MURPHY
(406) 782-5131
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I 10
May 2, 1994
Russ Forba
EPA Project Manager
301 S. Park Ave.
Helena. ~t. 59626
Dear Mr. F orba:
I disagree strongly with your preferred alternative for the cleanup of the Berkeley Pit.
There is no r.: . ....vl1 to wait thirty years. The pit should not be allowed to fill with toxic water.
The cleanup should start soon and the water level should remain at or below where it is now.
Other alternatives besides lime treatment should be considered. You should be more con-
cerned about the health and safety and quality of life of citizens of Butte and downstream
instead of so focused on what a proper cleanup will cost. We citizens deserve this and we
don't want a giant body of toxic water upstream from us.
Thank you.
11 ; I '
Y~t~ ./-:/'1'. '. '. '
Steve Schombel
IEN~IfIIONMi:"' ~~
PflOTECTION AGENCY
MAY 0 4 \99.
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1700 APPLEWOOD IN
MISSOULA HI 59801-1284
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ENVIRONMCNT AL
PROTECTION "GENCY
Pia Gregan
310 W. Silver Street
Butte, MT 59701
406-723-9339
MAY 0 3 \994
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Another vie.,
It's time to holler about plan for pit
(Editor', Note - Mary Kay Crail of
Butte is associated with the Clark Fork-
Pend Oreille Coeltion.)
Asa younll5ter, I was delipted when my
brother Tony olrered to let me help him
wash walls and ceilinll5. It looked like fun.
Tony, on the stepladder in the kitchen with
a roaster pan of soapy water, asked me for
a broom. Tony placed the heavy pan of
water alainst the ceilinl and held it in
place with the broom. Then he backed
clown the ladder, keepinl the broom
alainst the pan. lie said I'd be a big help
by holdinl the broom in place until he re-
turned. Well, I was a happy assistant ...
unlit I realized that dear Tony was curled
up in the living room with a funny bookl
The answer to my dilemma wasn't djlri-
cull. I hollered. Mom and dad came run-
ning to save me.
Butte has some dirty water hanging over
It: The Berkeley Pit. And it's time to holi-
er.
EPA wants you to tell them - with a
postmark no later than today - what we
think of their' plan for cleanup of the con-
taminated water in the pit and nooded
mines.
Some say, "What's the use? We're ign-
and." Othen are burned out from years of
ltudies and meetings. Now Is the "oUicial
public comment period." Now's the time
EPA must Iilten. "Community accept-
ance" mUit be c:anaidered in Superfund de-
cilkinl. In 8CIIn8 countries, when you don't
lpeak up, JOU're uylllll you don't Itke the
proposal. Nal here. You can Io8e a lot by
not lettl... EPA know your opinion. And
there'l plenty to say.
The EPA-ARCO "remedy" would:
. Allow doubling of volume of contami-
nation now in the pit, from 25 to 56 billion
..110lIl, before any pit water Is cleaned.
Superfund law reads "reduce" - not "in-
ere&Se. It
.." K.,
Cr.'.
,
cost $60 million about 20 years ago. Cost of
this "eternal cleanup" would be less: $42
to $53 million.
. Use 18605 technology in 2022. ~PA is
open to elrective, new technologies ONLY
IF THEY COST J.~SS.
. Saddle future generations with
worries about the pit level always at the
"full" mark.
The EPA.AItCO 1I18n wouldn't:
. Absolutely assure toxic water isn't
leaving the pit. Instead, it would provide
new wells to catch it aUer the fact. Yet,
Superfund law says we are to bt' protected
from the "threat" or release (If contamina-
tion. If AItCO alld EPA are sure contami.
nated water can't leave the pit, how dil1
Butte miners pump all the water out of the
bedrock aquifer?
. Have any short-term adverse effect!l?
EPA can't think of a one. Can you? ...
Creation of the nation's largest poIsOn lake,
and more?
EPA must proceed from today, not back-
ward from 2022. Butte-Silver Bow hu
asked EPA to find research dollars to help
develop newer, cost eUective technologies.
Added to MSE's funding from the Depart-
ment of Energy, more than two or three
technologies per year could be tested. Set a
deadJine from companies who want a piece
of the. minerals pie here to submit tech-
nolOlies to MSE's Resource Recovery ~
gram. Competition and market fores
could bring the best solutions forward.
Within, say, two years. one or more .....
nolo8les cou1d '0 into pilot null a~ .
pumph. and u.tment plant could be ..
IIgned and COD8tnJcted. By the end 01 .
total of leVen or eipt years, cleaned Pit
water cou1d run down Silver Bow Creek, 01'
be avallable to atlract new industry to.
Butte.
It'l time to hoJler. Write (with today'.
postmark) to Mr. Russ Forbs, U.S. EPA~
3tlt S. Park, Helena 5962:8. .
,
Let's look
for better
solutions
. Tie up that amount of water in the pit
forever - without it being used for any
good purpose. Legal?
. Allow AItCO to self-insure its financial
ability to maintain a pumping and treat-
ment plant in perpetuity, rather than put-
ting the money in a trust fund upfront.
"Perpetual care" for some local ceme-
teries didn't work; yet, we're to trust
'ARCO.
. Set a precedent by "writing off' the
bedrock aquifer. Other towns In similar
ctrcumstances get their aquifer water'
pumped and cleaned. Perhaps Jack Nick-
laus couldn't delign an 18 "mineshaft" Iolf
course as ARCO's present to Butte for
leavlllll 100 percent of contamination in
place. tSo where's our pretty present In
lieu of cleanup?)
. Save ARCO a bundle. Butte miners
-------
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I 12
IHYIAO~'''c'',~, .
PROTECT" .~. ".
\1r Ru~~ Farha. PrOject \1anager
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3(J15 Park
:-ielena, .\fr Sg62A
NAY (I J IY~
~ONT ANA OFFICE
~t' ;:mhllC f'rm'!1e""~ ~erl'el'e\' !:ilt an" Hlne F"nndlnO Plan
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'.:omlder ~~e short ter~ effects, Why aren t you lOOKing at that I
! W A\T THE BERKELEY PIT CLEA:':ED rp \OWI 5tart ~'C)rl~ nC)~' Reduce,
rhe water leve1. Let s have clean water OUl 01 our C)~;n aquller ~;!thIn the
~~~~ ~:X ~':; :!:gh! years .~.!1\.th:~g le~~ l~ ~nac:eptabje
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~£OOBCI£ )I. 8ABJNCI
518 WEST GRANITE ST.
BUTTE. MONTANA .,8701
I 13
April 29, 1994
ENVIRONMENTAL
~OTECTION AGENCY
~r. Russ Forba
US EPA
301 South Park St.
::elena. :~T 5962':
MAY 0 3 1994
MONTANA OFFICE
Dear ~r. :orba:
I have reviewed the EPA-ARCa proposal to deal with
Berkeley Pit here. I find several things quite disturbing:
the
1. The propsal actually makes the toxic site worse by allowing the
volume of acidic ~ater in the Pit to double. How can EPA justify a
remedy ~ that actually worsens this community's environmental
situation. That tOX1C water needs to be reduced, not increased!
2. The proposal denies Butte
forever! At a time when this
problems, a remedy that does
quickly so that it can be made
incomprehensible!
the use of the water in the Pit
communi ty is facing severe water
not treat the Berekely Pit water
available for usage in Butte
3. The proposal appears to be written more in the interests of ARCa
than in the interests of the citizens. It even allows ARCO to
escape the necessity of having to create a trust fund now so that
we are assured that ,we are not left holding the bag. I simply
cannot trust ARC a to treat that water in perpetuity. EPA must think
that the people in Butte have no memory of all the corporate flight
that took place during the past 15 years.
4. How can this proposal ignore such a crucial item as the cleaning
up of the bedrock aquifer? This would seem a' self-evident
requirement of any remedy EPA would agree to.
5. The proposal to dump lime into the Pit and leave the accumulated
sludge there forever ignores the technologies now available for
treating'the water. Folks who maintain that ARC a has been given the
"cheapest" alternative make a good case here. EPA should be helping
~~mmuni~ies find the latest technologies to deal with their
environmental disasters, not just the ones that are cheapest for
the responsible parties.
6. Everday you can see dust blowing south from the area surrounding
the pit on to the Flat. Your proposal must require that the sides
of that giant dump be planted--shrubs, trees, grasses. We in Butte
wish to live in a beautiful community, not simply survive amongst
the rubble of the polluters.
Yours sincerely,
, J~J~ 7l 0 ~ '''''1.
-------
GEOHGE H. WAIUNG
518 WEST GRANI1 E ST
BUTTE. MONTANA 59701
USA
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-------
114
A~:>ril 29. ~994
ENVIRONMENTAL.
~OTECTION AGENCY
MAY 0 3 1994
~~. ?USS :~=~a, ~.S.~?A
~ONTANA OFFICE
301 S. ?ar.'<
Helena, ~T 59626
Qear Mr. Fo=ba,
I want ~~e ~?A t~ CO sOmethln; about the Be=keley Pit ~ \~e
need to begi.n ::Jr.::Jce5sing til= ?it water~. rhere are too many
unknowns ~~ wait until 2~22.
The EPA needs to allow co~~etition and market forces to compete
for workable solutions.
The EPA mus~ look at ~ew technologies, regardless of their cost.
There are so many unknown hidden variable costs connected with
allowing the ~it water to continue to rise that the only way to
really save money is to do something constructive ~.
Please! Please! Take action now to find a solution to' the rising
contaminated ~ater in the Berkeley Pit.
Sincerely,
"
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Marian C. Conklin
4400 Western Blvd.
Butte, MT 59701
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I 18
April 28, 1994
EH"'RUNNItN I AI-
~ROTECT10H AGENCY
M~Y 0 3 \994
MONTANA OFFICE
Kevin and cindy McGreevy
2709 Bayard
Butte, MT 59701
Mr. Rus_s Forba
U.5. EPA
301 5. Park
Helena, MT 59626
Dear Mr. Forba:
We protest ana object to the proposed plan for the Berkley
Pit. We feel that the plan is inadequate and that immediate
action should be taken to resolve this serious problem. We
are ~larmed that procrastination is considered a viable op-
tion in addressing this problem. It is our. understanding
that the EPA was formed to PROTECT the the environment as
well as the inhabitants thereof. Procrastination is NOT
protection.
ARCO entered into the minerals business with the same short-
term, immediate profit motives that applied to their oil/gas
operations. They picked up. the Anaconda properties for a
song, with no long term commitments to that operation in
mind. Well, mining is a long term investment, and unfortu-
nately, the effects of mineral extraction are even longer-
as ARCO is now finding out.
When the Butte operations were terminated, the bottom line
dictated that it was no longer profitable to perform mineral
extraction. 50 let it sit in the ground until the economic
climate changes. Their attitude was one of: It isn't going
anywhere. 50 shut it down. We'll take it later. But, ARCO,
in purchasinq the the Anaconda properties, became the
steward of those properties. Now those properties are harm-
inq my town, my valley, and my state.
You and your aqency are mandated by your charter to PROTECT
-------
We require ARCO to act 'immediately in preparing a site
for total cleanup of the Berkley Pit toxic waters. This
will include actions to prevent future contaminations
their properties.
plan
plan
from
Aside from ARCO touting age-old precipitation methods as the
cleanup instrument, new technologies which yield far better
results such as kelation chromatography are currently em-
ployed to perform this type of cleanup. This method could
be used IMMEDIATELY, not twenty Qr thirty years down the
road.
The Berkley pit and its surrounds pose many environmental,
economic and social problems for the community of Butte.
. But, mi~ing is our heritage and our future. We need to learn
from our past mistakes and misuse, not perpetuate the indif-
ference and short-sighted attitudes which led us up to this
point. The mining barons that bore into this hill, erected
the the smelters, and ultimately poisoned the valley over
over the last century did so in the name of greed and
progress. Greed lined the pockets of the barons, the bosses,
the miners and the pOliticians and progress made us blind to
anything unsavory around us. They knew that there would be
hell to pay. Someday. But, someone else would pay 'it, not
they.
Well, we as a society grew up- a little. We became a little
less indifferent, we learned from the past- a little. Your
agency was created and YOU have a jOb to do: LEVY WHATEVER
FORCE IS NECESSARY TO INSURE THAT THIS ENVIRONMENTAL PROBLEM
IS ELIMINATED. Yes, they will kick and scream and cry, "It's
NOT our fault!" But that was the bed they made when they
purchased the Anaconda operations.
This is our home, protect it.
~:;r~~ /
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2709 Bay'ard
Rulle MT 59701
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I 19
Clifford and Rita Bradley
1923 Argyle Street, Butte, Montana 59701
.-\pril 28, 1994
ENVIRONMENT -'1.
Pt:IOTECTION AGENCY.
Russ Forb a
l".S. EPA
301 S. Park
Helena, ~IT 59626
NAY 0 3 199~
'AONTANA OFFICe
Dear \lr~ Forba:
We are writing in opposition to the current EPA-ARCO remedy plan for the Berkeley Pit
for the following reasons. \Ve are concerned regarding the danger to public health due to
(he risk of contaminants getting into the aquifer. We do not feel our children should
inherit our problems--such a legacy as the problem of the Pit is too drastic to pass on to
a future generation(s!. we want to be sure there is room for new and more innovative
technologies in the plan. These technologies could turn out to be cost-effective. However,
irregardless of these costs, the long-term costs in terms of danger to human health and the
environment cannot easily be put into dollar terms.
We urge you to re-consider the current plan to address the Berkeley Pit. Thank you for
your consideration of this important matter.
Sincerely,
!~JJIL .; /.2 (L
(;Jrc ~ / Y'Ut<, /'
Clifford Bradley
" f..r~ ,3"n:IJ...c,'~'.
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-------
Bradley
192:1 Argyle Sl.
nuttc, MT 59701
H IJS5 ForlJa
U.S. EPA
30 I S. Park
Helena, MT 59626
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IRONMENT AL
EMil ~ION AGENCY
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MAY 0 3 \994
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T'J :~e Environmental
=rotect ion Agency,
Nri ~e your tul I ~ame:o r~mi~d I~~ ot :. lour '~sponsibi i i fy.
v~ur are not the big ousiness protec:ion agency (SBPA) nor the
-'Jxic Dump Montitori"g Agency (7:JMA) nor :ne ~et's protect tt1e
.~:~re of mini~g agency (_?~MA).
Environmental ;:;"Jtec:ion Agency. 7he !aw is c:ear: reduce and
::;-:::eCL r'':'J are coi~g r:either with :ne proposed solution to t:le
::; roo I em s 0 f : n e 3 e r 1(. e ! e y ? it: n 9 u t t e. ~., 0 n tan a .
W"'y ~ot star: r-aw :J c;ean uo :~e p;~" 'o(-:u are not protecting"'y
'.'lei i mor the safety of our drinKing water suoply by allowing the
water in the pit to near a cruciai level that could (no one
. ",.c.nows for. sure t"at :t wi:1 or it won't) cross into the alluvium
a cui t e r. -F rom my k i : c n ens ink I can I 0 0 K 0 u t the win d a wan d see
BerKeley Pi t. :OOK from there to t~e water and wonder how wi I I
I ~now wnen and it tne water wi I I become unsafe to drink. Why
must I live wi:- :~e threat of the water leaving the Pit and
entering the al.uvium acuifer? You are the Federal Agency that
is mandated by law to pratect me and my tami Iy from such a
. threat. I only ask that you do what you are charged by law to
do.
WhO out the stipulation on the cost of clean-up and treatment?
Why does ARCa have the rignt to say that tne method of treatment
must be cheaper. or equal to the I ime treatment? I f I break
someone's winaow, I must fix it. I cannot say that I wi II use
plastic because tnat is the cheapest 'Nay to fix it now. The
owner has a right to nave it returned to tr,e way it was not just
fixeo in the cheapest way possible. As custodians of this planet
we are responsible for this water, ; t :an :e cleaned, we must do
it right.
I urge you, on behal f of my chi Idren, not to let this act of
violence take place in our communi ty. Do not let us I ive wi th tne
threat of the increasing volume of toxic water entering our water
supety. Do not allow ARCa to treat the water with lime. Dri II
more wells to monitor the flow of toxic water. Do not wait until
2022 to act on this problem.
T~YOU,.IG- L"'
~~(~~-
ENVIAONMiHT "L.
PROTECTION AGENCY
MAY 0 3 '9~4
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EM'I'~O~ AGENCY
~O'T£C'T''''''''''
M~'f Q 3 \994
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It's time to holler about plan for pit
(Editor's Note - Mary Kay Craig of
BuUt' is associated with the Clark Fork-
Pend Oreille Coaltion.)
AI . ,...ter, I was delighted when my
brother Tony offered to k-t me help him
wasb walls and ceilings. II looked like fun.
Tony, on the stepladder in the kitchen with
a roaster pan of soapy water, asked me for
a broom. Tony placed the heavy pan of
"ater against the ceiling and held it in
place with the broom. Then he backed
down the ladder, k.-epirlll the broom
agalnet the pan. lie said I'd be a big help
by holding the broom in place until he re-
turnl'd. Well, I was a happy assistant ...
until I rt'~li7.ed that dear Tony was curled
lip in lhe livin~ room with a funny bookl
The al1.'Iwt'r to my dilemma wasn't dlm-
Cllit. I hollpred. Mom and dad came run-
ninR to sav!' me.
Hutte has som(' dirty water hanging OVl'r
It: The Bl'rkl'ley Pit. And it's time to holi-
er.
EI'A w:tnls you 10 tI'll them -- wilh a
JXl!'tmark no later than today - what we
think of tllI~ir plan for cI!'anllp of Ihe con-
taminalrd water in Ihl' pit and flooded
mines.
Some say. "Whll!'s thl' use? We're ign-
ored." IIthers arl' burned out from years of
studies anrt m.-elings. Now is the "official
public comment period." Now's tht' time
EPA must listen. "Community acccpt-
ance" must be considered in Superfund de-
ci.'Iiol1.'I. In some cOllntril'S, when you don't
speak ull. YOII're saying you don't like the
prOJlOSal. Not Iwre. You can lose a lot by
not IpUing EPA know your opinion. And
there's plenty to say.
The EPA-ARCO "remedy"would:
. Allow doubling of volume of contami-
nation now in lhe pil, from 25 10 56 billion
gallons, beforl' any pit water Is cleaned.
Supt'rfund law reads "reduce" - not "in-
creasp. "
..r, KI"
. Crl',
,
let's look
for better
solutions
,
cost $60 million about 20 years ago. Cost aI
this "eternal cleanup" would be less: S42
to S53 million.
. Use 1860S technology in 1022. EPA Is
open to effective, new teclmologies ONLY
II-' TilEY COST LESS. .
. Saddle fulure generations with
worries about the pit level always at the
"full" mark.
Thl' EPA-ARCO plan wouldn't:
. Ahsolutely assure toxic water Isn't
Il'avinR the pit. Inslead, it would provide
new wells to catch it after the fact. Yet,
Superfund law says we are to be protected
from Ihe "threat" of release of contamina-
tion. If ARCO and EPA are sure contami-
nated water can't leave the pit, how did
Butte miners pump all the water out of the
brdrock aquift'r?
. /lave any short-term adverse errecls?
EPA can't think of a one. Can you? ...
Creation of the nation's largest poison lake,
alld more? -- --- -- . -
--EPA musl proceed from today, n~i back-
ward from 2022. BuUe-Silver Bow has
asked EPA to find research dollars to help
develop newer, cost effective technologies.
Added to MSE's funding from thp Depart-
ment of Energy, more than two or lhr.-e
technolORies per year could be tested. Set a
deadline from companies who want a piece
of the mInerals pie here to submit tech-
nologies to MSE's Resource Recovery Pr~
gram. Competition and market forces
could bring the best solutions forward.
Within, say, two years, one or more tech-
nolOlies could go into pilot runs and.
pumping and treatment plant could be de-
,iKned and constructed. By the end of .
total of seven or eight years, cleaned Ptt
water could run down Silver Bow Creek, or
be available to aUract new industry to
HIIUe.
It's time to holler. Write (with today',
postmarkl to Mr. Russ Forba, U.S. EPA,
301 S. Park, Helena 59626.
. Tie up Ihat amount of water in the pit
foreVt'r - without it being used for any
gooct lurpose. l.egal?
. Allow ARCO to self-insure its financial
ability to maintain a pumping and treat-
ment plant in perpetuity, rather than put-
ting the money in a trust fund upfront.
"Perp!tual care" for some local ceme-
teries didn't work; yet, we're to trust
ARCO.
. Sel a precedent by "wriling off' the
bedrock aquifer. Other towns in similar
circumstances get their aquifer watt'r
pumped and cleaned. Perhaps Jack Nlck-
Jaua couldn't design a" 18 "mineshan" golf
course as ARCO's present to Dutte for
leaving 100 percent or contamination in
place. (So where's our pretty present in
lieu of cleanup?)
. Save ARCO a bundle. Butte miners
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CATHERINE COUTURE
3005 Nf TT IE
BUTTE, MT 59701
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TQ:.Mr..BIIt.r.I~PrtlldtriL, ,J :!\J;1r:,B~Y""owjJl,\MReD.~~ " , Irmttm it ':jf ' I, ,: '
'JAr. AI'aor.; ViCe President' ' . < Gov. f.1wc Radc:ot ,', -,' (, 1\7 It,bjly.'''J:n:.;~ ,y~,\ ~~ II .,J., '
:6.n,Max~uc:us" I ",,;,:.: ',!~i,.., Mr,~WWd8':EPk:MT"Dlr,!1 (:'l ;', .~ana~lSpart'1~' ':.;~,
,Sen, CorY8d ~urns~":,I/, !,~: 11./:i:';,~..'~, Mr, Bob~~. blr, MT ,QHES,'~ . 'lI'Superfunil tkiisii1n- /' ~,",' ,
, Rep, Pat WlIHams ;, :'HI . <..... ,""'I, ,.:," ',: 'f11r~~~ 'F~. ~PA ProJeft~ :,', .," . .. ,: ~' ~"?I.
; Ms. Carol BrCMfltr. EPA,LAdminii~alDr ,Ie, J" '" . ,,. ',., ' .., ".., , t I~I\!I ~I, " :, '.
~rc:~~=~~Ffj~:i~~~r~~~~~ . y~\~~;t;~~ I. /:,
L'-YELIN TH~ BE~KElEY PIT AND ~l~N IT VP, ~OW, ," ""',~"I 1:J11!1: ~IUI'~" " ,
)fNE DON'TY(ANT, a.vrre TO HAVE 'M:fAT OOULD PROBABLY BE H RGEST BODY OF TOXIC ",.:1,'
~TER I~ THE.,WORLD.. EPA'S PLAN 10 lElTHEPIIFILL FOR THEN 38:v.eA1It6 rI,JitA~~URI:h' " ,', "
S~IALANDECONOMICFUTURE.AFULLPIT'POSESAPERPETUAl'T EA'tO~'~ S Pt;~f~J,~~~.. /":
Ci.. NTAMI~~P,~,!T ~~ES OUR~~~~~~~~~~,~~R ~~S,~ ~~;,~ " ,,~:~~~~:j,;,~ ~ . ..
,', RESPECTFVj.lY,~) - ~. ...J.. ,!",i/uli:: ,j !
" 901' 1101 .p~.:.t .11 'NAMEd bl ~. . ~ "~1-W'r.Q!..-,~:" ..u. ,,;,Il1, ,4!sJ
Ii '110"6U1 lotni ,...., ~t'I:' ." ' , , ,1>'11', '
(0. , ;". ot . h . 'dC" ' , "(f ", 'il ',." v"":)"- II "j'
I " (-II"""" "..",ADDRI:S~ u v ,.., ~ 'Jr. )., 'II ,:o.} ..1... ",
. ..) f ...I~. \; f.. ~..,' , " to. ,,; <, '. ': ." , ...00:-.5'9;-1' '".. ';"C" \I", fT~
~, 'CITYISTATEIZIP HON ' ~ rJ' ,6'0, ',;1,',!t.
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Another vie1M
It's time to holler about plan f water 1IgaiDSt'ot!Ie uiIIDg-1uld heJd'lt in :.,. '.-,-' 8 Absolutely -aauretoxic water isn't
place ~. the broom. Then be baclted ' , leaving the pit. 'lDSteacl, it would provide
': down',' ,'~dder, keeping the broom Dew wells to ,c::8~..tt after the fact: Yet.
To against, paD. He said I'd be a big belp . Superfuud law ~, we are to be protected
~ by holclint'thebroom in ,.place unW he re- . , 0 from the ..threat" of release of CODtamiDa.
turned, Well, I, was a1:lappy assistabt ..: tiOD. U ARC08Dd EPA are sure eoDtaJni.
unW I realized that dear ,Tony was curled:, ,. L ' I k Dated water taiI'tleave the pit, bow'did
' up in the living room wttha fwmy book!. "~" ,- ,ets"OO '."', Butte~JII~11I1)8U;lbe water outGf.tbe
L The answer to my dilemma wasn't dim. ',;:- " 'f' b.' 'tt'" " bedrock 8cpiJf8t~.'~, .. . . ,.~~,
r c~t. 1 hollered, Mom a~ 'dad came fUD.'" .' ", or e er "': :'" ,,::,:. '.,Ha~~~ adverse e!fed8!
. nmg to ave me, '.' '.. ':," '.. , . ~'I. ' , EP A eait~'!!tbJDi: 'cif . ODe. Can yC!U!'...
Butte has some dirty water hanging over ',SO utJOns,...,' Qoeatioail ~1Iiatiaa~ laqest ~n1aU.' .
':. ~. ~:Berkeley Pit. And it's time to holl. ~"', ,',~, .... , :.' . .. '. 8Dd~a::1l'~~ '~y:"~t ~ I
EP ~ wants you to tell them - with a :, ' " , " .ward tram, 2OZ2. Butfe.Silver Bow ~.... .
': postmut no 'later tbau today - what we 8 Tie\up that amount of water in the pit asked EPA to fiDd resean:h dollars to '
'. think of their plan for cleanup of the COD', forever - without it being used for auy develop oewer, alSt effective teeImologi ',': .
tamiDat.ed water ,,-iD-.:tbe"1rit aDd :Oooded..:'loodpurpose. Legal? - . Added to MSE'. fuDdiaI from the Depart- ':
' mines.: ' ~' ,;,,', .'.' . 'A1low.se1f~' its fmancial ment of Energy, more tbaa two or three "":
\ Somesay,"WJiat's ,the use? We're igD- a' bility to a p p and treat- tec:Imo1ogies per year could be tested. Set a '
1.. ored.'~Others are.burDed outlrom years of 'I~:mellt',plaat tui r :thaD put.', 'dead1iDefromeompaaiea wbo waut a piece
studieaaud meetings. Now is the "official tiDg.the mad upfront. of the minerals pie here to submit tec:h-
t public. eommeut period." Now's. the time.,~'PerpetUal .. r some loc:aJ ceme-" oologies to JrfSE', Resaurce Recovery Pro.:
to EPA -,:must..listeD. "CommUDity ac:eept...'tei1es t4irtn't work; yet, we'::.tO trust, ',gram. ~~petitioa ,aDd market farces
~', ance" muit be ~......idezoed in Superfund ~'ARCO.. ~, ' ',',' , "cauld 'bring '1J!e' best' 801utioas fanrani.:
t cisioai. ~ :Soqie',CoumI'Ies, 'WbeD ;au 4aD~~::1~ '. Set . p~ by "WritiDg ofr the ".Withill, say, two years, aae ell' more ...
i speak up, ;od're~yiai 300. ..'~.~, tbe : ~ aquifer. Other towns in limilar lIologies "could, io into pilot nIDI aad a
. proposal. .l'jot~. YouC8!.-. ~'~ :~..~taneea get their aquifer. water I pumping'ad treatment plaat could be d&-
~' DOt 1~i£PA..~ ~:qD1oa:,~~;,'pamped au~ cl~. P~1!8 Jaclt,!'llclt- 'lliped aDd ~ By the eDd of,.
I there s,p1eatytnaY:.t. .j,".,,~f'~ :-:~.', ~ ',: :' ,alii eouIdD t desllD aD 18 mmeshaft golf ,total of seven ell' eight years, c1eaaed Pit
' ' The EPA.~CO ':remedy'~~d:";~' "., ';~t:aune as A1WO's present to Butte for . -:wa'ter could fUll down Silver Bow Qoeet, ell'
t ~ A11GW~~,4!f,~~~~j;.""'~ 100 ~t of contamination in "be av~ ',~' attract DeW iDdustIy.to
' Datioa 1!ow'in ttiejn('from 1s",~'56 biIIioD ,)alace. (~ where s OW' pretty present in" Butte. ,'..' ,
I .ga!loas, befare 'ey' ]lit' waUi:ts c1eaaed. JIea at cleaDuJST) , ,,It'l ~e to boiler: Write (with todaj'1
;, Superfund.\a~ mdl"nduce'~;S.~ .~:iD-,'~, -::,: . :&ave ~ a buDdle. Butte miners ~'})CI8tmart) 'to Mr. R&8I Forba, U.S. ~A.
crease." :", ;!~,-:~~ii$k- "i, ::"l/,,:fc:~;:"'~:~" '~liiy" staiDliii lteel pumP,J at the Kelley' 3\»1 S. P.n,1IeIeDa ....~, ....;
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130
::)31 iJtah Avenue
Butte, Montana, 59701
April 29, 1994
~US8 rorba
~ . S. EPA
301 S. Park St.
Helena, Montana
59626
Dear Hr. Forba
The Berkel.y Pit vould not ~av. b..n a probl.m if ARCa had not turned
off the pump8 in the m1ne. without even giving anyone a chanc. to do
.~ything .1... Th. ~Comp.nyW had a deal with the Miner'. Union that they
vould nev.r. turn off the pumps, but they did anyway.
I agree vith the .peak.r at the oral comment me.ting who said that v.
and our children ar. the victim. in this. ARCQ turn.d off the pump. vith
malic. and forethought. You, EPA, are the judge and jury. Nobody in this
town want. to ... the pit fill with 56 billion gallon. of poi. on. W. want
the poison in there reduced, and reduced is what v. und.r.tand EPA i. told
to do by the Superfund law.
.
Pl...e do not b. intimidated by ARCQ'. threats of laY8uits again.t the
EPA -- citis.n. could threat.n a cla.. action laY8uit, too. People do get
intimidat.d. Many people in Butt. ar. not willing to speak up on this is.u.
becau.. of the .conomlC ~ter'sts in this town -- m.aniDg D'nDi.
Washington'. Kontana Re.ourc.s. The County Commissioner. v.r. given a tour
hi. ongoing miD. in Butte and vere told it would not b. good for th.m to ask
for a b.tter clean up than the one you and th.y agr..d to vith AROO. Th.
Commi..ion.r. v.re ShOWD all the numb.rs on tax.. and vag.. paid and hoy
those dollars might move throu~h the retail stor.. in Butte. Th. vord vas
spread. around. town that MaI might go bankrupt or stop miDing in Butte. MRI
va. a.k.d to put their situation forvard publicly'but did not. It is your
part to listen to the ~i.he. of the majority of the p.ople in town.
P.rhaps on i..u.. that have p.rp.tual implications, you should give
greater v.ight to opinion. of parent. than you do to intimidated, short-t.rm
.l.ct.d official., becau.e vh.n it come. to human health and the
.nvironment, moth.r. and fath.rs knov what. best for th.ir kid. and for
future geAr.tiOD..
Pl.... g.t d..igning a pumping plant for the pit noy and take actions
to g.t n.y t.cbDologi.. that don't product .0 much .ludg.. Pl.... g.t th.m
into op.ration vithin the n.xt f.w y.ar..
SiDc.rely,
. ~~- ,.J- £r
Sue G....Dberg
ENTAL
E""'RO~M AGENCY
~OTECTIOH
tUY 03'994
~ONT ~NA OFF'CE
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- 131
,~~.-77~{"A"- /:kOJ ec.. I ,4(f'L
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~up~r. una ,....rogram
;E?4
'l
o EPA I
Region VIII
Montana Office
-
A"J..." I1E: Silver Bow Creek/Butte Area Site
'.~' Butte and Walkerville, Montana
. ,.
EN\lIRON""~N' '..
PROTECTION .GE~Y
COMMENT SHEET
MONTANA OFFICE
Please write any comments that you ~ay have concerning the
work pl.:anned on thi.s sheet:. .
, ~g a If -.
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~ " -~~s V~IT~~::.':~ ,=;: ~se~ v~ no~',
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133
ENl/iRONMt:NT .~
~ROTECTION AGENCY
~:'~e:::le~:: P. :~::::':.-';::~.::j
:2 J2 0 .;"'71:e::-S c
APR 1 1 1994
.3 ~: = e , :~!~::: a::a
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.':i.wss:
~h~s ~ec:e::- ~s :c ~~=:~ you :~ac :~e C~~~~~gham Family of Butte
oppose your ~.?A. a~d Ar~o p~ans :0 ~et :~e Berkley Pit water rise
to ~r.accep:able ~e:;~ts.
Arec a~d :~e ~i~ :~=~s:~/ i~ chis ~;:-eat cc~~cr/ of ours completely
desc::-cyed :~e Cc~~e::- :~duscry :n :~e U.S.A. In my opinion this was
done ==::- ~ax _=e~.:. == ;-..:::-p:::ses .:y :::e Ci~ :~dustry .::'hey :..;ould
::-a:her dest::-:::y a ~to~e :~duscry to gain ~ax Relief from their huge
ci1 profits. My c~~~~e~ is that, if the Oil Indust~ paid their
fair share of taxes :tis c~ean-up c:::uld have been taken care of.
Areo eame into But:e ~ich a promise to stay for three years and do
l71i::cr ::r;pr=T.lemerlcs. :-.~ey did th~s and also sold equipment and
p::-c~ercy '.'~:=.': :::ey ::-:ade huge ~::-cfits f::;:n. It was Arco's own
declsion co floed :.:e Butte .::i~~ and again gain Tax Relief
Benefits. : am su:e they figu:ed :hey c:::~~d buy their way out of
their clean-up respo~sibili:ies.
It is my opinion chis is being done ty
other gove::-,-~ent agencies.
c~~:~=~ling ~he E.P.A.
and
I have been a lifelong resident of .3uc::, Xontana and
tr~st .~.aconda Company, Areo Oil =e~pany, :::- the ~.?A.
my taxes are being used to finance. .
I do ~ot
- . . .
=or ~~..~.lC.t:
I have no faith i:1 you Russ, :::e ~. ?..:".
representative in ~on:ana - Sandy Stash.
or Arco' s . :.,'oman' s
I do not know where you were born and raised and educated, but I
know it was not in Montana. I can tell by your beliefs.
Russ I had a well drilled on my property so that I can have good
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_e ::-~..;...' -..uses an lIe:-/: hr ~
~---e for -~ y pro:;' . ee
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134
~
*
ft :
o EPA I
Region VIII :
Montana Office!
Superfund Program
Silver Bow Creek/Butte Area Site
Butte and Walkerville, Montana.
e~V1RONMENT"L i
PlltOTECTIOI>4 AGE!WCv I
I
COHKD'l' SOft
'-fONTANA OFFICF
Ple3se write a~y co:ments that you =ay have concerninq the
work planned on this sheet.
t7&.... ~ fi'.~ l' d;..u,. I:r ~/...a' &. k..d
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3::.\ ~. P~;k.. ,MAY 0 2 1994
H Ll ~"', / ~ \ r 5'::; 7.;; ~ONT ANA OFFIC~
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('1.1.-" u ",~ tit.. J"~" t" {, piP \ fw "-",,-,,( 6.diz \
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136
e"'YIRO"'IIII~T AI.
pqOTeCTI~ AGENCY
APR 2 8 '99~
. "ONT ANA OFFICF
April 26. 1994
To: Russ Forha. EP.\ R~medial Proj~ct :<.r:mager
From: Barbara 1. Archer. rhomas ~f. Tully. 302 W. Galena. Butte. :<..rT 5970 I
RE: CI~:m-up of the B~rk~l~y Pit
The primary .:on~~m regarding th~ r~m~diation of the Berkdey Pit is not who pays
and how much. but is rather the health of our citizenry and of the watershed, which
are ine::tricably intenwined
The EP.-\ must begin the process ofphysi~ally addressing the problem of27 billion
gaJ)ons of toxic water now, rather than putting it off for 20 or 30 years on the
premise that experts have assured them and us that the pit water is not a problem
and won't be until a certain critical water level is reached. That critical level has
somehow bec:n ~stablish~d through modeling and interpolation of data and if
incofTect,. may have dire and permanent consequences on the ground water system
of the entire valley.
Some experts have also assured us that the Yank~ Doodle Tailings Dam. holding
back up to 600 feet of wet tailings, would be sound in the event of an earthquake of
around 6.0 on the Richter scale. It is my understanding that this dam was never
d~igned or engineered to contain the volume now behind it; furthermore, it is my
understanding that while the top of the dam is designed to ~ontain the tailings, that
it is buih on an inadequate base that is not toed into stable materials. Given that
the Continental fault runs very near the dam. and given that Butte is squarely in
the Intermountain seismic zone. it would seem that the prudent course of 3I."tion
would be to reduce the potential for disaster as quickly and thoroughly as possible.
50 as to assure you that I am not merely crying wolf about the possibility of a
seismic event which could have severe ramitications on the Bmeley Pit. I quote
trom the Roadside Geolon of Montana by David Alt and Donald W. Hyndinan
regarding the Continental fauh where it runs through Butte. on page 174:
On fIrSt thought. it might seem that the Continental fault is simply slipping. a type
of movement that should cause little trouble except corltlllued subsldence of Butte. .
But there are no signs of surface slippage where the highway and other roads cross the
fault Therefore. it seems more likely that the fault is stucic. and the earth's crust
is gradually bending, accumulating strain energy like a slowly drawn bow. If that is the
case, then the fault WIll eventually slip suddcnJy, and release the accumularcd energy III
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-2-
T 00 many urnes "~xpens" have been proved '-"Tong. We are dealing with complex
hydrologic and g~ologic ~1ructures along wIth countless other variables.. What are
0ur assurances that the EP.-\'s pret~rred plan tor remediation will be adequate when
~ven the expertS are in disagreement about the dangers?
It is always easy to use 20-20 hindsight to determine how to rectify miscalculations
:lJ1d o::tToneous hypothesc:s. But 20-20 toresight is bc:st achieved by eniJ g on the
side offaution. Caution In this case means beginning today to fonnulate a plan of
:ll."tion based on the best a vailabk technology~ that being the technology that works
b~.
A. suggestion: .
(1) begin mediately .1lId take 2 or 3 yem to solicit technical solutions to cleaning
up the water.
(2) ~ithin 3 years. using market forces. have someone ~1SE?) screen the proposals
and choose 2 or 3 10 put into a pilot program.
(3) test for three years .
(4) fifth or sixth year. begin pumping plant with the 'bcst available technology and
worlc out bugs in the sy~tem.
(5) seventh or eighth year. project established
To begin doing what needs to be done by the end of the century is a realistic goal.
rfwe have the technology and resources to send people to the moon, ifwe can
commit $.500 billion to bailing out the S & L's. surely we can come up with a
workable solution for remediation of the water in the Berkeley pit this century.
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ENV:RONM~I'''I Pol.
PROTECTION AGENCY
~ -.trfu. ?c.~ 'J
MAY 0 2 1994
~ONTANA OFFICE
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138
;'.pr i ~
:7, :994
~ike ar.d Debra ~,ankovich
3207 ~.mherst
Butte, MT 59701
eN'iIFtON"'fN~~'I'
~oTECT10N ,.
APR 2 9 \99-
~ONTANA OFFICF.
~r. . Russ Fcrba
U.S: EPA
301 S. Park
Helena, MT 59626
. Dear ~r. Forba:
We protest and object to the proposed plan for the Berkeley
Pit. We feel that the plan is inadequate and that immediate
action should be taken to resolve this serious problem. We
are alarmed that procrastination is considered a viable
option in addressing this problem.
As members of this community, we expect ~CO to take
responsibility and commit to total cleanup of the toxic pool
which has accumulated to date. We feel strongly that
~easures should be taken to prevent further contamination.
Surely there are less antiquated processes available in 1994
than those in the current plan. Can new technologies like
Relation Chromatography be used NOW to begin the cleanup?
The Pit poses many problems for the commuhity of Butte
including environmental, economic and social issues. We
find it unacceptable to plan for perpetual care of a
hazardous situation, a poison pool, a potential disaster
waiting to happen. IT IS ESSENTI~L THAT CLEANUP BEGIN
IMMEDIATELY!
S~rEeJ;i.' ;' A> II
'1kr~~
C ~ f~2.v1o...~~
-------
139
EN\/IAONMENT AL.
~OT£CT1ON AGENCY
APR 2 9 199.
'.AONTANA OFFICE
April 27. 1994
~r. Russ Forba
EPA
301 S. Park
Helena. ~ 59626
Dear ~r. Fori:a:
I have been to several hearings and reviewed the documentS penaining to the EPA and ARCO's remedy
for the Berkeley Pit.
I oppose the plan to let the rit pill to the proposed critical level and not build a treaDDeD1 plant until the
next centUry. What this does is create a 6OO-acre waste pile that does not assure protection of the local
aquifer. Silver Bow Creek and downstream resources. It putS off a solution to the problem and continues
to threaten the viability of Bune. The result is that people and businesses are discouraged from locating
here. ~ore seriously. it shows a lack of concern for the health and safety of Butte people.
To begin to create a solution now would be good for the environment, the economy and the peace of mind
of all Butte residentS. Please consider a treatment plant now, or alternatively, some of the mineral
extraCtion possibilities mentioned by various companies in recent newspaper articles.
Sincerely.
Jf:t~
114 S. Jackson
Butte, ~ 59701
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ft 140
~, EPA
Region VIII I
Montana Office
Superfund Program
Silver Bow Creek/Butte Area Site
Butte and Walkerville, Montana
I
DMRONfIIIEM'" AI. 1
PROTICTION AOENCy i
APR 2 9 199~ 1
~UNTANA OFFICE'
l'
COMMENT SHEET
Please write any comments that you may have concerning the work planned on
this sheet.
- \
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NAME: vi L. ,rl i.:::J C'"" d I .
ADDRESS: ~ / A j.,/ P- 10 ", h \J P )/
, /
f3" ff.~ H 7- .c- Q -,. '" .'
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7tF~-,(,,4~
Russ Forba, US. EPA
~ontana Office
301S.PMk,~awerl~
Helena, MT 59626
PHONE:
Please return to:
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141
:228 Grand Avenue
~~::e. ~on:ana 5?~J:
";;,rl.: 2'7. :. ?34
ENVIRONMeNT..\.
C>ROTECTION AGENCy
APk 2 b 11J~4
'AONT.ANA OF~IC~
~~=. ~~ss :,::"ba
~~.:ironmental ?rctect~~n
:;:''3'5. Cl.ari< 5t.
:rawer 3016
~e~ena. ~T. :9601
Agency
, :ear Sir:
f:.:. :ure
attendance last n~ght ,of the meeting to discuss the
or the Berkeley Pit in Butte, we were informed that
At our
we might express our :eelings
in this manner, by writing
to you before Apr~: 19.
Our home is
located relatively close to the Pit, and we
have a well which supplies us with drinking water as well
as watering for our lawn and garden.
If.the water in the
pi t is allowed
to rise
to the
"critical water level" it
~culd be w~th~n 50 :ee~ of ~nen water would discharge into
, the
alluvial
aquifer.
thereby
posing
a
most
dangerous
position for those of us who pump water in this area.
We
were informed a few years ago of a person who lives within
six blocks of our home who already has been restricted in
well digging because of the condition of the water.
Therefore,
we
are
standing
on
the
feeling
that
it
is
dangerous to wa1t ~ntl.l Loe level reaches 5410 feet.
Let
us do
sOmeth1ng
1n the
immediate
future to protect the
health and ftelfare of the citizens of Butte.
It cannot be
too soon.
Yours truly
,ff~4/~~~
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LalaOuloll
110 W. Poop"",
B""e, MT 111701
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142
~!'4VIRON""~:"'" ~l
:>QQTECTIOH AGENCY
APR 2 8 1994
~
C1?U: ~t/ /975/
'AONr,ANA OFF'C~
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Frank L. and Ruth L. Rosich
2328 Grand Avenue
'(1""~'i:.-'-'ii";,'
,'I oJ'~
,:JJ PM '!.)
\ :,', MH /
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Bulte, MT 59701
Mr. Russ f'orua
Envirollll1clltLlI Prulectioll A!.)ullcy
310 5.CJiJrk 51..
I)I~dwe ['
3016
lIelena, MT 59601
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CHEMICAL I~RACT10NS IN SUlfiDE TAILINGS
7
The fernc ion wIll also o:udise the sulfide minerals. The overall reactions without
showing intermediates can be represented:
Chalcocue:
Coveilite:
Cu:S ... tOFe!' ... .&H9 = ;Cu" ... lOFe;' - HSO. - -H'
CuS ... 8Fe" .. .&H~O = CII;' ... liFe;' ... HSO.. ... 7H'
Ch.tlcopynte: CuFeS; ... \6Fe" ... ~H:O " Cu:' .. \"Fe" ... ~HSO, ... \.&H'
Bornue: Cu.FeS. ... 36Fe" ... tbH,O = :Cu:' ... j-:'F.::' ... .&HSO. - ;SH'
The pH of these re3cuons of the femc ion with sulfides has been ;mumed here
:1) be below pH = 1 where the SO:' . HSO; equilibrium etlSts. Above pH = :
rhe equallons would involve SO~- rather than HSO;. It is likely that se\erai
Intermediate steDs are involved in each reacuon and. as with bornite oXldaticn".
intermediate solid phases (Cu)FeS,1 may be formed and may slow the overJII
reaction. Also elemental sulfur may form as an intermediate but this is possible
only at low pH. high sulfate concentr:uion and low metal ion concentration in
solution. This lalter situation sometimes occurs In sulfide tailings.
The reactions of the ferric ion with sulfides aJso involves the action of o:mzen
in the air which will oxidise ferrous ion back to ferric species: . -
~Fe.:' + 0; ... ~H' = .&Fc'" ... :H~O
~Fe.:' ... 30: ... ~H:O = JFeOOH
These reactions are accelerated many orders of magnitude by the influenc~ of
bacteria such as Thiobacillus !trrooxIfJIJIIS'J.
The presence of ferric sulfate can lead. to precipitation of basic' ferric sulfates
(and jarosites with Na' . K' etc.)
3FeI' + 2S0!- ... 6H:O = HFc:,(SO.):(OH). + SH'
3Fc" + 2SOj' + 6H~O + K' = Kfc, (SO.):(OH). + 6H'
The mineral goethite (a-FeOOH) which is shown as a pWduct in several of the
above reactions is in fact ferrihydritelS which is a less crystalline material with large
surface area and capable of formmg :I broad range of iron bearing :naterials (g~s'
sans). Thus the supergene alteration of sulfides aJlows the binding of ':Jtion~ of
Cu. Co. Ni. Pb. Zn. Cd. etc.16 :lnd at lower pH the anions of As. 5e. Sb. :tc.
These reactions result in the formatit'!1 of I:!terites with n~merous poorly cryst31!ine
and amorphous phases and are t:tus "scavengers" which collect and Jccumul..te
metals from the solution which may :nigrat.: through the laterite. Alisorption plays
a very imponant pan in the first stages of :he~e r~ction5.
..
RelCtions in the Reduced Zone in Sulfide Tailings
There has been vinually no in\'estigation oi [he reactions which oecur in the reJu.:eJ
zone of a tailings heap. It has been ~umed that metJI ions liberated in [he o)(jJised
.zone will reprecipitate as sulfides in the reduced zone but that e\entually [he
oxidation front will proceed to the bottom oi the tailings. In the reduced zone oi
-------
R (j. ROBINS
of soluble sulfides (mediated by the action of microorganisms). It was mentioned
earlier In this paper that there were the soluble complexes of iron.
Fei HS )': and Fec HS)j. It IS also known that many other metal sulfide complexes
eXist (see Table II) JRlJ that metal sulfide minerals are soluble (to some extent)
In sulfide solullons. Khodakovskiy" has discussed the transport of heavv metals In
(he iorm of hydrosulphides. giving specific data for the solubilities of ihe sulfides
Jj Fe. Zn. Pb. Ag, Cu. Co. CLI and Hg.
The solubility of gold and sllv.:r in high temperature sulfide solutions has been
''''Idely I.westlgated also to explain transport In ore fomung solutions. The solubllitv
,)i ~opp.:r sulfides In sulfide solullons has been studied by several authors"':o. I~
:,.S9 a numDer oj papers on the solubility of metal sulfides in sulfide solution and
the various thiocomplexes involved were published together in the Journal Geo.
;:;iffil':Oi .:t Cosmocnimlca Acta;:. Allhough most of the published work has been
.:onducted at elevated temperature, it has indicated that there is an appreciable
>oluDllit)l of metal sulfides in sulfide solutions at ambient temperature. Somi: of
:he metal thiocomplexes that have been proposed together with free energies oj
formation are given in Table II. The induence of the polysulfide ions
S~'. Si'. Si' . Si' , and S; - on the solubilities of sulfide minerals has also been
considered to b.e appreciable I!.
In a sulfide tailings heap it -is considered that there is an oxidised zone and a
reduced zone. The reactions leading to the oxidised zone were discussed in the
prevIous section of this paper. The reactions in the reduced zoile have not been
considered in the usual models for determining the chemical stability of tailings.
At the Interface of the two zones there will be interactions between dissolved oxygen
and dissolved sulfide and these interactions will almost certainly be mediated by
microorganisms. Jorgensen and Revsbech: have shown the inftuence of the col-
ourless sulfur bacteria B~ggialoa spp. and Thiovuiwra spp, at the oxygen-sulfide
interface in sediments. This interface was shown to exhibit very sharp oxygen and
sulfide gradients above and below it. and it is likely that the same general conditions
will exist in sulfide tailings, Davidsorr' bas reviewed what has been reported as
TABLE II
Some metal thiocompleses and pol~lfides and theIr free energies o( (ormation as given In Saumov
et al.': .
Species ~(j';.. ~'al Species ~(j;.. ~'al
."gHS. -~.I Hg\HS)d .' -I)A
Ag\HSI; -1.0 HgS;' -10.0
CdHS' -:9.6 PbtHSI'! -:0.9
CdlHSW -~~.4 Pb(HSI.- ':"19.8
CdIHSI," -jS.S Zn( HS I! -49 ~
Cd(HSIi' -j5.6 Zn\HS)j -.48.5
CofHSl' -18.3
"."" :'" COIHSI¥ -19.6 S!' -190
- ."" , CuIHS)j -11.1 Si- -17.6
.. FciHS), -:9.5 5;' -16.5
FefHS),'; -:9A Si' -15.7
-------
.".' ,
_.
0" ..""0"
::HE~IC"L I:'/TERAcnO~S IS SI..:"F1DE T.>,ILI~GS
measured solubilities oi ferrous sulfide in natural waters. and claims that (here IS
3n apparent Increase In the solubility product with depth for Ihe reactIOn:
FeS - H' = Fe" - HS'
which IS probably due to the associated potential gradient,
The solubility oi FeS in sulfide solution can be stmply considered in terms of the
pH dependent equation 3bove Jnd can ,e Illustrated by reference to Fi~ure I
Ho-'-'e\cr. the eXistence of the proposed ferrous sulfide complexes" Ic:ads to JU,
dlllon31 solubility equations:
Fc:S - H:S" = FeIHS)~
FeS - H:S. - HS' = Fe\HS)..
The dissolution of pyrite in the reduction zone is likely to be more complex and
to involve polysulfide ions:
FeS1 ... H' = Fe"' ... HS:'
FeS: - 3HS' - H" = Fe(HS)i ... HS1'
Similar sulfide complexes proposed" to explain the solubility of covellite lead to
the equations: .
C~S ... H:S. ... HS' = Cu(HS)i
CuS ... 3HS' = CUs(HS):'
"
Shea and Heltz:o have interpreted covellite solubility data in terms of the complexes
CuS(HS)i- and CuS(HSH-. and the polysulfide complexes Cu(S,)i-. Cu(S.)(S,)J-
and CuS(S,):- for which they give stability constants.
Arsenac is often present in sulfide mineral assemblages in the form of the indi-
vidual arsenic minerals shown in Table I and many others. The solubility of these
minerals in sulfide solutions bas not been directly measured but the solubility
of orpiment in sulfide solution has had considerable anention as reviewed by .
Spycher and Reecf'. Stability constants have been proposed variously for HAsS~
AsS~-. H:As:S~. HAs~.-. A~i-. H,As!sg. H~As,s.- and A~a-. and well docu-
mented solubility measurements on As:S! in sulfide solutions show extremely high
values In the neutral to alkaline region.
The author has calculated a number of solubility diagrams (log activity \'5, pH)
for some of the sulfide minerals in sulfide solution using free energy data from the
literature cited above. The diagrams were generated using the program DIASTAB:!
which is one of many which are available for that purpOse. These diagrams indicate
that the solubilities in some cases are small, but sufficient to generate solute ions
in the reduction zone of wet tailings. The solubilities (in activity units) of iron
sulfides in sulfide solution are shown in Figure 3 and those for copper sulfides in
Figure .a. In these diagrams p.. values. decreasing from pe. = -.a. relate to a
. decreasing potential in the reduction zone, On a pf-pH diagram the p.. value
indicates the position of a solubility scan on a line which is parallel to the SOi - I
HS- interlace, For example the scan at pto = -.a is a line passing through pf =
-------
'.
;; B
H
~ 9
I[
H
Q 20
1-11 ilJlU' J.
"IU':.
.\
I .
o
IRONIIII-5JLFURI-III-WATER
T: 2911.25
~.... E C 1I:t".
CONSIDERED
----f-------t----.. ..--..-t_u_.. ---
, FI:"'.
~ f-EOH+
:J ,.. E 10HI 2 IALII
4 FE 10Itl 3-
~ FE CU. II 2 I~I
b ~ t: C~ISI 2 IAUI
~ f t' 11151 :3 ..
tot ~.t." ISI
Y ~ t. S~ ISI
1 u t- t:. (!;I
.11115-'
12 S-.-
,:::I "2S IALII
FES2 ----
2
:3
Ft::S ----
4
I
./{"
I
I ./ I
I I/'I
I 0 1'/ I --
: FECHSl2 I/FEIH513!.......-'---
I - ./'j ....
PE7=-10 -. I /./ I
I I/" ---
I : /' I ----
I 1/ I-
I /1 ,...;..-"""'-
I -.......- I /1
PE7=-g ../. I ----
.1 I / I ~~~~
I ," 1 --
I ./ V-
I .---""'" /1
I PE7=-B I PE7=-7 0 I
..~..---. ~ ,HaS IHS- I
3 4 ~ B 7 B
L~
FE".
~
6
7
2
pH
I
9
I
10
--f------+._. ---.
12 IO?
I.ng iU:'lvity f..,lrun)-pll dI4S.4Im ,hoWln8 calcul..lcd w.duhdily hnc~ fur the 111111 ~ulJhk!lo I ,'S ,&11,11 ,'~ .tI ,hlkl,"1I1 k,,:h III Ilh ":..,,,......
::;
'"
CI
'"
o
ID
Z
-------
I . ~ ( .
. ,
"
'(
~t...t:Cl~S
o
COPPEH-SULFIOE-WATER
T: 29B Ie
t, ..--.,.- u-t- ...n. t ...-.-t --.-..t---.-- ~
t CLJ..
2 CUS "iSI 2--
:3 CtJS I~'SI 3---
4 CIIS 151
~ cu 1 ' 7~5 151
6 CtJ 1 96S ISI
7 CtJ2S ISI
it ell ISI
y S',.
'10 115-
11 .125 IAUI
S
2
3
4'
e
6
7
8
II
1&1
0. 9
Q
0
U
a so
2 3
pH
I'IliIJIU, ..
CONSIOEAt:U
A
:: CUS
B :: CUI.7eS
C :: CUI'SBS
4
-7
II :: CU2S
PE, ::' -4
" PE, ::
-~
PE, ::
-6
CU5IHSI;
CUB ( HS 1:-
PE, ::
7
B
S
10
11
12
1::1
1,IIg 1I,,1i'lly Ia" 'u"perl'pll diaaum Ihowina calculated ...Iuhlllly line. lu, th. cuppe' .ulll.l.,. lit d,lIc,elll In"h Ifl Ille ,,,duLllun lUll"
Ii
J:
m
~
;:;
:...
,...
'"
;;1
'"
).
~
<5
'Z
v>
"L-
v>
r.
,...
:!!
c
m
);!
;::
~
C\
-------
.,
q rj ~OBINS
The solubility regIon for rhe copper sulfid~s In sulfide solution as shown In Fillure
~ IS andic:ned on Ihe p,.pH diagram for the copper,sulfur.water system In Fi2urc
: as a hatched area. This solublliry reglon.w'as not generated by t,he p,.pH comp~ler
calculatlon due to the "predomlnant Ion limitation which applies ro the partlcular
program used here I this IImltatlon e:mrs In most programs which generate potenttal.
pH diagrams I.
Ir IS assumed here that the reduction zone lies below the sulfate-bisulfide Inter-
::;ce. However. It IS likely that rhe real redox Intedace IS kinetically controlled and
)0 may relate to rhe S:Oj' HS' coupie with an annuence irom other sulfoxy anions
lnd POlysullides,
T~e above bnef discussion on the solubility of sulfide minerals in sulfide solutions
and rhe likely mediation of the associated reactions by microorganisms leads to an
ODVIOUS application to the chemistry In sulfide tailings. These considerations have
nor previously been put forward in modeling the chemistry of such tailings,
Artemors ro model rhe chemical reactions in sulfide tailings have had ro dell
with rhe complex chemIstry IoIonlch IS very much simplified above. In most of rhe
models the oXldatjon of pyrite to produce acid is taken as the controlling reaction
and rare equations based on rhe Singer and Stumm proposals'A have been used, It
has iurther been assumed that oxidation will commence at the top of a tailings
deposit and proceed to the bottom and that the solutions generated will percolate
10 the bottom and if allowed to escape could carry the solutes into ground water.
A CASE STUDY
"
A \iery detailed study has been conducted of the sulfide tailings left at Anaconda. ,
Montana. l:SA aft~r more than 100 years of copper smelter operations:6, Today
these tailings consist of about 150 million cubic: metres of material covering a total
area of 2.500 hectares (about 9 square miles) at an average depth of tailings of 6
metres. In this study more than 100 wells were inserted tbrough the tailings. some
into the alluvium below the tailings. Although the mineralogical characterisation
of the tailings was difficult a good indication of solid phase concentrations of selected
metals was obtained. Solute concentrations in the tailings pore water and in the
groundwater were measured and a geohydrologic characterisation of the site de.
termined.
The geochemistry report on the Anaconda tailings predicted future water quality
conditions within. beneath and down gradient of the tailings. The predictions were
made primarily with geochemical models including MINTEQ~ and groundwater
transport models and additional models developed to simulate leachate generation
from the tailings. Acid production in the tailings was determined from the simu-
lation of pyrite oxidation with a rate constant which was "based on the literature
reviewed." The executive summary in this report stated that "model predictions
indicate that Ihe oxidising zone will move downward until it eventually reaches the
bottom of the tailings ponds" and went on further to say that this would take a
period of 10.000 to 50.000 years depending on the locality. During this oxidation
period it was predicted that the major ions such as calcium and sulfate would move
-------
.'
CHE~IC.~L (:-;TERACT10:-;S t~ SI;LRDE TAILINGS
:J
througn the reduced zone Into the groundwater. but thata~ntc. cadrTllum. copper.
lead and zinc would precipitate as metal sulrides In the reduced zone and be further
retarded hy adsorpllon.
In the Anaconda tailings study no conslderallon has been given to the POSSibility
of leaching In the reduced zone due to the formation of sulfide complexes of the
metais. yet there IS very strong eVidence of that having happened. Early in 1985
e1gnteen boreholes ""ere drilled through the tailings (0 penetrate the underlying
alluv I;)m and conllnuous cores were taKen In these boreholes. Ten of the boreholes
were ;ompleted as screened wells in the taIlings for future water sampling. The
cores ....ere logged and sealed in tubes to await analysis. All aspects of the in\"es.,
ligation lI.ere weil prepared and competently executed and the thorough repOrts
on (he proJect are an excellent source of information for future study. However.
many assumptions were made and the conclusIons reached in several areas are not
based on a complete understanding of tailings chemistry. The chemical analysis of
core samples has been well documented and supported with excellent indicators
of quaiity assurance and quality control.
The chemical analysis of the core samples from the Anaconda wells is shown,
graphically in the final geochemistry report with bar chans of element concentration
versus depth from the taIlings surface. extending In some Instances mto the allu-
vium. These analyses have not been extensively examined to obtain information
ahout chemical interactions but there is obvious evidence for the loss of certain
metals In the reduced zone of the taIlings together with a loss in sulfide sulfur. This
giv'es support to the proposal that the solubility of sulfides in the reduced zone are
a very Important aspect of the chemical model for sulfide tailings.
Figure 5 is a diagram illustrating the general trend of some of the element
concentrallons Ix axis) with depth Iy axis) in the Anaconda tailings well-cores. It
is a trend which is exhibited by other elements in manv of the analyses reported.
and a more detailed examination of the results should be conducted.
CHEMIC.\L MODELS
-,
,r. .".:. ."
A knowledge of the various species oresent in tailings and an understanding of the
chemical reactions likely to occur would enable very useful predictions in terms of
environmental impact.
The calculation of trace element speciallon using mathematical models based on
thermodynamic and kinetic concepts has become popular during the past twenty
years and some complex and very useful computer codes have been developed.
Some of these codes have been applied to the calculation of the formation and
movement of trace metal species in saturated and unsaturated zones of tailings and
the chemical interactions that occur with sediments. alluvium and bedrock. The
application of these models to complex sYHems dc-arly presents some problems;
in particular the presence of unknown solutes or complex ions that have not been
thermodynamically characterised. interactions with complex organic materials
(humic and fulvic substances) and the presence of colloidal material of uncertain
mineralogy. As a result of these problems. the application of the various codes to
-------
. I
I'
. .
dOR"..OLE
.:~
. aOo
~
~.
L
.
-.-- ----.--.
BUA
UOHEHOLE
UUH" ItU.. E
UU
I:HH'.~"UI. t.::
BUB
.:~ .:~ ..:~
100 100 11,10
10
L ~,..
. 10
~-
10
~.~~..
L
SULFIDE SULFuR ,.,
COPPER g/1<8
~
.
~
. .
ARSENIC g/Kg
.-.---.
tttJL
UtHH..ull t=.
tttt~
..
'"
CI
:u
o
GI
Z
'"
rUitJHI: ~ U,",UIl Cy a.I)) V~ nJlIl:clIl.allun.(. tI.i~) uf nun. )ullidc:.,ulphUi. cUI'I~' ~IUJ d.)ClUl III 1 Ill" )ulilllllh'" 1.IL,'n hu... 'lu.l) '~Udhill') 10 111(
An.u.u...I.. I.uhug.."'.
..
II ..
100
~~
IU
--'
IS
L.
-------
CHEMICAL I:"/TERAcrtONS I~ SlilFIDE TAILINGS
. I~
TABLE III
Some or rhe C.,mI'Uler Cude5 Invol"", Ch~mlC~1 ~odeh"g 01 AqueoU5 S"lem5~
lET..~GROP II%~I \II:'ITEO Ilq~3)
HAlTAFAlL II%i) ~ICROOL 11~~ql
COMICS IIWli) CHEMEOl.:ll tlqM)
COMPLEX IIq71j1 EOJ.6 Ilq'71l)
SIAS li9r.1 SOlVEO ,!~~~)
w", TCHEM '19i:, PHREEOE I :QIlOI
""...TEO ,lu"J, THER~fO<:HE~1 (:~M71
WA TSPEC '19'"j RIVEOL ,:u~:1
SOL~t:>OEO : !97}) ~EXAMS ,IU~~I
REDEOL (!97:) FIESTA 119":1
\U:>oEOL 119'(11 TRANOL 11~~bl
REDEOL.l.:~D (198.&1 DYSAMIC 1191161
GEOCHE~ t :980)
a complex system such as tailings cannot be expected to give precise answers. but
can certarnly indicate likely trends.
Table III indicates some of the computer codes which include chemical speciation
modeling thaI have been developed over the past thiny years. A review of those
codes ~hlch are currently of interest has been published by Waite:- and there are
several chapters on these codes in the book "Chemical Modeling an Aqueous
Systems II"~. The program which seems to be used most widely at the present
time IS ~lINTEQA2 and version 3 is now availableJO with capabilities which will
allow adsorption processes to be considered. The complexities which are introduced
by considering the adsorption of different species onto other minerals add funher
to the inaccuracy of model predictions.
CONCLUSIONS
'....... ..
The generation of tailings from the processing of sulfide minerals has led to various
environmental problems which are mostly related to groundwater contamination.
Many of the metal contaminantS in these waters have been identified and are. often
monitored continually. but the precursor chemical reactions are not fully under-
stood and many of the chemical species involved have not been identified. Attempts
to predict the future chemIstry of tailings has to date been very inaccur:lte. The
computer programs that have been de\'eloped for this purpose will give good
indications for simple systems of known chemistry but for complex systems in\'olving
tailings the predictions are poor. Problems of adsorption funher complicate any
predictions.
In order to design tailings systems for mineral processing wastes prior to mine
development, the tailings materials must be evaluated for their potential to release
acid and metal solutes. The use of existing data from similar tailings disposal areas
(such as the Anaconda data) can provide a good indicator of drainage quality, but
such data have not been adequately examined in terms of the actual chemical
-------
;/,
R. G. ROBtNS
be conllnuc:d. and re.examlned with a more fundamental approach since the data
irom those ~tudles are rarelv available. .
Due to thc:\'arious uncen~inties mentioned above illS really necessary to conduct
predlcllve tc:sts wllh J view to sillng and construction of a tailings disposal area in
relallon to the potential environmental Impact. Solid ph3SC char3CterlS3tion and
dissolullon e~penments should be underraken. Solid phase characterisation can be
~eriormed iairly ~ulckly uSing such techniques as )t.ray diffraction. opttcal and
~!cctron microscopy. e!ectron probe mlcroanal~sls (,,,"d others) combined ~lIh
..:hem,,;:!1 analYSIS.
T~~~nl4ues useful in predicllng mine waste drainage problems have been CIS,
.;;mea :,\ LaDakko' md Fen!uson and Erickson". The use of shake'~ask leach.
..iOlO num'ldIlY' celts tests have -been recommended":. but the best simulation is ob.
talned in column tests'). Column tests 3110w for the formation of stratified zones
which are SIml13r to those which form in a real tailings situation. but most of these
(eStS have been conducted in columns that are too shon in relation to the height
oi the proposed dump and do not allow for the formation of a reduced zone in the
lower secllon. The column test is not an accelerated iest and hence does not reve31
long term interactions. but such tests should be set up and run for many years to
observe the chemical changes that will occur in tailings. .
Shon term testing ior the leachability of metals from wastes needs also to be
considered. In the United States in 1989 the Environmental Protection Agency
introduced the EPA leaching procedure Method 1312)0. with a rather arbitrary
protocol using sulphuric acid/nitric acid at pH = .U. to initially characterise wastes.
The prediction of long-term behaviour from these tests is not poSsible.
II IS obvious that there is enormous uncertainty in relation to the chemical
speciation. reactions. and prediction of behaviour of metal sulfide tailings. These
areas all need much funher investigation.
The references cited here are a select list of books. proceedings. reports and
papers which provide some further information about the subject which has been
addressed here.
Reference.
..
~
I.' K. upakko. Solid phase charactcrisation in conJuncrioll with dissolution cllpCrimenlS for predic.
tlon of dr:llna@c qualicv. Procccdinp of thc W~tcm Rcponal Symposium on Mininl and Mincral
Prncc5Sln2 Wastcs. Berkclev. CalifornIa. Mav I '/QQ. Fiona Dovlc tEd.). SME. Liulcton. CO. pp
.~I-M. - . . .
, P. H. Ribbe lEd.). SuJfldt .\tilltra/Of)'. MincraJolJCII SocIety of Amcrica ~Ol~. Vall 197~.
J. R. M. Garrels. 3nd C. L. Chml. 50/11110111. .\tillmW IUtd EqwlibritJ. Ha~r &: Row. I96S.
~. D. G. Brookins. Eh.pH Di'WGIfU {o, Gtochmw",. Sprinser. Vcrtq: 1987. 176 pp.
S. F. M. Doyle. and A. H. Mirza. lindenWldinlthe mccllanism and kinetICS 01 acid and heavy
mClals r.clc:ase from pyrilic "'ast~. Chaptcr 6 as In Reference I. pp 43-5 \.
6. D. A. J. Rand. O.ygen reduction on sulfidemancrals. P:m III. J. E/tCUOQIIGI. Cht"'.. 8J (1977)
19-32. .
7. R. T. Lo.-son. Aqueous o.idatlon 01 pynle by molecular o.ygcn. Chnrt. RtIIltWJ. 81IS) (19821
J61-497.
8. P. C. Sin@er. and W. Siumm. Aad mlnc drainage: thc rale determinins step. SertllCt. 161 (1970)
11=1-11:3.
9. C. O. Moses. CI 31.. P~'riIC o.idauon by dissolved o.ygen and by lerric iron. Gtochi",. tI COJ'
-------
CHEMICAL I~TERAcnO~S IN SULFIDE TAILINGS
!1
it) C 0 Mines. ~d J. S. Herm3n. Pynle olllUllon.1 mCUmneU.,31 pH. (i~ocllllft ., CcJslftodllm
..1m. S~ 1111'11) .71-~2.
: I J B. Hlskcy. 3nd W J S.:hlnt. AQueous olld.lllon of flyrnc. Proc. :nd SME.SPE (nlcrn3110n3'
Solullon Mln,"g S~mposlum. \Ii J Sdlhn I Ed.) Dcnver. C..lur3do. ~nvcmllcr IV"I. pp ~~- OJ
:~. G. B. :-;aumoy. Cl OIL. HlllltJb
-------
,
~DMINISTRATIVE RECOHU
I S4
.~pr il 21, ~ 994
U.s. Environmental ?rotection Agency
Butte, MT Office
Montana Department of Health &
Environmental Sciences,
Helena, MT
Citizens Technical environmental Committee
Butta, :-IT
Ref: Butte, fliT
Mine Flooding
Dear ~adies and Gentlemen:
The following are my. comments and concerns about the
risin9 water in the Berkeley pit, the Butte Hill and the
surrounding area:
I
I
~
I rec09nize the fact that the Berkeley Pit and the old
underground workings of the Butte Hill ate acting aa an
inverted cone (cone of influence).
I am in favor of the proposed additional monitoring wells
in the eoutheast quadrant of the Butte Rill'. Hopefully the
question of concern about possible migration of waters away
from the Berkeley Pit in this area can be answered.
The question in my mind for this area is whether or not
because of heat and, pressure, the aerkeley pit water May be
moving in a south-south easterly direction and if so, are these'
waters being influenced by the Continental fault and old mine
workings?
1 believe that a outer water monitoring system weet of the
Butte Hill - Summit Valley aquifer should be implemented to
identify any irregularities as to water flow and what elements
are contained within these waters. I would like to see
quarterly monitoring and a quarterly reporting of thoee
results. 4401307
1
I 111111
439192
FROM EP~ MONT~N~ OFC
09/07/94 15:33
p.. ' z
-------
".
, .
. \
,
i
I
1
J
I
I
I
I
,
Seca~se of the geological complexity of the autte area
havi~9 large land areas influenced by old mine workings,
faults, ' ein structures, aplite and rhyolite dikes west of
Sutte, the following location would be my recommendation for a
Headwater Alert System: .
*
The Bull Run Creek Drainag- flow ~onitoring and testing
station.
Located in
Q~arter {NE~ NE~),
North, ~ange Eight
the Northeast Q~arter of the Northeast
Section Thirty Two (32), Township Four (4)
(a) West, P. M.M.
* The Oro Fino/Beef Straight Drainage flow monitoring and
testing station.
Located in the Northwest Quarter of the Southeaat
Q~arter (NW~ SE~), Section Six (6), Township Three North, Range
Eight (B) West, P.M.M.
* The Browne Gulch Drainag- flow monitori.ng and testing
station.
Located in the Northwest Quarter of the Southweat
Quarter (NW~ SWia), Section Fourteen (14), Townehip Three (3)
North, Rang' Nine (9) West, P.~.M~
* The whiskey Gulch crainage now monitoring and testing.
station.
Located in the Northwest Quarter
Quarter (NW~ NE;), Section Twenty Two (22),
North, Range Eight (8) West, P.M.M.
of the Northeast
Township Three (3)
* The Gimlet Gulch/Rocker Drainage North flow monitoring
and testing station.
Located in the Southeast Quarter of the Southwe.t
Quarter (SE\ Sw\), Section Sixteen. (16), Township Three (3)
North, Range Eight (8) West, P.M.M.
.. - " ... .... - ,... ... .... . . - ,.. . . .... - - -
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* The existing gaging station at the Colorado Tall ings
and at ~iles Crossing should be upgraded for said flow
monitoring and testing of ~aters and be incorporated into the
above ~entioned Heaa Water Alert System,
ALSO
* In addition to the ~ater levels monitoring conducted by
,the ~ontana Bureau of ~in.s & Geology, I would like to se. the
Orphan Girl Shaft ?laced on their elevation comparison data
shut.
* I would like to 05.. either the Nettie or Norwich Mine
water levels .monitored. By this action, water levels can be
checked east and west of the Whiskey Gulch £ault.
It is my belief that thia hult system lIIay shed some
light to possible water discharge from the Butt. Rill aquifer.
The intent of my proposal is to have, inplace, a way of
checking whether or not these drainages are gaining or loosing
in water flow and whether or not these 'waters may be
contaminated.
Because of the complexity of the Butte Hill's geology and
two billion tons of ground disturbance, the outer limits of the,
potentiometric surface ia truly not known.
By having this Readwater Alert System in place, it may
give our community eome time to correct problems if they should
ariae.
cc:tile
MR:sr
Respectfully yours,
M:t~~
09/07/94 15:;34
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FROM EPA MONTANA OFC
P. 4
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i.~eCie~C1~n~i Indusr.;',
'~::e ac~ec '.'Je::.~~r ~upply "Nouie ~nsu!"e a l!1c:"ease In the recreational
;r'.c~st.ry In Montana. A sufficlent water St.:PPly would increase the
't.::c"; -rc"'" 'cts for the 10..~ O~'"""C 'H"" &iS~'''''''' '-C'II~t-'cs AdA" i"n~l
:.=_'-oot:" ~"-'" '" W~$c~..."c;.;....~.~ 4....=~~.. ""- .."'. ~.-!\J (;A
~'~a~::t:es of water wC~lc also beneflt s\..i.ch :ndust:-:es as bcating,
-;.,.....~ ~,..,..j ....the""' re'''.:1~c''; ".:I"'..'?l't'es hQ~'?"" -cll'''.:I....t C"" ".:In ".:Ia'eo' '~te
:.. ':'..... . ~, <;... ....... v'- ... 4~." '-8 ""'- i.. ... ~ .....,~ ( I.. Y .. "'" "'1.. ...L c;A '" .. '-4c;.4
'.'.'c,::3:- S---~;:;::'I Tr.e pCle:;.tia,1 cf the state's :c~ storage units 1S 20
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:-~.::::~c:-'. cr ~.cre l:1 ac:-e :eet of water.
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'''''Q'.Is i r-~'rQ,...", t~e S' '',...;Q,..: ""'at~c,.. 'n~:H -,.."'../ 'oe ?"'\a'cntable
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:"-f"'I"""''''''C''''' ""''''''''' i ..,: 0... :7-""""-':--0 ~ ',... S.,... r-.:"";c I' W~th due to the
'.v............S<..-........Sc:.S c:...-.......... I...a...c:: ...........,~.........all. .-. -..
~:::>""'' V'Q",--,..,i t;-e er:"..,-. ....-...: cv"'"'e'"',.o ';"''''~ "?e-C '"'eressary to crea'':
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OtJ1fJl CAMr
W.... Quality
2/1511994
D[ss()LVED CONCENT'RA nON
-' !:m Lab DATE TIME Fe MIa "COJ a S04 NOJ AI Cd Cr Cu Pb ZD N
o Aaalyais. (mmfddlyy) (HRS) (II1II1) (..,n) (l1li11) (l1li11) (I11III) (1Ii&fl) (",II) (u,n) (u&II) (",II) (uan) (qII) (ua/I)
o.
I'- ORPHAN BOY MBMO In7/1917 14:00 N/A N/A . N/A MIA N/A N/A N/A N/A N/A N/A N/A MIA N/A
I" MBMO 5n1l19.7 12:40 .2.5 8.M 90S 14.5 702 .., <)(I <1 <1 11 N/A 10 90.0
In MBMG 6flSII917 I1:U .27 1.11 N/A N/A N/A MIA <30 <2 <1 <2 N/A 22 18.0
MBMO 51)1119.8 17:10 oS? 1.67 9)9 14.5 638 .06
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BERKELEY PIT QUESTIONS
1. Did the E.P.A., Montana Department of Health and Environmental
Sciences and the P.R.P's know beforehand that allowing the Berkeley
pit to fill up to the 5,410 elevation with toxic water" the
bedrock aquifer would also have to be written off? If so, why
wasn't it explained much sooner to the people of Butte Silver Bow
and C.T.E.C? '
2. What type of advertisement has the E.P.A., Montana Department
of Health and Environmental Sciences and the P.R.P's done so far
for the solicitation of innovated ideas for the Berkeley pit toxic
water issue.. or was this solicitation process given to only a
select few for their ideas? '
3. What type of funding and inquiry mechanism for innovated ideas
will the E.P.A., Montana Department of Health and Environmental
Sciences and the P.R.P's put into place for the solicitation of
innovated ideas (if you can build a better mouse trap, I'll look at
it Russ Forha)? '
4. If the answer to funding is yes, could a panel of experts as
well as people from the community, mining, timber, agricultural and
recreational industry sit on this panel for the adoption or the
declination of innovated ideas?
s. Finally, I can not believe at this point in time, that the
people of the United States, State of Montana, Butte Silver Bow and
the stock holders of the P.R.P'swould allow such a catastrophe of
a high degree and volume of toxic waste and water to be allowed in
this area. This may be the point in time the community should seek
_national news coverage similar to the reporting on the oil spill in
Alaska some years ago. Believe me, this issue has for greater
effects to a natural resource than the oil spill did to Alaska.
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ALBERT MOLIGNONI
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EVALUATION BY CANONIE
4.2.15 Mechanical
Evaporation
Vapor
Recompression
This report gives a cost of $2 to $4 per 1,000
gallons of water. I seriously question this
dollar amount when a few added energy
enhancers could create a clean drinkable water
supply for .50~ per 10,000 gallons of water.
~. Is this the cost of the plant that will
produce 1,000 gallons of water or is this the
cost to clean up 1,000 gallons of water? If
the cost of $2 to $4 per 1,000 gallons is both
- what would the cost be to treat the 1,000
gallons of water after the plant is
constructed?
2. What type of energy sources are needed for
this type of plants operational cycle?
3. How many gallons of water per day is this
type of plant able to produce? .
4. Could we see a set of plans on this type
of unit?
FREEZE CONCENTRATION
~
1. It states in this report the use of
refrigeration to freeze water. Did the expert
on this process take into consideration the
fact that at'certain times of the year (due to
our location) mother nature would freeze this
water for nothing? It is a fact that very
large bodies of water can be frozen by mother
nature in a short time frame. It takes large
amounts of energy to turn cold water into ice
and also large amounts of energy to turn ice
back into water. As I stated earlier, mother
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SUMMARY
Will the preferred alternative enhance mining
in our area or make less the amount of
minerals that can be taken from this are body
by allowing the water table to rise'? Will the
preferred alternative make more or less toxic
water for this area'? Will the preferred
alternative create more or less jobs in our
community'? Will the preferred alternative
. enhance our community image as a great clean
'-~p project or a project thatw.ill have a
multitude of institutional controls'? Controls
that could prevent the people of this
communi ty the benefit to utilize a natural
resource of clean water and easy accessibility
to the mineral deposit in our area.
I would like to know if the E.P.A., Montana
Department of Health . and Environmental
Sciences and P.R.Pls are willing to go the
extra mile to turn our community into a model
of a highly productive al ternati ve proj ect
that could be used for future clean up
projects allover the world.
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In the past, there has been seed money for
other proj ects in our community by the'
P.R.Pls. Would the P.R.Pls also provide seed
money to create a panel of not only experts,
but also people in mining, agricultural,
timber, recreational and industry'? This panel
would decide on the adoption of innovated
ideas that could be cost effective and, also a
unique alternative to a massive clean up
problem we are all now facing.
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MOLIGNONI MANUFACTURING, INC.
ROUT! 2. ROC:~E" . BUTT!. MONTANA 511701
M'. Russ Fcrba. PrOtect Manager
U. S. E.P.A.
301 South Part
. Helena. MT. 59626 .
Dear Russ:
Will yoo please indude the attached letter to Governer Marc Racicot and the attached water
puification System Infermationas par1 of the public comment that will be responded to fer the
Berkeley Pit .
Thank yoo.
Ycus very truly.
oILir
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Albert MoIig1oni
AMlhs
Attachmen18
eNVIRONM~'1 "'\,
PROTECTION AGENCY
MAR 2 1 \994
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MOLIGNONI MANUFACTURING, INC.
"OUTI 2. "OCI(I!t . eUTTI. liltOHT""" S!nOI
The HonaaDIe M..c Aaacot
Govemer of Montana'
State Capitol
Helena. MT 59601
Re: Butte'~ Bertefe, Pit
M;;~f (, I I~~;o
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De.. Govemer:
This replies to ytU letter of March 3. 1994 and jrovides you with. U1h8' infcrma1ion
concerning the types of innovative technol0ges that mi~t be emP'oYed It th. Berteley Pit in lieu
of the EPAIState of Montana -preferred Remedy" to allow the pit to fI and r~ full in perpetUity:
As an officer an the Bowd of Di'ectcn of cree (Butte's Citizen'. Tedlrlic:8l Envronmenlll
Committee funded by EPA g'2nts to help the commWlity ..- it's Supirlund ccnams), lilt.
you, I have been made awcre of a U'emendaus number of inno¥IIiv8 t~,. thll can be
considered fer rescuce recovery (water and metals) at the pit. What has been missing until now is
fer anyone to come fCIWWd with a comjreheruive plan fer utilizing the complex natll'e of the
Berteley Pit fer benefic:iaf and p-oc1ldive ~
The attached doaJment p-esents the be9nnings of whit could be termed a "oIisIic.
awoach to U'e8ting the itt8'8dive, rnuttiple ills of the 'Bertefey Pit Ind mine tloocing in Butte. This
means the legal mandate ~ EPA to p-otld human he8JIh and the envi'onment need not be the
- benefit to be derived tom a deenup plan. As in the unicJ,le alternative ItIIched. the Remedy
could be a setf-suppcrting Wiler Pwificatian System that indudes asped8 of 8ecricaI genera1ion,
referestatian. warer recyding. rnetIIs recovtry, hnesing 9Ik ~ paww -.end. the I8me time
create hunchds of screfy needed jobs an a austainatH builL
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Th. EPNSlate cI Mantana -preferred Remedy" adUaIy hll'mS Butte's 'economy by tIoocing
off access of hiatcric IMerg-CUtd rescuces. I~ the r~ to '\"tcb:8 wilme of
contamin8Iian.. it does the oppoeit. - doubling of the tcmc pit .. Ind the amount of
c:antamNted bectoct 8CJIifer 8'cxN the pit. The. Aemectt ICII'tS the heI out of ~.. Ind
cldltn lit.. People imagine a lot of terrible thi1gs IhII add belli them wiIh . fuI pit - tom
houses sinking and buements ftoodng and weI contamination to the ~ that an economic
dep'essicn 100 er 1,000 yews tom now could hili pumpng and aDow the pit to overftow. No cne
really tnOWI fer ue wnat the conse
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and EPA lWay from 1hi8 "remedy" and the ci&a8l'ou, economic and social cen~encetI it is u,
to cause. We need reucne fer busnesses and profes8ien.. to relocate here, noI 1tIe WCltd',
I..gest body of tmac .d to ctiv. the falk. we have .,.y. W. den, betieve it i8 good pcic:y to
pass (:AI ~ot)Iem. en to (AI kids and then and then. We need innovative thinking. not I
Remedy thlt fit81he old adage of cutbng off one's nose to spite ene', face.
Why not go on recrrd u suppcr1ing the n~ts of the peepe to det..mine 1her own fate and
the fate of ther Jown? The EPAiState of MontinI Remedy wiD likely put Butte n~ out of business
.u I 6vab1e community. Ideas sud\ as the ene attad'led deserve I1e ~ of day..
. .
('m not the oriy affected resident who knows there's got to be. bell.. Wtl'/. We need y(:AI
help to asue we dan, loot only at the Ie88t expensive opticns and Ihcr1change CU' tuue.
Ideas thlt indude social arid economic isEues must be tr~ to ~ 80 the Rem~ doesn,
leave ftmre genera!ions with I perpetUal urresolved a;8ie. .
Thank you fer yas sincere interest and C3'e fer the people of Butte-Siver Bow.
YCIII wry~,
v(U;f(~
Aa.1"~.
MoIig\oni ManutadUing. Inc.
AMIhs
cc:
Senlv Max Baucus
Senafa' Ccrnd BcnIs
. Rep. Pat WDams
Ms. c.a EnMrMr, EPA
M". BiI YeIowiai. EPA
Ptt'. Jack L)'1d1. a.n.SiJwr Bow
Mo. John W8'deI, EPA
Mo.' Bob ~. DHES
Ptt'" Nei Mal. DHES
~. Au. Fc:rbI, EPA
,.... Jm Scaa. DHES
,.... Friti Oily .
Membn at EMIl Lepa1ive Delegatian .
Butte-Shw Saw CQni of Comm "lL QjN1'8
o.t Fat CcIItion
cree
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Albin MoIicJnani
Roct.. lIT 59701
FebnJlry 11, 1..
RK Y IT WA
Benefits for the Community from
. Maintaining Water Levef. at the Bottom of the Pit:
1.
V.., large yotu",e. of low-c08t. dean. Gintable wat. can be ....
available far the community of Butte-Silv. Bow far bcdh ita preeent
and futwe need8.
2.
L..ge amounts of inelpensiye etectricity can be utilized by 1M
r.ommunity. ar 80td at a profit to Montana Pow. Company.
Starm W8t. run-off. a. weO .. the sewage of the community. can
be proceaed into a deu W8t. 8UppIy that meet. th. Sal.
Drinking Wat. Ad r~ement8.
3.
-t.
Metal. that now poae a health rilt in ocr aquit. can be procea8d
at.~~ .
large amount. of glrt)age can be proceaed. th....., reducint
demand an the CUlTent new landfill by .. much .. ~.
5.
6.
It wiD Ip8Wn . syalem to ~oYide a ft. .....y of high-tech. high-
paying jobs that will be sarety needed aft. EPA. MDHES and
ARCa Jaye the community.
The procea can be utiflZed in oth. area. of the .artd to benefit
mantind while practically etiminang the coy.-up and In8liluti0ft8l
Controla !hat .. 8O.e of the poaible "'.m8(i... of present and .
futwe Superfund sit... .
7.
8.
It efinain8lea need far ~ed8lion of Big Hole RiY.. wat... .....
.. SilY.. Late wat.. tb8t could inst88d be utilized far fuhr. n"*
of tbe ciIiz... of the State of Montana.
Summary
IIo8t of !lie f8ch...DRI!!gJes -~ to r .:: ~~t:' ~
01 . highly contaminated ara Into nor co
.~-~~~ achievable. timJ8 the rivbtJlmLln the B.:i.;d
proc.e.. to put these t8Chnol~-: I~:n::for .~ U;;;
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OFFICE OF THE GOVERNOR
STATE OF MONTANA
MAaC RACICOT
GOVERNOI
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STATE CAPITOL
HELENA. MONTANA 58620.0801
March 3, 1994
Albert Molignon!
Rocker. MT 59701
Dear Mr. Molignoni:
Thank for your information regarding the situation at the Berkeley
Pit.
I agree that there are some exciting new technologie8 that can turn
a problem (degraded water in the pit) into a solution (not only
clean water, but mineral extraction from the polluted water). In
fact, I have taken a tour of some of the facUities and been
briefed on the research involving the pit, and share your optimism
in the new and innovative solutions expanded and applied on a
larger scale.
The Department of Health and Environmental Sciences (DHES) has
state authority over this issue, and I have taken the liberty of
forwarding your information to them for their review and comment.
.Thank you again for taking the time to send me your fact sheet. If
= ~4n ae oi aaoltlona1 ne~p in this or other issues, please don't
hesitate to contact me.
Sincerely,
/Vl~~~~~.JJ.
-.
MARC RACICOT
Governor
cc: Bob RObir.son, DHE~
TELEPHONE: (401) 444-3111 FAX: (408) 444..5521
..,
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WATER PURIFICATION PROJECT
!2Y
Albert Moliqnoni
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TREES
Trees ,are one of the main ingredients in the water purifica-
tion process. This natural phenomenon takes places allover the
world's top soil. By looking at the area of Butte Silver Bow
County we can see vast tracts of land that can be utilized for a
large tree growing project. The trees would add to the attractive-
ness of our area by covering up the baring soil left over from past
mining and smelting operations. The tree growing process has
several unique features when it is growing.
1.
Supplies our planet oxygen.
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Takes moisture from the soil for the plants growth.
It also evaporates some of this moisture into the
atmosphere by the tree needles or leaves.
3.
The tree also helps purge or purify the soil by
absorbing the impurities through the tree root
system.
4.
The tree is a solar collector that absorbs solar
energy when the tree is growing. This solar energy
is converted into heat energy by burning the tree
after the tree is harvested. An interesting fact is
that every year many thousands of cords of wood are
burned in our forest from this region in the form of
slash piles that are left over from logging opera-
tions. This is a waste of heat energy that could be
utilized if ,burned efficiently.
5.
The tree or wood from a tree has the ability to
absorb large amounts of water. For example, a piece
of wood 2" x 4" X 8' feet long may contain as much
as three gallons of water, or from 30 to 300 percent
of moisture. This is a fact due to the cell
structure of wood like a sponge. This same fact
also gives the wood the ability to absorb impurities
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6.
The same wood product can be made into charcoal for
a water polishing agent to purify water to a higher
standard. (Example: a carbon filter). After the
carbon filters have served their usefulness and the
impurities in the water cannot be absorbed by the
fil ters, they are removed from the water system
operation and new ones installed to take their
place. The old filters, some of them high. metals,
are burned at very high temperature in a combustion
chamber where the metals are melted and collected to
be sold. The residue left over from the combustion
process are mixed with other ma'terials to make a
. soil conditioner to help the trees grow. The high
temperature gases from this burning process are used
to heat impure water into a water vapor.
7.
The cost of tree planting and tree harvesting is
very low in man hours because of the highly mecha-
nized machinery used in todays planting and harvest
operation. This operation will create new employ-
ment in our area. Also, the type of tree used for
this operation can be of small diameter which will
shorten the time frame from tree planting to
harvest. The demand for this tree product will give
property owners, public or private, an incentive to
, grow this commodity to produce an income when the
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BERKELEY PIT
This enormous deep hole can be turned into one of the best
assets in qur community. I wi 11 now try to describe in simple
terms its cycle of operation. The sooner this project is put into
operation, the greater the benefits will be for our community.
1.
Start a massive tree planting operation in our area
to supply the water purification plant with one of
the main ingredients for the water plant cycle of
operation. After 2S years some of the trees can be
harvested on an annual basis to provide the water
plant its energy and purification material needed
for its operation cycle.
2.
Create a large water and ice storage reservoir above
the 'town of Walkerville. This high elevation
reservoir will supply our community with a cheap
abundant supply of clean high pressure water for
domestic and fire protection. Also some of this
water supply can be used for tree growing,agricul-
ture, mining, recreation, and industry.
3.
Design and build a water purification plant that
will process fifty million gallons of water per day.
With over twenty billion gallons currently in the
Berkeley Pit, it will take about 2S years to drain
the pit. The lowering of the pit water will improve
the water project.
4.
Take all of the water from the metro sewer plant as
well as the storm'water runoff that is now going
into Silver Bow creek. Install a water main from
this water supply over to and down the Berkeley Pit
wall to the present water elevation of the pit.
Because the pit water elevation at the present time
is much lower than the metro sewer plants water
outlet, the water will siphon into the pit. Put a
hydroelectric generator on a large barge, the reason
for this is as the water table drops in the pit
additional water main can be added thereby creating
a higher water pressure source to generate more
electric power to be used by the community or sold
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this water leaves the hydroelectric generator it 1s
captured in a large floating vessel and put through
the water purification plant. A note of interest
is the current cost of electricity to pump water
from the Big Hole River at Divide, Montana into
Butte, Montana (about S150.00 per million gallons)~
If we pump an average of eight million gallons per
day, the cost is S1200.00 per day or S438,000.00 per
year. Wi th the Berkeley pit water proj ect this cost
is eliminated.
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WATER PURIFYING PLANT
A simple, very tall, highly insulated vessel like an immense
thermo. bottle can be installed at an angle near the present water
elevation of the Berkeley Pit up to the highest point of the pit
wall. Wood chips or wood shavings are gravity fed by a hopper into
the vessel about one hundred feet from the bottom of the vessel.
Near this same point the contaminated water is inserted into the
vessel. ~ear the bottom of the vessel, hot clean gases from the
combustion process of dry wood chips and the air dried carbon
filters that were removed from the water purifying system are
inserted into this vessel. The combustion gases are kept below the
burning point of wood or about 250 degrees Fahrenheit. Water is
preheated by the combustion process to keep the combustion gases at
250 degrees Fahrenheit. This is the same water that is inserted
into ~he vessel. As the hot gases are driven up through the vessel
the b:igh in moisture wood chips are separated from moisture by
evaporation. The hot gases and heated water vapor will continue to
rise in the vessel to the top of the pit wall at its highest point
and at this point of discharge from the vessel a condenser is
installed. This condenser or heat exchanger has cold liquid
ammonia in it. The hot gases and vapor heat the liquid ammonia
enclosed in pipes to a high pressure gas or vapor. This action
turns the hot gases to cold gases and hot water vapor to cold
water. The hot high pressure ammonia vapor is used to drive a
turbine or engine to generate electricity to pump the condensed
water to the high elevation reservoir, pump contaminated water into
the water purifying vessel and to run the air blowers of the water
plants system. At the very bottom of the vessel the hot dry wood
chips with the contaminate in them are taken to the combustion
chamber.
Some of the water from the high elevation reservoir can be
brought by pipeline to and down a mine shaft close to the water
elevation in the mine shaft. A water turbine can be installed to
generate electricity.because of the high pressure water from the
reservoir. If this water has oxygen put into it to produce acid
that will solubilize the metals in the ore body of our area. After
many years of this water mining the contamination of metals to our
ground water should be eliminated. If this water that is high in
metals goes into the Berkeley Pit it can be processed in the water
purifying plant. .
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THE USB OF SOLAR AND WIND ENERGY
1.
Trees can be planted around the Berkeley Pit walls at
each bench level. The trees will absorb solar enerqy
and moisture from the soils. After many years of
qrowinq, the trees can be harvested on an annual
basis in this area. This factor will reduce the
transportation cost from tree farm to water purify
inq plant.
2.
Solar collectors and solar cells can also be used for
a heat enhancer and to qenerate more electricity.
The qlass products needed to make solar collectors
can be taken from the qarbaqe waste that now qoes to
the landfill. This qlass product can be manufactured
locally creatinq more jObs for this area. A note of
interest, larqe.amounts of copper are used to make
solar collectors and arsenic is used in solar cell
construction.
3.
Because our area of this community is surrounded by
tall mountains, wind turbines can be installed on the
tops of these reqions that can be used as an electri-
cal supply for the meltinq of qlass.and metals used
in the solar collector and solar cell manufacturinq
process.
4.
Many other combustible products can be taken from our
qarbaqe waste stream such as paper, tires and used
motor oil. Also, the many plastic products can be
used for insulation products and material.products
for solar collectors construction.
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EFFICIENCY CYCLE WINTER AND SUMMER
By changing the flow path of the ammonia liquid and vapor this
water pur1fying plant will have an efficiency rating of over eighty
percent. The wood product will cost about fifty cents per one
hundred thousand B.T.U. This efficiency rating will give us 10,000
gallons of clean water at the high elevation reservoir for S .50.
The people of the present water system pay close to $2.00 per
thousand gallons of water.
SUMMARY
The sooner the E.P.A., MDHES, Arco and the communities of
Anaconda and Butte Silver Bow accept the project design and ideas
I have described in this text the sooner the region can have the
vast array of high-tech, high paying jobs that are now needed in
our area.
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Albert J.
Molignoni
I.' Creation of Water Storage Systems
Creation of High Efficiency Electric Generation
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Creation of Water Stoi'age Systems
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T:~~.8e:- areas ar.c other smaller sites can a!:.:) be uUllzed for the'
~::-e8.t:on of this project,
l-f''cter
'..\;~t.er is a natural resource that this state hns a. grea.t abundance of ir.
:e'::~::'.. tLmes and very little of during a drought penod. The'
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....,. C 'C" .,... """"".'-I:C a "rewt~ r"er:"""; :.....r- 0::'" -~ l'r-,C'US. "'~es as aQn'culturc
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:or ttle project design. With the COld, Wil~d. water and land, massive
:.:e storage systems can be created for c-.:.;- state to insure a.n adequa~e
'dater supply for future use. The system design will place the water
en the lan.e. sterage area (See Land), The massive blocks of iee are
c:-eatec t'/ putting the waler cn the land when the air temperature:s
2e~ow f!"eezmg, l:1 ret.urn, the water- win freeze from the bottom up,
~~liS pr-I;cess is ~:1!L.'
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'.:-. s =-::~s~ s:aole fer-:-::s fer the storage of the ''''at~r The benefits of
-''''-''''0 ._,~tc-'''' .""S !.....,c frame ~"",.. -~r"Q'" '.)rn,
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. :-:~ ::~:'":"'.~~_-:: :C:- ~~..5 S:e.:SS wate:- :s at its ~~~ :est ~e'lel
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;~:e.:e.::cf'.s. :: "tltll C:-S~:5 <: water tr.e Wllh r.:~h r.~~ac pressure wt'.e~
. '-0 ,,.::. --e~~:::::'"" ~:...c :::::--''''0 '.)~c: ~.:~~e'" ---.....,~s -:--"';s e""'ero,y sou.-"::,
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.: 3'/ \..:::::~g ~ g5C::-"S:-~":C '''::.:e:- s'..:;ply, ~:-:: :::-:e:-r:'.odynamic princ:p~;;;.
,......,.; ,."",..; ~;.. ~Q"",,""O-?" '-c:.c:: Pf' Q...,o-o',/ S'" ,~~::. i~ r"'catc,.; to sU"''''''''., t:"'Q
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II.
Creation of High Efficiency Electric Generation
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'~:""..e ~;'"::':",e scurces cf electr-lca1 generat:c='. ::1 Monta:1a are,
: . "/c:-celectric and stea~, 'Nind ger:era::'ic: :--:as aLso been. used in s~al:
",,,""'.o;c<:::~"'" ""'-"";""'0 c:e""-;c.ty ,
. ,~c.;.. . ............- .--' :"".. '-''--''''''-- "'. ......... ... .
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'-'::'-0"" ,,.,.-- ,,,,'.... '/<::Itc- :,.,- ge""o-ai ;c"'" ~.... "'~C'l'+l'on to crOVt'c'l'ng a C'ea""
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~, .""",,',. -'1"\0 c~r;r;or"lr" ....~ . ""';s . ',7""'0 ("or e'or' -''''''<::11 Oeneratl'on I'S around
.~-~~.,/. .:......., ""':';.~-':'-..'-i ......1 ~..... ~i:-,""" "",1 :-....~. ....~ Q
. '--'-~'f 1"'0"''''0''''''' 7:"';S ~oar"s ~~at ,over"ty T"::.-cont C' t;""e coal's heat
... ;..... ~--. '-".... 1... ....."" J.~ .... "" -'-' ..... :,~1..., L.~
,:."0,=" j- ...:;:>,'~""; ,-"...,: i" :""", ~:""e O~'Y "1""0 Of f"'ss;l f'u'cl t'n<::llL'S used
''''''''''''''':::;I1.~ ..-..."""'...... vvG4........v\"..... .... '-lr-'v ..v 1......, t4
,""c::''''''c"",-:''''''' \Ac""'a"";:> r.asor;~o <::Ir"IC' C"e~cl f. ,01s L'n roday's i""ternal
,.,,"'~..""."".:.~.i' .1...1. ~.. I.... ~....... "'" ......."""'" ~~. ~ w..., 1"",.., .. u.
',:c::,,:ustiCrl er..gmes, suc:; as automobiles. ~:"'J.cks, tractors and trains
./or-' selc',......... -e~c"'" <::I eHl'c;e""cy 01" fcrt\: .,..,e"ccont
. -..1 .. "'-"........ c;.-...:. "" .o... 1 ... 1 /:-; ~ ....., .
~J",....' ?-'a's eV! -0""" co t c"""~cr<::lt' '-0 '/a-;..,.t icns Scocn t""'rouAh"ut a....
."~\J~ ........... ."".. ........:...~"'" """"'..~:-''"' ",",-'-4~" '" ,:,""'... ~. ,,""'.... ~.v \. J..
;:~~.~aL pe~:od, is ano~:-_er scurce cf clean energy. Water. cold weathe:-
..... ~ '....c ....e:""" t r_::.oz~r'O r'"'",,""rhs a~c' '"'ot. ',:)<'1: her l'n the latc sDr;"'O aT"\""
.......v \0", .vtT .... -- ...:;: ...Vjo--.... I -- .. \f"-,,,,-.. -... """". ".c .-'-'-
"'-"- """'~r ......",..... "s <::Iro!"'o '"''''SiC ..eso' ~-"'coS "ccoC'co" to C"e'-'tc m'-'SSl'Vo
.. _........."""~ .:._.'-"~ ...... ,~...., \,.~~" ..,(1 ~ ~ ,"",,4'-"" i :....,'" "'~ ~ '-L "" ~ ..."
:::'::':8t...:~tS d e~ergy in'expensiveLy, For l~e ~ast seve:-a1 years, r have
";f'\s,"....o"'; ~""Ic' ""'atCOr"lte,.; a U"'t'q' 'e ;,..;oh C'J-'C''-'O''''C"' enoi""'e a"'c' heat
......., .Q~ ~.......""" ~.... ~ '-'4..""""-- .. J. .... 1':'.C.1...,.. ~ -,:;...."t ... .Q-~ J. J. J. -""'
,""I"""""?~OI""O S.' S"e""'" T;""t"s sys'oro" ";O<:'Or"l ,.,,---, >he usaoe ot- aro""""cnta""-
".\"".';'-~"QI.:'.O . '- .':'':'.:'1 \.."..:.:.,-"",-~o~., ,.~....I.~.. Q J.,:"LJ.,~.... ".
..,._,......., P-",..;. 'I"'Cs a ell;",;onC"J OI' oiOh"y r--...c-""" A dC"""on C: "hl'S t'Y""o C~
... ~....,-., .. ""......''''';',-,- ii.4'Woi." ., ~.Q".'- :-"~. ~...i.. .-. ~~:. - J. I.. t-'''.
(;:".e:-gy syst.em, in conjunction with the ice storage units, WOUld
:Jrccuce extensive arr..cunts of water and 'energy cheaplY. The
~CL:c',ving text wiu give examples of how lhlS type of system can be
dsed in our slate,
-,
Citi:sand Towns
:)reS~r1t sewer and ,garbage disposal systems are abundanl supplies of
~!"..ergy needed to make t::"e system succe~sful. The heat energy
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, ':~edec fer :.:;e sys..em would ce cer:'.rec: :: )m warm 'ffBste wat.er L."1
::~~~:-..;: I sewer ~ls;;osal systems, and :.;:~ h!€.her temperature ~.ea'.
3~~;rce tr-..ar. can. 'ce supplIed by ether !nC~~ratli \g garbage or the
-: ''-''''''''0 01' met~~....o ~as ....~...,.;, 'coc' h., "', !.. "'r..,,,,o~" 1""11~....! ':: ""....,..,j 'al'~ 's . I...e
.'. . a...= . . .-.. V = :-'1.. ""'--""" '\,J -.J I \J\,..i.. ,..~ 'W. ~.c;;.- ....,.. """"""LI.... "'. I...
-"""''';O''''Sl'''g "'Oe"" r.e°";e"; to "''''''''''''''eto rl...o r.~"'o~O\Y C~'c'e of eperation
-.................... ., c;..r.~ ""II. . 'V"'-... '-"".".:-'1. \!,.v .~."" -.."'. c I. . ,
'.i""::-:r'.g the cOld weather months, Precessed water f:-cm the sewer
::~~t cu:-:ng tr..e celc weather operattor'.. ';1:11 be used in the lce storage
~. 'c::",:)""'" 7~.S ,.....,,.; -.r~'o", c:::U""''"'lY ;s ' . So"; "'<:' " r"'ndens''''o aoent C' 'r;""~
.:,;:~.......,..... .... "","""",,,,,- .,,,,,~,,. - ~~ - '- 'w"'~-(,.;......v.' "'. ...c = ~ ...c
"""Q "'....., -.'~-.:I!~o'- I"-.""o...i "'''''e~a'ie''' :' ........., """"/O"""''''''O..,IS cou'd r0'-"';zo
.... ....... . .....,.. ."' ",-,,,*,-. .....,. '-1"".--""'. "'~.. 1... J.., -""""~.. :: '"" ",. ................ . "'...... '"
.,,.;,.;.. ''''''''''-.:11 ''''''''''''''''''0 :..y c:::eI1;....o '~e v~s. ~~,... """S 0.. elecL'-.cl'ty ~,.,,.. -W~'cr-
' '........~."-......,,, .""'.. ~. .'-....;~.."'..., - "'....Q '-~. ~ ,-. ~.......,........ L 4.. (;4.1"'" c..;.........
:::-~c:...:cec ~'I t~...e s.~.s:"e~,
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/",::"".../ :.:_'(.J \001/
-:"Q '~/a,'~,.; 'Y"'C"; """;"''';''''''S ~:""'at a~o neT .:c:::c,..; in our staLe's forests is
...'-' _......,....., v \",8:". ,-""--",,,...... ... ... .. "".. . """-...,..... .... .
. '-'~o';e~'~"':Q Tl...e -''''''''''''0 e...,........"'~.... roas""""" .s tho W~sted wood
,-....-.....,l~ .,<;:.....,....." .... ~"...:-,."" .....""'~.'-'.....~...... ...., VL." '" c;..
_..",";, ,....' S ~ :~at a'-Q 1"'-=0-.:1' c"; f,-",!"", leOoi..,c ';~'..~ "'e~ thinnl'no and t-ees
.-. .....,....."""'''''. ..... ... "'" .... "''''''\.'''''- ... '-'.... cC-.,"'C' 1".............. ......1. .0' &.
,'~". ,.... :.....- '--:OC:::'---' '-0 n,....' ;.... ";0..,... ....,.; 'P"r.. Q""~ U'se f waste Woco' ~s
.. .~- ...s",,-..~ ~",,-\..i.""'l a.. "" .."oJI.o. ~.. ,-...........~a..,,--,. . . ......5",.,. O. .
~... '~........o ""'{""er-c:::'''' :...~:..... :...eat I '-el'r C'~"eTj.-,,,s -l-""'e .nl'"h cost of homo
...,;: ~:'v.!..h..... ",," ~. ,- I.v :':"""''':J:'~ ... ""'.~ H ~..:.~;=, :'j. .. Q _w
~'c"!,~O C"'caro,..; ,''''e ";o-a""d :,..- t\...iS t-,'-'e 0: weed ""uirn;"'''
~._c:.......= ."" .."''- woo'. "'-""'",.....! ....,i ~l.;. 1:-'. W U1Q'
"r."., 'o"';""""""""'''y frl'- C'o~~ ;..,u,.........,,, Of '/00(; P"\'-f"IC'..lC's combt'n.ed '....i!~
. ".' a, ~"'''''.''.'''V''''''Q .\.1. ."'''''''.. w .. ~ ':'..0 . f ), :~!.. v. I.. # rr ......
':...,:) 1...'0"" ~":'''''er''1r'' Q"'O"-'./' S~,_. om C'~s'''''-' ',''''1 ~lr; C-oato a l~-oe C'o.....?.......;
'.... .'':'" ~-.;.o.:.. '-":..'-1 ''''''''1 .............~~, i::::H..'\,J.,.;.. ...... '0:'1 """'~.~ a." ..., ~L C ...,L.._........
, "'.. '.,' ~~,...; ~ ""'rI"; .....~-,.;. ....~ - _1:""'0 I. '''''';''''0'' :~"J, ,-~ ,: <:>I'-eady \...as t~o
,""- ,~e.s..._- tv"""",,,,,-~. .....---'""-""...~. ~....... "'''''''''''.~ItoJ''-. .........~:::>...r, '-I.. 1~, 1.......
C'o"". """"""0'-'1 ....e0";o"; t... "''-;''''g t~o ,.r~s'o,.; . .;.....,.; to ~ ---ill er a Cf"Inver-;o...'
~"""",""""'~.:--'.1.""~._~. ""~,,,--..........J..,1 ~i. ..~..., ,.,~ ..........- I,.....,,,,~ . <.. .,... .., ...~.'"'....
_.. r.. ....... '~e hur~'~o or" t~is ""-"'cuc' .~ . '.... ~ ~"'''oh off:cl'e"'cy ener"y
~;'..""."'-'1\...""" ...1.0 ... ~I." ......-..""...~_."..... ....~ 1..0
-, .-. Q"'" ',' .....,...... .......r. '"". -. '-.0- ..,jo .-.... . ',-,' ,'..,j r to .0 'n~a,..,t
:::.: ~I......... .....C":-'I..C,....... ~,..s ::. / ~I."..... ~,""S'5:' ;. '-'~J."" C. ea "an a 1..41.", ..
.: ....1' f"'" ! 1"" -; ", .. ,.:..,..; ,..;";.' ''''''''801 c S~ l'OW to the""'" ~o'-
S,-p:-, yo. c...eap e.e..... .c.-'t. ]CCS, a...;.o a.............." .a 01 H u ~..~....".
industry
~ ;.-icl./lturallndustry
_.
Fanning and ranching industries face a very urLfavorable growth
~ericd in Montana because of the increased demand for water by
agricultural, commerctal a.nd recreational groups. The state's present.
water pOlicy is unfavorable because added storage was not dev.elop to
!r'..sure a adequate supply of water for the growth of agriculture.
Ra.:ich anc farm incustries ar:-eady have e:1ough problems with
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. --"', '0"'" '''''serts !~w --',-es ""nd ;...;gh '''''''e''' '''''' ~""j,e ~he;'" ;...usi""ess
...... "W.....~. ~.. ..... '- I ~v ~. .--""" "" ... -~A ~ _....J L. .U.;'\ ...... ... w ~ "-
, ...........-....!"ta'c'e
\004~ .~. Y.t. 1.
;.... rr;,oblle unIt can be used for this type oi e:'..ergy production, The u:"..~~
~a~ ce ;noved from one lOcation to ar.cther- :or the tce and energy
..-....,..;! :cr 'on' Also 1'f t""e...e 1'S a maJ'or --atfl"'''''' '0"" W" h t""e e~e"'gy , '.......
:.. --........... J '-.... """ .. .... ...................,~ .- ...;. ... """.....
Co ~:::er-e:1t U:1it can be c~ought in to produce the energy while the
"-'o'''''al' '-''' .s :"'.:ung -e""al'ro...; T'ne ""ut"""""2o~ c~ "f"1't '&J'ould -eoul're
""';'.0:'';'. \.4....... ~.....,.... :.....,,~ v""". c;.l. ""'i.. ........~~..,.,. 1.."
. '0::.""/ '.,. 'c . '''''''e a-.c' e::""r' (-"m the C"'er2o'c- . ~ere'oy rele""sl'ng .~e
v........ l..~.", i..... ~. ~~v '-1.:. """~. J. ~ :.. ~ . ..... .. Q.. '-.o.""'"
""0"'-""'" rO-,..., ;...ef"' c', ,.;os . :...at af"'e rc,...' ,;-c,.; :,..,- .:...c far,"""i""g ""nd
:-,,,,,..::....,:.~~ .. '"'~.."'''' ~~.'" .~~~ . ""'~........--.....~"'~ I......., 11..u.l (;4.
-..,.....,,:....,....~ ""''''''e'''~~ ,....... ,.., ,./,.;., .o"'a' "as:'" (!C.., :-""'m t;...e sale of e'cctrl'cl'+"
. ~..'-..._..~ "'::' . c...............;... .:-...............;.. ,~ """ 1~ j,. n ... ,",,1~ .. 4.'" '-'I
:..".........:...""......i.......,.:,.;......-,._=;,:... " ~ r'r~'':"s'ys'emo'ur'''''ohioh .
..v......'V....~...,.vv...._.........~""".;..........e~sasec .......; .;'. U~CI "g"'
"'::>-'''''c's''''f --,::>",,,,,,:'~!i.,..,!,,, ',... !!"'",-ca"e t:..,c ,,''''~r..- .a;"'lo of the stare's
--..-...J 'w. -. -'-.w...~............ ......, ...."". '" - ..."-' ffc;,.;.,..w. Iw faJ!...., -
a ...
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('[//ity - Puclic imd Privote
"'''0 "/-:'S~ """"""""""'0"; """'~'!"'al"'Qsour,..o"f 1.1"!"t"',..,.,,s heatandcOldt's
.. . .- "".. --......... """"''-- ."'..... . ..""_.'-"0.1. . 'W ,-"", "'. 1/..",.. :...."".....-
~'..............,.... ''''''''''''''''s-;'""o L'" ,,;=s"'-';...e,.; '1.:e r-a'/c &"'''0''; 1'.... the past to utl'lt'ze
.........--.::H.. ~..~:-''''' ~L."".L'" u '-...... '-....., ......, VY L.. ...., lc...I.I."''- 1. ...
~:--:~s 2.~'..::'.~c::.:"..~ SGur'ce of energy, Public c::.l'1G private utilities of this
s:flLe. w~~h ~:-..e sys~em cesign. would be able Lo produce large blocks of
.'.,,..'-',, "-""'---""",,.,....~....:... '''/L '" ,--''''''c tho e'Dy'ncrcas'-'~
:::.::;",.,;,,-20:::;";;;'51 ..--~.",~--...eSCL.... oO:...e. ~,-(:'\'....s, ......r L..... Lie
. ''''0 "~Sh f'"""" i~~ '" ,..,u:- S!at Q 7f ex"'c-t"'t'10!'" ,,; olo::.rL-l'Cal eneroy I'S
....- "".... ... ..v't, ..._v v. ... -'W... ~....'-'.... '-"'.. -."..- 1 C
. ~ Xo::.....; . ''''e a"';"';Q"; ,..."..........,.0 WOUIC' 'oenef,' . :"',S " "'L&:. _I ne sale of this
...t:. -....., l.... '-"'--......'- .1.:.,-",~~."" . . ~!t.. t..:..:... -\'c;,.ir.....,.. ~...
o::.-c,..-:;.,/ ~r '" :-Q";!'co::."'; -""c ,.71't;...in tnes~-:.to \,'1"\1110' 0ntice'ir'lO'Ustr-y t~"'.
""."".O~ ...._"'"".....,'--~ "......'-..." ff ...... .. ....""...., '''''''''-. - . "-"'-.. .. ~ ..c;......
,...........". ''''''''c 1-:'-"'0 "''''''''CU'''''S cf c'ort -1'C"" or.o...~" ....to th's state
"""""'.-'-"0;.1..:.""...<....=.......,-..... ~.. .....-........ c;...""'''.''''''''''o/.~':'.\,. ~.. ...."
/1/f7lng Industry
_.
Ml:1:ng conce:-ns have one of the best poterlL~alS for the system design
E:::ergy generation and ice storage will creaLe an abundant supply of
I~ex;:ensive electricity and water for mining, n'..s increase of demar:~
f-Jr llffie and phosphate £0r fertiliZer by the agricultural industry
',::\..:le reopen ole mines and create nev{ ones. C09per and aluminum
i:":dust~ies are also great benefactors, because of the large amounts of
c;pper-
-------
143
ENVIAO"'M~N . "I.
PROTECTION AGENCY
APR 2 8 1994
'AONTANA OFFiCe:-
7'34 locust
\ [issoula. \ lontana 59802
\pnl 15. 1994
Russ Forba. Remedial Proiect \Ianager
C.5. Environmental Protection .-\gency
301 South Park
Helena. \Iontana 50~26
Dear R1:iss Forba:
I am \\"nting to comment on EPA's and \IDHES's potential alternatives
and Proposed Plan tor addressing contaminated water in the ~(ine Flooding
Operable L"nit of the Silver Bow Creek/ Butte .-\rea Superfund site. I have a . .
number of questions on the Butte \[ine Flooding documents on this subject.
and some recommendations for ways that I. as a concerned member of the
community. would like to see the Butte \line Flooding documents and the
alternatives improved. .
Questions
_.
-First, why haven't EP.-\ and \IDHES prohibited the nearby mine
currently in operation trom dumping their waste\\'ater into the Berkeley Pit?
If this is a federal Superfund site, shouldn't polluters be prohibited from
increasing the contamination? The current mining operation is not only
aQQing to the contammation in the Berkeley Pit; it is also adding to the
surface water inflows to the Pit--inflows that might have been clean \\'ater but
have been degraded by the current mining operation. .-\ccording to the
Comprehensive Environmental Response, Compensation and Liability .-\ct of
1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), the aim of Superfund is to reduce
contamination. not to add to it. Why have none of EPA's alternatives
considered prohibiting the current mining operation from continuing the
practice of dumping their wastewater into the Pit?
-Secondly, has the issue of cumulative impacts in the Silver Bow
Creek/Butte ~line Flooding operable unit been considered with the RI, FS,
and Proposed Plan? .
1
.~
-------
. Thirdly, have the ..;\"nergi~tic t?ttt?cts Pt pollutants been considered with
,he RI. FS. and Propost?d Plan:
. Finaily. \\'h:' b It that the Propost?Q Plan only diverts Horseshoe Bend
~urtace ',\'dter inflo\\" <1\\"c1\' rwm the Pit? \\'h\' doesn't the Plan divert all eleem
, "
'.\'ater indo\\' trom the Pit: This \\"ould keep the Pit trom filling up as tast and
~c1\'e clt?an \\'att?r trom bein~ comaminatt?d.
Recommendations
.1 recommend that the \\'ritten quality of the public documents be
improved. to makt? them understandable to the public and to facilitate. rather
than discourage. public involvement.
. I recommend that EPA. and :'>.IDHES publicly acknowledge that the
assumption that no \\'ater is escaping out of the Pit is exactly that: an
,.~~lImption" It is based on theory. not f\'lct. I found the public documents to be
misleading on this point. making it seem as though the hydraulic gradient is
a known measurement.
. I recommend that some action be taken to, increase coniidence in the
direction of ground\\'ater t1o\\' at depth in the Butte :'>.Iine Flooding operable
unit. whether it be in deep \\"eU drilling. sediment testing, or improved
::':.onitoring from existing wells and mine shafts. If no action is taken to
accomplish this. I recommend that the C\ \"L be lowered for a greater margin
of safet\".
. I recommend that the Plan ultimately decided upon by EPA and
:'>.fDHES be flexible in addressing the possibility of groundwater
contamination at depth. and include a contingency plan if it is discovered that
contaminated water is leaking into regional groundwater flow. I recommend
that precautionary measures betaken to keep this from happening, to prevent
having to rely on emergency measures after it's too late.
.1 recommend that both the (Wis-for the Pit Svstem and the West
Camp System-be lo\\'ered. .~ccording to EPXs Proposed Plan. the SAID-foot
CWL for the Pit System is fifty feet below the alluvial aquifer. Fifty feet belo\\'
the alluvial aquifer doesn't seem to me like a sufficient measure of safety. If
Hoods andlor soil sloughing into the Berkeley Pit were to cause a sudden rise
in the Pit's water level. the water level could exceed the present CWL.
2
....,-:...
-------
. I recommend that all surface water inrlows--from streams,
precipitation. snowpack, etc.--be di\"erted from entering the Berkeley Pit. This
would prevent wasteful contamination of clean water and prevent the Pit
from filling as fJst as It is.
. I recommend that the current mining operation be prohibited from
dischargIng contaminated water trom their mining activities into the
Berkeley Pit S~'stem. nus current discharge is only adding to contamination
of a Superfund site that is on the :\ational Prionties list tor cleanup, which
c:eems to be in violation or the goals ot CERCLA.. .
Sincerely.
~
:\ Iarv E. :\'Iiller
:\.iissoula, ~Iontana
cc:
.\Iary Kay Craig, Cpper River Representative/
Clark Fork Pend Oreille Coalition
_.
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To: ,.. BiD Cinlan. President
Mo. AI Gore. Va Pres.aent
Sen. Max Baucus
Sen. ConrId Bums
Reo. Pat Wlbn8
MI. Carel BrcwnIr. EPA Adminisrall:r
Berkeley Pit Petition
\1r. sal Ye!towtait. EPA Reg. AdmirUhtar
Gov. ~c Racicot
Mo. JeM W.aei. EM MT air.
Mr. BoO RcbnCn. Dir. MT DHES
Mo. R\8 F~ EPA PrajlclMIJ
'C omttUUIity
kt:&~ is part of
$ufItrfruu! UdsUm-
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a&tD1/I.
lINE. THE UNDERSIGNED CIT1ZENS(S) OF BUm-SILVER BOW COUNTY. MONTANA. HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDUCE THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW.
I!WE DON'T WANT Bum TO HAVE 'MiAT WOULD PROBABLY BET HE LARGEST BODY OF. TOXIC
WATER IN THE WORLD. EPA'S PLAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MLL HARM OUR
SOCIAL AND ECONOMIC FUTURE. A FULL PIT POSES A PERPETUAL THREAT OF RElEASE OF
CONTAMINATION. IT PASseS OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
WORRY ABOUT FOREVER. . ~
RESPECTFULL . . "\ "
.. NAA4E ~~r
-------
P3
RUTH COONEY
C:JUNTRv ClUB MANOR 211
:lJT'TE. Mr. 59701~1
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lINE. THE UNDERSIGNED CmZENS(S) OF BUTTE.SILVER eow COUNTY. MONTANA. HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDUCE THE 'MTER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW .
IM£ DON'T WANT BUTTE TO HAVE 'MiAT 'M)ULD PROBABLY BET HE LARGEST BODY OF TOXIC
WATeR IN THE WORLD. EPA'S PLAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS Will HARM OUR
SOC/ALAND ECONOMIC FUTURE. A FULL PIT POSES A PERPETUAL THREAT OF RELEASE OF
CONTAMINATION. IT PASSES OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
'ItORRY ABOUT FOREVER. .
RESPEC~Y." .
NAME ~:1-;'~. L' I/O" Ii i
ACORESS " '9 Y e / w I, t11 J.".~ - t4 t:I'f. .2/1 ,
CfTYISTATEIZJP-B04.c/-~. Mf;..j;'iJl cWONE d'1"- 2.019
- - - - - - ~ ~-;.._, --;':cM-;';.;;';-~-:~ -~.:.: - -.;.;.;.:.;.;;,. - - - - - - - -
----------------------------._-----------~
Berkeley Pit Petition
Mr. Bal YeMowI8t. EPA Rtg.14I';'.... .C~
GCIv. P.Wc: Raacot Jot...... . ,..
Mr. John Wardell. EPA MT ~. ""..111 II "'-J
Mr. Bcb Roornsan.Oir. MT OHES $v.petfuNi tIIdIfmr,.
Mr. RUII FortIa. EPA PrajIQ.. ~ . ait:eI'iJI.
..
To: Mr. Bal C6nD't. P!eSident
Mr. AI Gor.. Va Presroent
I Sen. Max Bauc8
. Sen. Conr8cI Bums
. ~. Pat 'MIIIITII
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Berkeley Pit Petitio,..
&,1(. _.. ..o,OWIaII. c.?A Reg. ACIInIIIIIIrDIr 'COItrItIII1Iity
Gov. Marc Racicot t)l1"1"~-"-"'.'""
Mr. JolIn -dell. EPA MT Dr. ~--r--"'IS ptII't "') .
Mr. Bob Robinlan. Cit. MT CHES .sUf1Dfrm4 ~ .
Mr. Rust FcrDa. EPA ProjIc:I,. L. c::rHm&
io: Mr. enl CDnfIIn. President
Mr. AI Gen, Va President
Sen. MIX Bauaa
Sen. Conrad &ms
R~. Pat Willms
MI. Carel Btonr, EPA Admll1lS1ratOr
I/WE, THE UNDERSIGNED CITIZENS(S) OF BUTTE.SILVER eowCOUNTY, MONTANA, HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDUCe THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW .
I/WE DON'T WANT BUTTE TO HAVE WriAT 'M:)ULD PROBABLY BET HE LARGEST BODY OF TOXIC
WATER IN THE IMJRLD. EPA'S PLAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MLl HARM OUR
SOCIAL AND ECONOMIC FUTURE. A FUll PIT POSES A PERPETUAL THREAT OF RELEASE OF
CONTAMI~TlON. IT PASseS OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
. IMJRRY ABOUT FOREVER. .
:'~TPULLy. r!t- f/;;;. ),. .
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CnYlSTATEIZIP ~ ::- ~ .WlJNE 7.f1~"$'7S-
--------------------------------------------------------
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PAGE ,;
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Berkeley Pit Petition
Pres. Dill (/inlon
Virr l'rrs. AI (jure
SI'II. Ma~ JI;mrus
St'll ('(Inrad Jlurns
Rl'". 1'011 Williallls
Ms. rawl /frnwnrr, E!'A Adlllinisll'r
Mr. Bill Yellowlai., ErA Rrg. Adminislfillur
Guv, Marc Raricul
Mr. luhn Wardell. I:I'A MT I>in'rlur
Mr. 0011 Rohinson. Dirl'rlm MT UlII:S
Mr. Russ Forha. /:I' A l'rujt'c, Managl~r
l!We, Ihe Undersigned Citizen(s) of Montana, hereby petition the United States
Environmental Protection Agency to reduce the water level in the Berfceley Pit and clean it
up now.
l!We don'l wanl BUlle 10 have whal would probably be Ihe 'argest body o. 'oxic water in
Ihe world. EPA's plan to let the pit fill for the nex130 years will harm Bune's social and
economic future. A full pit poses a perpetual threat of release 01 contamination. "passes
ollr problems on 10 lulllre gelleralions 10 worry about forever.
nespecllully,
Name
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o Berkeley Pit Pet~t~o~- 0
ro: Mr. Bill cnnton~ President \11. Bill Ye!lowtarl. EPA Reg. Admirishlcr TIC
Mr. AI Gore. V1C8 President Gov. Marc Raac:ct taIU..: ,~
Sen. Max BaUQIS 0 \1r. Jon" Wardell. EPA MT Qir. . . ": ~'-P~ 0)
Sen. Conrad Burns Mr. Bob Robinson. Oir. MT OHES . '.su ~
R8\'. Pat Wiliams Mr. Russ FOlta. EPA Project Mgr. '. 0 ~c:..
Ms. ~ Browner, EPA Administaa 0 ",=' . . .
1fNE. THE UNDERSIGNED CIT1ZENS(S) OF BUTTE.SILVER eOWCOUNTY, MONTANA. HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, TO RED~Ce THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW 0
lINE DON'T WANT BUTTE TO HAVE 'MiAT 'AOULD PROBABLY BET HE LARGEST BODY OF TOXIC
WATER IN THE WORLD. EPA'S PLAN TO lET THE PIT Fill FOR THE NEXT 30 YEARS 'MLL HARM OUR
SOCIAL AND ECONOMIC FUTURE. A FULL PIT POSES A PERPETUAL THREAT OF RELEASE OF
CONTAMINATION. IT PASSES OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
'NORRY ABOUT FOREVER. .
RESPECTFUllY. ((I &11L1 ~
NAM~ 9-~ J.
ADDRESS ."'.J- J 0 V'; Ga.l e0 tL
CITYISTATClZJP.Bu.rf~ tilT .,-' 7CJ i PWONE 7;; 3 - 35lDcS-'
- - - - - - - -;>;;..-..;., -.;;.:a;.F.t.;;,;-~,;~~-..;.:-- ;-..;,;.;.:-- - - - - - - - -
---------------------------------
; .' :" /- . . - B.erkeley Pit Petitio~"' ~u
To: Mr. Bill CDnfI:In. President :.' . Mr. BiI YeIowt8J. EPA Reg. Admini*- PI aTE
Mr. AI Gor., Va PI8Iidtnt. Gov. MIre Racicot .;
Sen. Max Baucus ,.:, Mr. John Wardell. EPA MT Cir. . . : ~~ f.&put 01
Sen. ConrId Bwns " ' ,', : Mr. Bob Rotnon. Oir. MT CHES --su~ ~isUm-
Rep. PIt \WIIna . Mr. Rust Fort)a, EPA Project Mgr, ;;. 0tifH3f
Ml.c.at~.,EPA"Acm'.~"'. ..
1M£. THE UNDERSIGNED CmZENS(S) OF BUTTE.SILVER BOW COUNTY, MONTANA. HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDuCE THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW ' , .
lINE DONT WANT BUTTE TO HAVE 'MiAT II.OULD PROBABLY BET HE LARGEST BODY OF TOXIC
WATER IN THE 'NORLD. EPA'S PLAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MLL HARM OUR,
SOCIAL AND ECONOMIC FUTURE. A FULL PIT POSES A PERPETUAL THREAT OF RaeASE OF
CONTAMINATION. IT PASSES OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
'AORRY ABOUT FOREVER. . .'
RESPECTFUllY...i': .'. ~
NAME .' c:::J LV ~~-
ADDRESS .,-/ D . uJ. G 4/ P ,.).4
, . CITYISTATCIZIP Bu"""-~ At.,... 5970 I 9WONE 7.'3 - I j"(::)3
--------------------------.-----------------------------
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Ar..i - A \994 !!~ (:7,1. 3~/ 5: ~
'ON i."';' ;;, OFFI,..!!t:c,t:::;t/4r /)11:- S7~~(o
. Berkeley Pit Petition
~. BilYeIowtIil EFI'Rlg.Acilili_. 'C~
Gov. ~c Rac:ic:ct . 17J_-...II9U'r' . of
~. John w.dII. EM tIT Cir. ~l'--. U ptUt
~. Bob RobiIIan, Cir. tIT CHES saperfasul tI.tdsiDn-
Mr. Rust Fon.. EPA ProjIct t.9 ~ . aitD'i4.
To: !.t. BI CInIan. P!IIidIfi
rk. AI Gen. Va President
Sen. ,. 8IucuI
Sen. Comd 8I.mI
_. Pat WIIIImI
MI. c.a er... EPA AdmiIistratIr
lINE. THE UNDERSIGNED CITIZENS(S) OF BUTTE.SILVER BOW COUNTY. MONTANA. HEREBY
~ETTTION:THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDUCE THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW
WIE DON'T WANT BUTTE TO HAVE 'MiAT\\OULD PROBABLY BE HE LARGEST BODY OF TOXIC
'MTER IN THE \\ORLD. EPA'S PlAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MLL HARM OUR
SOCIAL AND ECONOMIC FUTURE. A FULL PIT POSES A PERPETUAL THREAT OF RELEASE OF
CONTAMINATION. IT PASSES OUR PROBLEIIS~. TO OUR:OSANO ~RE GENERATIONS TO
. RESP!fTFULLy' . ~
; CI'6~" ICQE ~ ~.
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P8
Let's tell EPA...
. Clean Up The Berkeley Pit Now!
AtiIr ...at_. E~ and NlCO ...10 11.1 011 *"ng Some Community Concerts...
a..., PI-1IIIIItIIr 30 ytn. ay 1h8n.1III 2S bdian '1Ie EPA-A~CO Clian: .
gdanl d DC" now n l1li 011 \WIlla... rnn II1an ClOUIIIId to . c:relttS I DtrIIttull "tIIrllt" of rete&le of c:cntammation:
i 58 billion..... The.... IrII WI! CIOVIr II8IrIY 500 1CrII. : :.asses aft an unt8SOlV8cl OllIS ana eyesore ID cu i
j' ';'hey WIIIII2 or.:'" SOIIII nllow I\OW so ~ tU8ll111 2.022 btbe :::IJdren ancI hlirs. forewr I
!lie 011II1IIl1li CJ1II:I( level. 5.410 f8ll "'trt It can Illy . incr..... contamination: doubles !DxlC Dit waitt I
fenwr. ';0IU1T18 D81are any I' IIU/TII8CI ana ~"IIIG /'
, retlrdllCOnonlC growII: histone uncIerground
E?A and A~CO say !lie.., wan1 ;a.,. ttIe pit. but III8y 'esouTc:es became inacceaiblt: prcoeny vaI- may
'l\IOII1 gJW ..... 1SSUrIIICI. :ec:raae: acl/ity 10 athct new ~ maybe
Your Opilion Countsl Here', willi you '!tard8d: well remctiora may stIut OUt new II'ICUtriII !
"CAN Delft :':at use 1119" YOIIITIII of - i
: . SEND THE PETmON BaOW TODAY . maICI8 far a IlIIoivabtl citr brings PGt8nIII for same ,
I 2. .WRITE, ~ ~Pit ~~-!f ~~I.29.:. 19!U 10 Net basements: wornes c:ctrIITUVly acout poI8ntiaI .
. w'",F:.:oi. ;".w. -""... - ,-arK. eanhQuaIcIirroactl
neltnl.. MT 59628 , "!1ay cause "'nil. delays 0' do8ItrIIIIt dunu..:
;. SPEAJ( UP. Get yOur oral ccmrrlellts !or feat of rec:ontamnalion. some pro- night not be
rec:ordId. Apn/26. 7.00 ~.m.. '.1ontana Tech aodres88a unal a1IIIr lilt remedy is in place
Auditcrilnl. . "81 unrtICMQ t8CIuIic:aJ PtOOIImI: no ICtI8ca8 far
4. CALL ~ elld8d oty. stale ana federal building & I8Iting a W8t8r Ir881rNnt plant ~ ~
represenlilives. .NeSt ~ pollutants b8fort di8c:harge to ~
MntUaIy uses Ihousands oIlICr8I far lIudgllandIII, fit
Clip AIId Mail NOWI To: Mary Kay Cllig. If sludge gotI bIc:X in 118 J)It. t8Ir8ItIlhI --
P.o. 8014718. Butte. MT 59702IPIIOIII 723~1) conumnama OWl and cyw rorw..
--------------------------------------------------------
Berkeley Pit Petition
Mr. Bil YeIcwt8I. EPA Reg. ktniniRatr
Gov. M8e Radc:ct
Mr. ..10M WItdeI. EPA MT Dir.
Mr. BoO Robinscn. Oir, PdT DHES
Mr. Russ Forba, EPA Projecr Moo
To: Ptt. Sill ClID!, President
Mr. AI Gore. Va President.
Sen. MIl Bauaa
Sen. Comd BInIS
Rip. Pat VWI8Ta
Ms. C.nIBroMw, EPA Adm.~lIIatlr
lINE. THE UNDERSIGNED CITIZENS/S) OF BUTTE.SILVER BOW COUNTY. MONTANA, HEREBY
PETITION THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO REDUCE THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW
lINE DON'T WANT BUTTE TO HAve 'MfAT 'w~UL::: ~CI'::;:.aL y aE i-:E LARGEST BODY OF TOXIC
'.'~TER IN THE IM:)RLO. EPA'S PLAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MJ4. HARM OUR
SOCIAL AND ECONOMIC FUTURE. A FUll. PIT POSES A PERPETUAL THREAT OF RELEASE OF
CONTAMINATION. IT PASSES OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
::~ ..; RESPEC;:~Y. /,?(t n'/~ ,/~~ .
J"'tal! ' . ~ I1d. tT ~ .)./
~ ;e.~.. , :TEIZJP I ~. ;{ PHONE'" -" ~ «/",.....
-~------------------------------------------------------
. (II8f.,--, """...o.a",.""GoIt~.....-- ''''''''J ''''''--_1
'COI1rItUU&#y
~ptQ1IU.. is pllrt 01
Supcfutul UiWm.
-------
_.
P9
I Let's teU EPA...
! ,~!~!~ ..~p_T~~Berke~l!~t~~!
. , :eI1tetl¥ Pit .. anan. 30 yeItS. Bv 1nen. tt1125 bIIion The EPA-ARCO plan:
. ~UCns 01 tr:IxIC SCUD nGilln ttII OIl Wilt naw ",..1IIIn aOlllllld III ' cru181118111t1llli "!IImr of reI8IIt of ..oI,IM\iIIIticI.;
56 billioll g81aa8. The lUrlIc8.ar.. MI CIMr II8IY 500 ICI'8. it ~ off an IIV8ICIMCI c:riIi8 n ~ II» ow
They WIIUICI OMIt Sll'lll1IfIaw now. so ~ 1lal1iI2.022 :'1118 C2iIchn nI theirs. fInwr
the 011 11..1118 'a1IICII" 18'111.5."0'''' WIInlt QllIIIy , i~ coallmilll..: dcUIII8 Dcic!lit.. .
fort... '/Ck1'n8 DIb8 rnt illUI'IIId n h8IId
. EPA ana AIICO Sly tile Willer wen t IeiM ttII pIt...but !hey , "... tCOItoaic grGIIII: hiltiClliC ~
'8IOUfC8S b8ccm8 rnacc8lllbI8: prqIIfty vaI..- !MY
won t gN8 aI8IU8 illlll'ance. QIICIUII; aciIity to athI:t nN ~ mayD8
I . (our Opinion CounlSl Here'S IItIlt ,011 retaraId: WIll rlllridior8 may ftII out nN inci8triI8
I - "CAN DOl" !hat use n9I YCIIIINI ohll8-
1. SEND THE PETTTION BELOW TODAY , ",... fer . ....... City: bringI-- far ICIm8
2. WRITE you Pit OpIt'IIon rJy ADIII 29. , 994 10 .. ~.n7*,1I; warn. ccmnuity IDout ....
~r. RUD Forba. U.S. EPA. 301 S. ParK, ~ ~
HtI8r8. MT 59828 , may CM8 ..rtII. dIII~...;
3. SPEAK UP! Get yoJI oral comments for fear of ~ nat.
reccrd8d . April 28. ;:00 p.m., Monllnl Teen acIdr8IIId unilftlr."8RiWl!I8u .
Auditonlll'l , hallInICMd ...iclllII8IIIM:""'''' fer
":~.::.-acity,stateandf8d8r;i '=~r-
'MfIIUIIyU811a181d1 d ICI8I far"'" ar
if sIudgI PI bide is.. pit. ,.... ..-
CIOIIIIII'In8It fNfIlnd fNfI a...
Clip AId Mail NOWI To: MIry Kay Craig,
P.o. Boa .718, Butte. MT 59702 (PIIOM ~)
--------------------.-.---------------------------------
Berkeley Pit Petition
Mo. Bill YIIowtaiI, EPA Reg. Admi. ~......
Gov. Marc Racicot .
Mr. JoI'II 'Nardltl. EPA MTDir.
Mo. Bob Robinson. Qir. MY OHES
~. Ru8 Forba. EPA PIOjId M!J
To: Mr. Bill ClnIan. President
Mr. AI Gen. Va PresIdent
Sen. MIX 8aucus
Sen. CorncIBwns
Rep. Pat 'M11ImI
/&Cn Brwnr, EPA Admi~-
"Canrmunity
~pttmUM is part of
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IN/E, THE UNDERSIGNED CITIZENS(S) OF BUTTE.SILVER BOW COUNTY, MONTANA. HEREBY
PETITION THE UNITED STATES ENViRONMENTAL PROTECTION AGENCY TO REDUCE THE WATER
LEVEL IN THE BERKELEY PIT AND CLEAN IT UP NOW
~ DON'T WANT BUTTE TO HAVE 'MiAT Y.OUlD PROBABLY BET HE LARGEST BODY OF TOXIC
WATER let 'AORLQ. EPA'S PlAN TO LET THE PIT FILL FOR THE NEXT 30 YEARS 'MLL. HARM OUR
. '. MIC FUTURE. A FULL. PIT POSES A PERPETUAL THREAT OF RELEASE OF
.T PASSES OUR PROBLEMS ON TO OUR KIDS AND FUTURE GENERATIONS TO
~~R . .
. '0:' RESPECTFULLY. .
NAMe.....rJ R,... ,;,p /J1 ~ .,. T" ,., .
ADDRESS 53" £cI.; J~
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PAGE 6
Berkeley Pit Petition
Pres. Bill Clintun
Vice Pres. AI (jure
Sen. Max Uaucus
Sen. Conrad Burns
Rep. Pat Williams
Ms. Caml Browner, EI'A A.llI1inislcr
TII:
MI, Bill Yclluwlail, I:I'A Rq;. A,h\lilll,lrallll
(;UV. Marc Kacicul
Mr. Juhn Wardell, I:I'A MT Bin'dlll
Mr. lIuh Ruhinson. Uilel'llIr MT BIII:S
Mr. Kuss huha, EI'A "ujel"1 M,III;I~I'I
ENVIRONMt:N r AI
PHOTECTION AUENCY
NA Y 0 .5 1994
lIWe, the Undersigned Citizen{s) 01 Monlana, hereby pelilion Ihe Uniled Siaies MONT ANA OFflCF
Environmental Protection Agency to reduce the water tevel in the Berkeley Pil and dean il
up now.
l!We don't want Bulle 10 have what would probably be Ihe largest body of loxic waler ill
the world. EPA's plan to letlhe pit fill for Ihe next 30 years will harm Bulle's social and
economic future. A full pit poses a perpelualthreat of release of contamination. II passes
our problems on to future generations to worry about forever.
Respectfully,
Name
Address
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I'res. Rill Clinton Mr. Rill Yellnwlail, ErA ReI!. Administrator
Vice "rs. At Gore (jOY. Marc Racicot
M MT I . ENVIRONMtNI Al
Sr.n. Max Raucus r. John Wardell, ErA ),rector' PROTECTION AOENC
Sr.n. ('n"rad Burns Mr. Roh Rohinson, Direclor MT DilES", Y
Rrf'. I'at Williams Mr. Russ Furha, ErA l'rnjrci Manal!er AY 0 4 1994
Ms. Carlll Rrowner, ErA Administt'r "'fONTANA OFFICE
IlWe. Ihe Undersigned Citizen(s) of Monlana. hereby pelition Ihe United States
Environmental Protection Agency to reduce Ihe water level in the Berkeley Pit and clean It
up now.
l!We don't w;mt Butte to have what would probably be the largest body of toxic water in
the world. EPA's plan to let the pit fill for the next 30 years will harm Butte's social and
economic luture. A full pit poses a perpelual threat of release of contamination. It passes
our problems on to future generations 10 worry about lorever.
Resflectfully,
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PAGE 6
Berkeley Pit Petition
Tn:
I"rs. Bill Clinlnn
Vier l'frs. /\1 (jurr
Sen. Mall n:lUCUS
Sl'n. ('mlnlll Burns
Rl'p. I'al Williams
Ms. ('allllllrllwnl'r, H'/\ Administrr
Mr. Bill Yellnwl.1il, Er/\ Rr~. i\lIministmlur
(jov. Marc Racicot
Mr. John Wardell, Er/\ MT Direcll1r
Mr. Doh Rohinson, Director MT HilES
Mr. Russ fmha, H'/\ I'wjeel M"n"l!l'r
------
ENVIROt4...d" A,-
PROTECTION AGEM;Y
MAY 0 4 1994
MONT ANA OFFICE
I/We. the Undersigned Citizen(s) 01 Montana. hereby petition the United States
EnvilOnrncntai Prolection Agcncy to reduce Ihe water level in the Berkeley Pil and dean it
up now.
I~e d~n't want Butte to h~ve ~hat would probablt be the largest body 01 toxic water in
the worldl EPA's plan to IPot the pit liUlor the next 30 years will. harm nulle's social and
ecoiiomlc lulure. A lull pit poses a perpetual threat 01 release 01 contamination. It passes
olJr problems on to hlture qenerations to worry about lorever.
Respectfully,
Namc
J\ddrc5s
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THE
Clark Fork
PendOreille
COALITICW
P.O. Box 7593
Missoula. MT 59807
4061542.0539
P.O. Box 4718
Butte. MT 59702
40&723-4061
PO. 60x 1096
SanC:DQlnt. ID 83864
2081263-0347
REQUEST TO EXTEND COMMENT PERIOD
t.t. Rues F crb8. Projed Manager
U.S.E.PA.
301 So. Ptn. cnwer 10096
Hetena. MT 59626
Feb18y 10. 1994
Re: Public Comment fa' Butte Mine Floodnq ODnble Unit
Dell' Russ:
This is fa'maI r~est fer extension of the Public Comm8'lt period fel' the
Bune Mine Floccing O/U. At least an adcttianat 4S . wilbe neeaJ8.. '/ fer
!he ct..nmunny to become famJii.. wnn the mmen.. to - ~ 81d
- weigl technological. ana futile ecanonvc: and social implications ~
remeciation at this O/U.
The Coalition is vfS'/ concerned the puDIic be ~ ~e appcnnty
to adctess the E.PA remedy J:ropos8. It is cu undb."1
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JAMES E!..I..:!NB~
3115 F\.OfW. BlVO.
BUTTE. r.rr 58701
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151
Testimony f)n Prooosed pt.n. ~jne Flooding Ooerable Unit
Berkeley Pit 4/26/94
Submitted by: John W. Ray. 915 West 6alena St.. Butte. t1T 59701
The purcose of Superfund is to clean uo hazardous waste sites which
are a threat to human hea Ith S1d the environment. Remedies under
Superfund should provide a oermanent cleanup remedy not temporary
containment or simply removal to another site, Simply, cleanup is the
"act of cleaning up; and the term t:!ean mear': "~ure.free from t.;r~,
contamination. impurities," According to the EPA publication entitled
Sucerfund: Environmental Pro9ress the purpose of Superfund is to achieve
"long-term cleanup goals for sites" and to remove "contamination from the
environment." (p. 1) The document further states that "the law directs EPA
to protect public health by meeting strict cleanup standards at e8ch site,"
and "Reduced to its environmental essence, the New Superfund mission is
'make sites safe. make sites clean, and bring new technology to bear 0;'
the problem." (p, 3) According to the Superfund law, any remedy for the
Pit should be a cleanup remedy.
If one examines the major Superfund laws and regulations,
CERClA. SARA. and the NCP, one finds that they All emphasize:
1 . Cleanuo as the primary goal of any Superfund activity.
2. The reduction of toxicity- volume. and mobility of hazardous
substances. pollutants. and contaminants at a site.
3. Permanent cleanup remedies. Senator George Mitchell
CD-Maine) has argued that permanent treatment means that EPA
cleanup plans must result in a permanent and major reduction in
the toxicity. volume. and mobility of hazardous substances.
pollutants. and contaminants at a site and that this reduction
must be to the -lowest levels achievable: He stated: -In addition
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2
.this context means the minimization of volume. toxicity and
mobility of such substances to the lowest levels 8chievable
with available technologies.- 132 Congo Rec. S. 14914 (daily ed. Oct. 3.
1986) .
4. Discourage EPA from simoly moving waste from one spot to
another. For example. is this what will be done with the sludge
which will result from treating Pit water?
5. CG1 is nsn the major factor. Cost is secondary to protecting
human health and the environment. Under Superfund. human
health must be protected from potential threats regardless of
cost.
Any solution to the oroblem of the Berkeley Pit must emDh8size
the above criteria. It is in light of the above five criteria that
the solution to the.'oroblem of the Berkeley Pit must be judged.
_.
In I ight of the above criteria, should we be comfortable with a proposed
'plan which would allow the volume of toxic/contaminated water in the
Pit to more than double before anything is done? (From 25 billion gallons
to 56 bi lIion gallons) Should we be comfortable with a proposed plan
. .
which leaves a Berkeley Pitfi1led with toxic water to exist and be treated
in perpetuity? This proposed plan would allow a surface area of
contamination of 487 acres. Is this a cleanup reme.dy? 15 this a remedy
which reduces the toxicity, mobility, and volume of hazardous waste? Is
this a permanent remedy or a remedy which will leave us with a p'erpetual
environmental crisis?
Unfortunately, past Superfund efforts have not mel these goals of
permanent cleanup. The Office of Technology Assessment (OT A) has
.concluded that Superfunc'remalns largely ineffective and inefficient: and
-------
-..-~-..':'" ~~: ::~ ~~~~~ :~::~~~ ::r rsmec', .cchnologies which wouid not
reduce the "toxicity. mobil ity or volume" of the the hazardous waste. All
too often Superfund has settled for remedies short of cleanup. Given the
serious nature of the contaminants in the Berkeley Pit. we cannot allow
any remedy short of c~eanup. We must ciean up the prOblem so that future
generations don't have to. deal with it.
Scecific comments on EPA oroco:ed clan:
1. Needs to "have a stronger emphasis on eventual permanent cleanup.
2. Needs to express in unequivocal terms that appropriate/new
technologies will be used. as they become available. in the cleanup of the
Berkeley Pit. The proposed plan's call for the use of innovative
technologies is too vague. This vagueness is particularly true with the
problem of sludge disposal. Either putting the sludge in the Pit or creating
a new tailings dump will have serious. potentially harmful effects on both
human health and the environment. The goal should be to keep the
production of sludge to a minimum.
3. Since so much of the proposed plan is based on predictive models. the
plan must clearly provide a def;ni te safety factor, Human error of
calculation or operation must not produce an environmental. catastrophe.
4, The cost factor needs careful consideration. There are two ways of
calculating cost: (1) What is the cheapest plan of action or (2) What are
the goals we are trying to achieve and. after the goals have been
established. what is the most cost effective way of achieving those goals.
According to Superfund. we are not looking for the cheapest remedy but,
once we have decided on the plan we want to implement to protect human
health and the environment in a permanent way by reducing the toxicity.
mobility, and volume of hazardous contamination, what is the mast
cast effective way ta accamDlish that Dlan. Under Superfund, cost
3
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does not determine which plan is accepted or the end resull desired of a
c:eanup plan. the cle~mup plan and its end result. which should be
protecting health. determines cost. Senator John H. Chafee (R-RD has
commented on Superfund's consideration of cost: "The extent to which a
_.
particular technology or solution is feasible or practicable is not a
function of cost. A determination that a particular solution is n9t
practicable because it is ~oo expensive would be unlawful.~ 132 Congo Rec.
S. 14925 (~aily ed: Oct. 3. 1986) In devising a remedy for the Pit we
must not select the cheapest solution but the solution which
will maximize the protection of human health and the
environment. We must select a cleanup solution.
5. The solution to the Pit problem must show sensitivity to public input.
As process. democracy demands that the public participate in the
formulation and execution of publ ic po licy. This is. particularl y true in lhe
case of agency rulemaking. as exemplified by the decision making
processes associated with the Berke'ley Pit. Such rulemaking is inherently
undemocratic because the people making the rules were not elected by the
people and are only very indirectly accountable to the people. Rulemaking
is only legitimate in a democracy if the public has ample opportunities for
meaningful participation in the decision maki'ng process. Meaningful
DarticiDation means that the DubUc really has an efficacious
imDact an lbe conW1..tLSuDerfund decisions.
It is contrary tl) democra~ic practice to seek to substitute the opinions'
of a few so called experts for public decision making. The best
environmental policy outcomes are achieved through public discussion and
debate. The reason is that the answers to most environmental policy
Questions. as to most public policy Questions in general. cannot be .
determined with the exactitude of a mathematical or scientific theorem
or law. Rather. the answers to public policy Questions exist in the realm
4
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5
of t~e cr0080Je or contingent. Given the complexity of society t,lnd the
complicated nt,lture of most environmental issues. no one individual. not
even a scientific expert. knows with absolute certainly what is the best
public policy. (Of course. there are numerous examples of where the
experts were just plain wrong,) 8ecause of this contingency and
complexity, the best environmental polic,! answers are found through
public discussion and by having the so-called expert submit his or her
conclusions to critical publ ic scrutiny and approval. The pub! ic has a right
and a duty to subject the opinions of so-called experts to intense
cn ticism. if an atlempt j s made to substitute completely the opinions of
the technical person for the opinions of the public. neither. the public
interest nor the demands of good policy making are served. The final Pit
decision must clearly demonstrate and show how public input was
efficacious in influencing the final decision of the EPA.
John W~ Ray 915 West 6.len. St.
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6
John W. Ray
Additional Questions about the Procosed P1an-Mine Flooding Ocerable Unit:
1. Superfund calls for the cleanup of hazardous waste sites. The Pit is
certainly a hazaraous waste site. Does the proposed plan really call for a
cieanup of the Pit. !s this a cleanup solution when it leaves in place a lake
of :cison? 15 this a cleanup solution when it leaves Butte in a state of
perpetual environmental crisis?
2. The Butt~ Hill of which the Berkeley Pit is a part is very complex. Do we
really know what is going on? Are we relying excessively on models and
predictions which could be found to be inadequate?
3. The proposed cleanup plan sets a bad precedent. It writes off the
bedrock aquifer as permanently contaminated. No attempt is made to deal
with this significant contaminated area.
4. Will the contaminated bedrock aquifer limit Butte's future growth by
limiting water supplies.
5. Will the proposed plan .end mining in Butte?
6. What if the EPA/DHES predictions are faulty. Can remedial action be
undertaken Quickly enough to avert an environmental disaster?
7. What would be the effect of an earthquake on the tailings pond and on
the Pit? Will the water treatment plant be so constructed so as to survive
a major earthquake?
8. What is the effect of pit contamination on the outer part of the camp?
i
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152
!
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ft
o EPA
Region VIII
Montana Office
Superfund Program
Silver Bow Creek/Butte Area Site ~(\,.c-. '. ",
Butte and Walkerville, Montana MAR 2 9 1994
'3/"1'~
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Dr. Robert G. Robins
25 Adelaide A venue
Lindfield. NSW 2070
AUSTRALIA
Fax/Phone: (nt+ 61-24163928
25 February 1994
Mr. Russ Forba
Remedial Project Manager
U.S. Environmental Protection Agency
. 301 Soutolt Park '
Helena. MT 59626
U.S.A.
eNVIRONMENTAL.
.QOTECTION AGENC'
MAR - 2 1994
40NTANA OFFlr
Dear Mr. Forba,
COMMENT' PrOJ)Osed Plan Mine Floodini Qperable Unit
Berlceley Pit Butte Montana
( am a retired academic, having been Foundation Head of die DepInmedt of MiDeraI
~ng and Extractive Metallurgy at the Univenity of New South Wales ill SydDey,
Australia until the ead of 1989. I visited Butte in 1979 at the iDvitaIioa of Ibe AD8COIIda
Company, aDd saw the Berteley Pit for die fin1 time (operatiDg). I baYe siDce visited Butte
on m:my occasioos - perhaps 20 times, have spent several sabbatical auat"lIIeIItS at MOIdIDa
J'ecb, aDd in 1993 spent ,9 montbs wofting with the Mine Waste Tedmology Pilot Project
team in Bune. I have also reviewed several Superfund documents for U.S. EPA'Region 8
(Ref: Mike Bishop). My field of expertise is in the genen.t area of aquaIic: cbemistty,
particularly related to the environmental impacts of mining and processing of minerals.
I bave read the Proposed Plan, Mine Flooding Operable Unit (Berkeley Pit) dated
January 1994, aod some of me associated documents, and would like to make severa!
commems on the proposals.
-,
FiJ:sdy let me say tbat I agree completely with the proposed introduction of a
-Comp.~ve MonitoriDg Program- wbich is a pan of most of the remedial alternatives. I
believe tbat Ibis monitoring sboukl have been in place before now, aDd should be weD
underway (with the interpretation of many results) before any major tteaaDent procedures are
established. This comment is made because of my belief that a complete understmding of the
present geocbemisay and hydrology of the Berkeley Pit System is not at band~ and that a
better UDdersranding could influence tteatmeDt options. I bave seen the results of a little of,
me moaitoring wort being conducted by the Montana Bureau of Mines aDd Geology
(MBMG: 1991-1993) and the Atlantic Richfield Company (ARCO: 1992) and the work
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;
An important aspect of pit-system chemistry relates to the reactions that are occurring
in the sediment that IS fanning on the pit bottom. submerged benches, and previously
connected old underground mine workings. The sediment thickness at the pit bottom (1993)
was said to be possibly 200 ft. The sediment generally will almOSt certainJy be becoming
sulfidjzed by a variety of chemicaj interactions. but there appears never to have been the
suggestion of an investigation of sediment in the Berkeley Pit. apan from my own in 1993.
A complete undel'SWlding of geochemistry in the Berkeley Pit needs information from
a sediment StUdy.
-.
Due to sediment sulfidation it is likely that an oxidation-reduction boundary has
already developed in Berkeley Pit sediment. near the sediment surface, so that the quality of
water on the reduction side of the boundary will differ from that in the pit itseJf; which wiU
be oxidized with respect to the H~/SOl. interface. An oxidation-reduction boundary could
separate die dissolved ionic species in the pit water from those in the underlying groundwater
(but aJlowing downflow. reduction and sulfidation) such that the lower grouudwater would be
of better quality due to the decreased solubility of metal ioIJs from a reduced sulfide
environment. The oxidation-reduction boundary is likely to have developed in the pit
sediment due to both the interaction of pore water with undertying sulfidic miDeraJs aDd .
solutions, and the likely microbiological reduction of sulfate to form sulfides. TIle former
process is similar to supergene enrichment in sulfide ore bodies where ~g solutioas
from' surface oxidation react with the lower levels of bypogene sulfidjc miDeraIisarioa to form
a region of enriched sulfides. Some ores which have been milled ecoaomic:a11y are aaributed
to this eurichmeDt process (this includes pan of the origiDaJ Butte orebody as described by
McClave: 1973). The propOsition of oxidation and supergeae earic:bmeat of sulfide ore bodies
sraned witb the wort of WbitDey: IM5, and by the 1960'$ the pe.~-_. of oxidized IDd
enric:bed ores was weU established. Accounts of the process have bee:a publDbed by ~:
1~, and ADderson: 19". More recent treatIDedU of the hydrology aad geoc~ of
these processes are pie5.aJted by BrimbaU et aJ: 1985, aDd BrimbaU aad Crear: 1987, and
some reWed cbem.isUy for tailings interactions was proposed by ROOiDs: 1992.
The likely mediation of sedimentary reactions by microorgaaisms depends to some
extent on the presence of orgillic c:aJboa. aJthough there are other energy Soun:es that suppon
the wide range of orgaDisms that are eDCOUDtered in the reduction of sulfate to sulfide. To
date it appears tbat DO aDaiysis of Berte1ey Pit wat&:r (or any other wata'S in tile OU) has
included the detaminatioa of organic carbon, aJthough it is likely to be present from various
sources, whicb iDclude a buge vegetated water C3t(hment (>, square miles) to the nortbin
which humic qJ~ are certainly being generated. AlgaJ blooms which occur regularly in
the wartr It die Norm of the YanJcee Doodle tailings are evidence of organic: material, whicb
in that regioa II least could support bioreduction of meta! iODS. RecycJe of contaminated
water to pan of this tailings area in order to form sulfides is wonb consideralioo. ID the pit
itself it has beeD said (without any evidence) that there is not likely to be any bioreduction
due to the -extmne- conditions in the water (acidity and metal ion concentrations). This is
not correct, and in similar mine waste pits, such as at Rum Jungle in AUSlralia, reducing
orgaaisms have been reponed at deep submerged sediment (Babij et aJ:1980)
The comprehensive monitoring prognm which is being proposed sbou.Id include a
sttong microbiological SbIdy.
-------
-..
~
. So, it is suggested here that the Berkeley Pit and surrounding areas could become
enveloped by a sulfidic bamer such that the underlying groundwater is in a reduced condition
where the metal ion concentrations will be considerably lower than in the pit water. There is
some evidence that this is the case (MBMG data, counesy Ted Duaime). In the West Camp
the Travona shaft water is sulfidic, and although the ground water at that location is more or
less cross-gradient to the Pit, it shows that the condition of reduced ground water does exist.
It also suggestS the use of West Camp water (or similar water) to sulfidise other waters in the
system. Water samples from the Belmont mine shaft, which is downgradient of the pit, show
metal ion concentrations considerably lower than in pit water; Water samples pumped from
the up-gradient Kelley Mine shaft (MBMG:I992) indicated that both pH and ~ decreased
with depth (pH: 5 to 3, and E..: 380 to 36OmV), which could mean that the Kelley is isola~
from the Pit by a redox (ox/red/ox) barrier. Cation concentrations in the Kelley appear to be
generally higher than in the pit, but this is probably due panly to enh2nced and locaJised .
oxidation caused by the more elevated temperates which exist in the deeper water levels.
There is Other evidence of sulfidatioo actuaUy occuring in the Pit : Lead weights used
to anchor a sampling platform in the Pit were noticed to be blackened on recovery (personal
. communication: J. Medish, MBMG). This was probably due to the presence of a coating of
PbS fonned by sulfidation; A copper bar lowered onto the pit ~imeot in September 1993
had a sulfide coating when recovered one month later (personaJ observations).
Another consideration is the influence of the OU groundwaters on deep groundwater,
and the fate of that water. A complete water balance on the wbole pit system is not reponed,
but could add perspective to understanding the likely outcome of allY cboseo remedW actioD.
For example, the maximum average mondLIy (JUDe) pI"edpi1aIioa of 2.42 iDcbe:s' in die
C8tC~DIeIII of the Pit system (about 19.5 square miles) could result ill the ~~ of ..
27 MGD of water (data from Botz: 1969), which would have beea acammodated (pre-
mining) by stt'eam flow, groundwater flow and ~. Preseady the ooIy
additional water into the system is 6.2 MOD of Silver Lake.water to the MR. c:oaceatrator. In
all months other than JUDe the precipitation is less man in JUDe by more tbaD the 6.2 MOD
from Silver l..ake. Actual measurementS of monthly ~vapottaDspiraI: would be more
accurate than using calcuJations such as in CFR 40 Cb.l (7-1-93). Up-gradient water control,
as in fact panly exists witb the Yankee Doodle tailings dam, sbouJd be carefully integrated
with recycle, to result in the appropriate water baJancc for conUlrrnnllf'ioa control.
The proposal to recycle Horseshoe Bend water to the Yankee Doodle Tailings is a
good start to water control, but it also presents the possibility of additional cbemical control.
There will be c:bemical (and biological) reactions between the recycle water' and the tailings
sedimatt, aad Ibis could lead to a positive outcome. AD investigation of tbese reactions
should be . pan of the Comprebensive Monitoring Program.
In the Proposed Plan there is the suggestion that there is an upflow of deep grouDCIwater from
the bedmclc ;~to the OU. Perhaps a groundwater model was the source of that idea, but I
wonder if it is realistic. There are simple experimema1 procedures that could be used here to
add to a realistic water balance.
I Butte stabOD, 30 yr average annual precipitation (1951-1981) wu 11.73 inches.
-------
A downflow of water over geologic time is evidenced by the Anaconda Company
maps (McClave: 1973. Figures K-I to K-3) showing the position of the zone ofsupergene
enrichment which lay in the volume that is now the Pit itself. and still exists in surrounding
areas . These diagrams show a downward extension of the enriched zone at faults and veins
(eg. to levels at an elevation of 3800 ft in the Middle Fault at the Kelley shaft), where there
would have been a downflow of surface water. A down flow of pit water (beneath the pit) will .
still be present and will be furthering the supergene enrichment process and carrying reduced
soluuons With lower metal ion concentrations to greater depths where enormous dilution will
occur with circulation to depths of 1-2', miles (BlackweD and Robenson:I973).
"Contamioated" water from the au may never influence surface ground waters.
My comments on the preceding pages lead to the following eight recommendatioos:
1. That a comprehensive monitoring program be quicldy set in place.
2. Thit a pit sediment StUdy be pan of the monitoring program.
3. Tbat a microbiological study be a pan of the monitoring program.
4. That Ulere be detailed considerations or geochemical and micrObiologic:aJ interactioos in
the pit system.
S. That an overall monthly water balance be used to assess both up;.gradient water comrol
and recycle possibilities.
6. That system-outtJow water quantities aDd paIIaDS be ~SOIj. witb some IDODibiag to
support any conclusions.
7. That in considering chemical treatment options, due consideratioa be given to recycle
of 8C011f2min:ilted8 waters as weD as the integration of waters from different sources.
8. That all of the above activities be supponed by an WlCn8advisory-and-review- panel
consisting of persons outside the commercial coDSUJtancy organizatioos.
Most of tbese retommendatioos relate to the proposed 8compreheasive monitoring program-
which, if carefuUy planned, could well lead to the fonnulatioD of a more cost~ffective
Strategy (embodying iD-situ immobilisation of contaminant metals) than for Alternative 6n.
~
I have DOt addressed the detail of the treabDeDt methods (chemistry) that are proposed
to be introduced at the time of suspension of mining. These methods are fairly standard and
reasonably well uoderstood~ However there is one aspect that is DOt understood at all, and
that relates to the interactions of treatment sludges with the enviroIImeot into whicb the
sludge is disposed, particularly if that was to be the pit itself. If treatment sludge was added
to the pit it would dramatic:aJly affect:the pit sediment and the reac:UODS occurring in the
~itnellt and surrounding groundwater'S and perbaps deep groundwater. These possibilities
should at least be considered, and preferably investigated in some detail in a pilot experiment
that could be carried out on site.
-------
-
The environmentaJ sitUation in the Berkeley Pit Operable Unit System offers a
tremendous opponunity fl)f ~ientific $tudy which should not be loSt. and which will cenainly
he useful to' others in futUre times and other places. There are presently similar sitUations
internationally. where detailed investigations have been in place for some years, but these do
not appear even to have been identified during the feasibility study, let alone taken as
example. In the near future other mine operators will need to deal with situations similar [0
those at the Berkeley Pit and a well documented activity will be appreciated. In the
. immediate future the WISMUT mines in Germany (especially the Ronneburg Pit) will
commence to flood and wIll take about 15 years to fill.
One funher suggestion that I would like to put forward is about funding of the
comprehensive monitoring program. I think that advanrage should be taken of sources otbel'
than EPA and ARCa. There are funding programs available through the National Science
Foundation. and others intemationaJly. where large grants are given for environmentaJ
projects. ~y; there IS at the present a caJl for submissions to a .. .~~JamatiOD and
Developnfent Grants Program" from the Montana Depanment and Conservation. EP A should
coordinate a grants application scheme witb the local institutions and otbers. My close
association with tbe Academics at MontaDa Tech, over more than ten years, makes me rea.Iise
!hat tbere is a great potential for more involvement in the au problems than at presem.
I will be in Butte from 5th March to 9th March 1994 and will atteDd the public
meeting to be held at Montana Tech on die evening of 8th March. I would enjoy ~g with
you or any of your colleagues during my stay. and in the meantime I could be contacted
through the Research Office at Montana Tech (406) 496 4102.
Yours sinc:crdy,
&&~~~u~ms
_.
Attachmeot: References to publications cited.
Inclusion: Paper on sulfide tailings.
-------
_.
. .
REFERENCES
MBMG. Unpublished data. 1991. 1992.
.\RCO. Unpub!::;heJ Jata. :992.
A. Davis and D. .\shenberg. .The Aqueous GeochemiStry of the' Berkeley Pit. Bune.
Montana. U.S.A' Applied Geochemistry. Vol. 4. pp. 23-36. 1989.
M. K. Bo12. .Hydrogeology of the Upper Silver Bow Creek Area. Montana..
MBMG Bulletin 75. September 1969.
M. McClave. . Control and distribution of supergene enrichment in the Berteley pit, Butte
district. Montana. in: Guidebook for the Butte Field Meeting, R.N.Miller, ed.,
Soc. Econ. Geologists, The Anaconda Company, 1973.
J. D. Whitney, .Remarks OD the changes which take place in the structure and composition
of mineral veins near the surface with particular reference to the East Tennessee Copper
Mines.,
A mer. J. Sei., Vol. 20, pp. 53-57, 1855.
A. M. Bateman, .Economic Mineral Deposits., 2Dd Ed., J. Wiley &: SoDs, 1950.
C. A. Andersoa, .Oxidation of Copper Sulfides and Secondary Sulfide Emic;hmem.,
Ecoa. Geol., pp. 324-340, 1955.
G. H. BrimbaU, et aJ., . Analysis of Supergeoe Ore-Forming Proces,tes and Ground-Water
Solute Traaspon Using Mass Ba.Iance Principles.,
Ecoa. Geol., Vol. 80(5), pp. 1227-1256, 1985.
G. H. Brimhall and D. A. Crear, . Orefluid: Magmatic to Supergene.. (Part UI),
in: Reviews of Minera1ogy, Vol. 17, pp. 235-321, 1987.
R. G. Robins, .Chemica1lnteractions in Sulfide Mineral Tailings.
Mineral Processing and Exttactive Metallurgy Review, Vol. 12, pp 1-17, 1993.
T. Babij, A. Goodman, A. M. Khalid and B. J. Ralpb, .Environmental Sbldies of Flooded
Opea Cuts., in: Biogeocl1emislry of Ancient and Modem Environments; Trudinger, WaJter,
and Ralph, Eds.. Aust. Acad. Sei., pp 637-649, 1980.
D. D. Blackwell and E. C. Robertson, .ThermaI Studies of the Boulder Batholith and
Vicinity, Montana., in: Guidebooldor the Butte Field Meeting, R.N.Miller, ed.,
Soc. EcoD. Geologists, The Anaconda Co., p 0-3, 1973.
6
-------
. '.f" , .. '.,,. ...."
.:. .." ~.-
. '-~~';..':.
'.' ~ ..~';.... " "~
. .'
\f,,,,ral Proc'JSI", lI"d !.zINCI/V' ."i"IU/wry R,v"... i99J. Vol. 12. pp. 1-17
RoC!lMnIS avaolable dlleCllv flom tile puOhsller
PhotOCOOYln, permUted by hcense only
C ;99J Gorcon ana Breach SCIence PUbhshers S.A.
Pnnled .n the L'Med Stales of Amenea
Chemical Interactions in Sulfide Mineral
Tailings*
ROBERT G. ROBINS
HyaroMet fecnnolog'es Lim/tea. 31-45 Sm/t" St,"t. "'.mdtvll/fl. NSW 2204. Ausrf.li.
nus paDer re"le~ lome of the "'I)rk Ihat has anemoted to Identify species which exm. or are formed.
,n
-------
rt. u. ROBINS
The Cniled Siaies Environmental Protection Agency has instituted a Resourte
C\)nservallon and Recovery Act i RCRA) with regulations to cover remedial action
to mlnlmise contamination irom both abandoned and operating mine and minerai
processing operalions. ~10re recently they have pubhshed draft rules which reQUire
the submIssIon of plans ior closure and post-closure care of mine Wastes pn~r to
~T1Ine development.
To obtain pre-development mine waste management plans. the geochemistry of
the syslem conlalnlng Ihe wasles musl be estimaled togelher wllh an assessment
vi \Juanllty and qualilY of the drainage in the system that is likely to be genera led
:,~ :ne waSles. Syslem mineralogy and hydrology are therefore imponanl sludies
to be undenaken In an overall assessment. .
This paper. however. will only deal with aspects of geochemical modeling which
can be related to a sulfide tailings system without considering the influences of
suriace and groundwater hydrology. other than the chemIstry of these walers. The
,jjfficullle~ in modelina such a svstem relate mostlv to Ihe lack of informallon on
tne cnemlcal species p.resent. a~d when kinetic daia are required. Ihe problem is
greally Increased. .
CHEMISTRY AND SPECIES IN SULFIDE TAIUNGS
The number of minerals present in sulfide tailings together with the many complex
ions that can exist make it impossible to cover the whole field of chemistry and
speciation in this shon paper. To enable an abbreviated discussion on the subject
only four elements will be considered here: namely copper. iron. sulfur and arsenic.
These four elements alone account for more than sixty minerals. of which the more
common are shown in Table I. Most of these: minerals have been identified in the
ores which are mined for copper production and many find their way into the
tailings from the processing of sw:b ores. Of c:ounc many other complex metal
TABLE I
The I:Iore common minerals in the Cu-Fe.As-S s~tem'.
. -. I :..
AsS
As,S,
Fe 5
Fe So..
Fe... S
Fe; S.
Fe S.:.:
Fe SO"
Fe S,
Fe 5;
realgar
orplmenl
Irotlite
macklnawlte
pyrrhoUles 191
gamma sulfide
smythlte
grel8lle
pynte
marcasite
(CII. Fel-5o
CIk Fe 5.
Cu. Fe 5...
CII.. Fe 5..
CII, Fe S.
CII Fe 5.
CII Fe. 5.
Clio Fe. 5..
C... Fe. S.
CII. AsS.
Cu. As 5.
C... ."'5. S.
Cu.; ....s 5.,
Cu As S .
disenlte
bomlte
1.bomlte
Idalte
fllkllCllilite .
chalcopyr1le
cubanlte
(several )
haycocklte .
luzonlte
enarglte
s,nnente
tennanUle
1~IIUle
Cu:S
Cu...5
Cu.. S
Cu... 5
Cu...5
Cu 5
chalcocite
djllrtelte
digenlte
antlile
b.r. coveUile
coveUile
Fe As S
-------
(HE~ICALI~TERACTlO~S IN Sl.:LFIDE TAILINGS
5ulfides are also found in such an ore deposIt. but these will not be considered
here.
The presence of water in most sulfide tailings disposal sires means that the s\'stem
under conSideration IS aqueous and so here rhe reierence IS the Cu-Fe-As-$-H.Q
system. A convenient and concise method for both interpreting and predicung the
c:Jmpie:< equliibna and likely reaction parhs that eXist to such aqueous systems 15
by (tie use oi vanous thermodynamiC: staDlht\' diagrams. The potential-pH lor PE-
pH) .:iagram is particularly useiul ana Figur~s I Jnl.i : show such l.ilagrams which
wlil be referrel.i to later. These diagrams can be easily generated by computer
pro\'lded the standard iree energies of formauon for all of the components to me
system are known. This last consideration IS a \'ery real problem for complex systems
as many of the species are still unknown let alone having been characterised bv
stability constants (or free energies of formation). Having obtained a pI-pH dia-
gram. the misinterpretation of the diagram is common.
Probablv the best elementarY text-book co\'erasze of stabilitv diaszrams for mineral
s\stems Is'stlil that authored by Garrels and Christ". The compliauon of ooEh-pH
Diagrams for G~ochemistry" in the book by Brookins. is more recent but many
errors lead to a general uncenainty about using his diagrams- Diagrams for very
complex systems can be derived and some of these have been published and are
invaluable as a general guide to the likely chemical conditions of tailings.
-~ '.0
Reactions in the Oxidized Zone in Sulfide railings
The generauon of acid in a sulfide tailings material is commonly attributed to the
oXidation of pyrite in the. presence of Water. oxygen. and naturally occurring bac-
tena such as Thiobacli/us ferrooJ:idanr. There is extensive literature on this process
but it relates moslly to acid generation in sulfidic coal spoils where the sulfide
mineral is predominantly pyrite FeS! and its dimorpb. marcasite. Numerous re-
action mechanisms have been proposed for the oxidation of pyrite and in general
the overall reactions are given by the following equations: .
(pH> 2) FeS, ... 7/20, ... H,O = FeZ- ... 2S0i- ... 2H-
(pH < 2) FeS, ... 7/20, ... H,O = Fe>- ... ZHSO,-
Fe;-'", 1/~ 0, ... H- = Fe-'- ... 1/2 H,O
Fe-'- .. :H,O = FeOOH ... 3H-
. but it is also proposed that the rirst reaction above is electrochemical where the
anodic oxidation of pyrite is coupled with the cathodic reduction of oxygen on the
pyrite surface. A detailed study of oxygen reduction at mineral sulfide surfaces'
indicated that pyrite together with copper sulfides and pentlandite (Fe.Ni).S, are
good catalysts for oxygen reduction which will occur at about ...O.~ volts (SHE)
in acid solutions (independently of pH). In the electrochemical model the half
reaction below pH = :! is given as:
Fe S, ... 8H:O = Fe:- - :HSO.- - lJHo - lJe-
with a theoretical potential in volts (SHE):
E = 0.35 - 0.0592 pH - .0085 log HSO.- - .0042 log Fe:'
-------
.,,:.. ..:.:...
, "
. .-.
~, G, ~OBINS
The generation of acid in tailings heaps is far more complex but studies based
on the electrochemical reacllons at pyrite surfaces are sull be 109 conducted in an
altempt to e:o
-------
III
Q -16
2
pH
'.
e
IRON-SULFUA-WATER (pE-pHI
T: 296.15
--
---t----~_.~-- --. t- --.-.-..t--
b'ft.Cll::~.
C\lNbo I OIoHtili
. ... ~ .. + +
2 .. t. Oli...
3 t-t (U.... ~..
4 .. t' (Otil ::I IAU)
~ 1'1:: (OIH ::I CSI
6 t:E~..
7 I'EOH.
B FE IOHI ;2 (AD)
9 FE COtil 3"-
10 Ft: (0... 2 151
II ""E (5)
12 foE IH~) 2 IAU)
13 f- E "i5) ::1-
14f-t:51SI
15 .. ES..! 151
1 b 115-
17 1125 IADI
113 504--
J9 5151
....(jll..1 I 1'''lcllllal (1'"II,II.h"II.aOl ,,,. Ihe Iy5lem fe.S.II,O wilh oullu. o,,,,de. .01 unll acllvlly a..d..".. O''''lICO .01 III . 'Ihe .""",o"III,,'.IC lell'''"'
..bc.c .....1..11"" ..,II .lCeUI, ...J Ihc .h..dcd a.ea where lulridc WonplUCk ..:oulIlII ouluholily.
6
FE..
4
2
FEIOHI3
o
-2
-4
-I:)
-- .
----'''''''''''':'~"...:. .
- J :: -.: :.....
SO:;/ttS
-.:....-
FES2
-8
-10
-12
FE
-14
3
5
e
9
10
1 1
7
8
4
(")
:r
..,
"
n
).
r
~
;II
>
g
o
z
VI
::l
VI
r:
r
:!]
o
..,
-i
»
;::
Z
Q
-------
I'
10
COPP~R-SULFUR-WA1~RlpE-PHI
T: 29B. 15
I
.. .-t------ --. ~. -.... - t
~.Pt. C 1 t -I
t:UN~IUt .H:tJ
+-----
----....-....-. --.. . - -
I ell'
d (:1' t .
"j ':"Utft
.. ClJ IU," .: CAUl
~ ClI IUt" ::!
t> ClI IUIII 4 .
7 ellS 1115 I c? - -
u elJS illS) 3-..
U C,,2.. (5)
1 LI CI.IO 151
1 I elJS 151
Ii! CUI 7!>~ ISI
I" ClI I 965 IS I
I 4 CU~S 151
15 CUSU4 L!ClJ Ill'" 'fIIllld'C Ieg'"II>
..-here ...,oIalllll' .e.clwlI~ ",.11 "",'u., .nol Ihe ,h.ded a.ea ",he,e ~ulfidc wmplcan .null in wlubdtly
.
3
I I
._-+-.. ----...
12 13
:5
B
7
4
B
10
9
;oJ
CI
~
o
III
Z
-------
_.
I SO
Albin 8IIaIign8
Roct.. MT 59701
February 11, 181M
BERKELEY PIT WATER
Benefits for the Community from
Maintaining Water Level. at the Bottom of the Pit:
1.
V.., 1"18 votum.. Gf .1aw-c:08t. de.n. ci'int8ble wat. C8ft be ...
...ilable far the community Gf Butte-Sil¥8' Bow far bath its pr.....
and fUt1a'e neecl8.
l..ge amounts at inexpen8i.. electiricity can be utilized by the
cOmmunity ar aotd at . profit to Montana Pow.. COIIIp8ny.
2.
3.
Stann wat. run-off. as wetl as the ....,. Gf the C08munity. C8ft .
be proceaed into a dean wat. lUppty that mHtS the Sate
Drinking Wat. Act requrements. .
4.
Metatc that now pose a heallh ri8t in ocr aquit. can be praculld
at a profit.
lIrge amounts of g8'bage can be proce888d. th«eby reducing
demand on the cwrent new landfill by .. m~ .. 10ft.
s.
6.
It will spawn a aptem to provide a vut 8T8J of high-tech. high-
paying i0b8 that win be carety needed 8ft. EPA. MDHES and
ARCa leave the community.
The procea can be utilized in oth.. ..eu of the wartd to beftefit
runtind while pradicaUy elilBinating the cov..-up and Inatitution8l
Comrala that ..e 80IDe of. the poaible -remedia- of pr..-t and
fubre Superfund lit... .
7.
8..
h eli8inat.. n8ecl far "'edation of Big Hote Ri... wat.. .. well
.. Silwr Late wat.. that could instead be utilized far tutwe .....
of the citizena of the State Of Montana.
Summary
Most of the technolOCJies required to turn the present catastrophe
of 8 highly contaminated area into an 8-* for our community
are currently achievable. Now is the rjght time in the Superfund
procea to put these technologies into place for beneficial u-
-------
.~,
(S).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII. MONTANA OFFICE
FIDIRAL IUILDINO. SO, I. 'A"It. DRAWlit '00.'
HIELENA. IIONTANA '''2'-00.'
Ref:
8MO
:ebr~arl :~, 1394
Mr. Albert Molignoni
Rocker, MT 59701
Dear Albert:
This letter is in response to your inquiry concerning the
effect of inundating the ~ines on the metals concentrations in
the mine water. As I described to you in our Pebruary 10th
meeting, the concentration of metals should drop because there is
less oxygen available to produce acid which solubilizes metals as
the mine waters rise.
Attached is an old (1960) AMC record which shows the.
concentration of copper in the pumped waters from several mines
to vary between 155 mg/l and 592 mg/l with an average of 363
mg/l. Our remedial investigation sampling showed copper
concentrations ranging from a minimum of .024 mg/l (Anselmo) to
.965 mg/l (Steward) and 1.28 1119/1 (Granite MtD.) . A8 you c:an
see, concentrations have dropped significantly. We believe that
this reduction in metals concentration is due to the inundation
of the shafts which limits the availability of oxygen.
If you have any questions concerning this subject, please
call me at 449-5720.
Sincerely,
;¥~ f~
Russell W. Forba
Remedial Project
Manager
cc:
Jam~s Scott, MDHES 1/
. 0"
-------
. ADMINISTRATI~E RECORD
abalzJd be added to iGUl Ht.. CGD pzCucUcD.
....... l1li .....,aI, IIDmt8 to 60 - 70 ,,' ,-.
'fta8 ~ _tel', &1~ ..-
~ ~i ... 8IUUNd.
tIai8 ""'1' adt. ~ '- IddId to tbI 1ft.. Call ~
":it tJ8 ... p1= ~,;.' ..,w, tbt to1laMl talUUaI ~ ~ :~, -
. ."
~~CD c: I!~:' ~CV::"1cS &~
~-."
,-: .~9608,." ~'.', '., ,
'", '-~,<~:.':> ~ ~-_.;:., ~.: >', . '.":''':.~',.: . ':'..~ :'~,,::, ,;,';:~;'>~':":~":'~."
~"rftI4l ''', ftA"~ soi.. ,C\1 ' QrosI tatai" ,,~-"" '
aa.:,.','".", ,lb.',.. 1fcatIa';~W:'/~'" .i:'~::-'~~.
".'" .' -~ ~..' .. foo' ...''''''.
",:",.".~~":""<~,'~ J,,~~:~"~"/,\\;~, ',~ !"",: :,~~~:~;:~,...:,<. >::'~:;:';,~,>~1,~v:-~',"~::':::~', ' ' ,~,., '
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ADcIroval For CIIIr8nc:I Plr Con_toon
A8 RlQl»8tlCl For Con'lCtlOn PrIoIreRlO1y
Clrculltl For Your tnfOfmltJOll See Me
Com- I~- Sionature
CoonlinltJOll JustifY
. REMARKS
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1'Io:.~.n.. iure.", oi .. ~ lIeS 01 Gea 109'.:1 :.led Feb 8'9 94 11:58 iW8I V2
Sutte Mine ?loodin9
Outer Camp Water Level ::ata
!1BKG Data
Green Laite Seep Elevat~on - 5560 ft (USGS-,
::ate O~han Boy !levation-
: ~dmmyy, SWL( ft) ! ft)
5700.00
:/ 7/1992 122.43 5577.57
;.i 4i1992 122.66 5577.34
3/ 4/1992 122.64 5577.36
~/ 2/1992 ~22.7S 5577.25
:/ 5/1992 123.~6 :576.94
5/ 1/1992 123.21 5576.79
7/ 1/1992 122.70 5577.30
6/ 3/1992 121.96 5578.04
9/ 1/1992 121.55 5578.44
10/ 1/1992 121..H 5578.69
11/ 9/1992 120.88 5579.12
12/ 2/19'i2 121.::2 5578.98
1/ 6/1993 121. 12 5578.88
2/ 3/1993 121. 34 5578.66
3/ 4/1993 121.55 5578.45
4/ 5/1993 120.99 5579.01
5/ 3/1993 120.76 5579.24
5/ 3/1993 120.69 5579.31
7/ 7/1993 120.02 5579.98
8/ 4/1993 119.34 5580.66
9/ 2/1993 118.29 5581.71
1'J1 4/1993 116.82 5583.18
11/ 3/1993 115. i7 5584.23
12/ 1/1993 115.53 5584.47
1/ 4/1994 115.41 5584.59
2/ 3/1994 115.61 5584.39
- Elevation data is based upon USGS tope map interpretation
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!'~RCAMr
.. .,,., QuaJiry
VIS/I~
''4
.) SITE Lab
DATE
.\. ADalyais (mmiddl)1')
'1
-, MBMG
.. tPllAN BOY 1127/1981
1'\ MBMG Sn8l1987
. .
o;t MBMG 6/25/1987
..., MBMG S13I/1988
,,) MBMG 6n9/1988
. . MBMO 111 811989
CJ MSE 5129/1.991
. 'I' MSE 91 3/1991
'0
SURFACE MSE 512911991
!;EFJ> MSE 91 6/1991
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PHYSICAL PARAMETERS
FIELD LAB
TIME DISCHARGE SWL SAMPLE PH SC TEM Eli PII SC HARDHES A1..KA1JNfI'Y
(HR$) (OPM) (FT) DEYrH (UMHOS (C) (MY) (UMHOS (MOIL) (MOIL)
14:00 124.4 6.44 2400 24.0 HI A H/A HI A HI A H/A
12:40 127.5 6.47 N/A 11.6 H/A 7.2 2260 HIA NIA
11:25 125.5 6.62 HI A H/A HIA H/A HIA H/A H/A
17:10 124.0 6.25 1101 25.0 H/A 7.0 2261 1114.0 110.1
17:10 124.1 6.33 2210 18.1 .2fJ7 1.0 2231 1t3U 150.5
15:SO 124.2 6.60 2190 18.5 NIA 7.5 2080 1115.2 100.4
14:51 H/A 6.96 2089 26.0 .2fJ7 HI A NIA NIA 1020.0
15:05 NIA 6.72 2200 23.5 .215 H/A NIA 961.0 7JO.0
17:15 6.87 1831 16.1 3 NIA NIA H/A 109.0
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ITHE
r Clark Fork
Pend Oreille
I COALITION
-~~...~.
-
~~
P.O. Box 7593
Missoula. MT 59807
4061542.0539
P.O. Box 4718
BU1le. MT 59702
4061723-4061
P.O. Box 1096
Sandpoint,lD B3864
20&'283.0347
P!
! April 28. 1994
"'. Russ Faba. Project Manager
U.S. E.P.A.
! 301 S. Park
; Helena, MT 59626
Re: 3.690 Public Comments on the E3erkelev Pit and Mine Flooding Preferred Plan
,
j
I Dear Russ:
I
I . Enclosed is a Berkeley Pit petition signed by 3.690 affected citizens. Of these,
i 3.4~0 are residents of Butte-Silver Bow..G.qunty. The balan~oncemed
: Anacondans and other residents of the Clark RihwtefSfiiQ. as weD 8S a few
I Montanans from nearby cities and towns.
; The people who have signed this petition make up over 10.3% of the population
I of BUlle-Silver Bow. Their number is about the same as those who voted in the recent
! school board election. The number of signatures is significant in that the petition was
! ''Waked'' fa par1S of the day on only three Saturdays in one stex'e in Bune (about
I 2.000 signatures): a small donated newspaper ad received an amazing 2.6%
i response rate (286 mailed-in petitions); petitions were out for about a week in six
retail establishments. and the balance came in from people who asked to take
petitions from K-Mar1 for their friends to sign. We believe that over 95'1 o' those
in Butte who were asked to 8ign the petition did 80. Those who Qci'l't were
usually in a rush: very few refused. The point is. this was something the citizens of
I Butte Silver Bow were able to ag-ee on wholeheartedy. They often said. 1hank your
and "bless you," and expressed the wish they had time to get more involved.
I Please consider that many. if not mosl. of the folks petitioning you to start wak
on deaning the pit water now seemed to be really upset about it. We often heard
i people say they "can't believe EPA would !et this happen to Butte: What the majaity
seem care 6DOU( CII'e no( un:: u~chnicaJ complexities. and not the Haseshoe Bend
water. but rather the Pit itself: e.g., that EPA would allow ARCa -...to wait nearly 30
yeen to pump and 'clean the water,. "... to let the pit fill and and stay that way fcrever. "
",..not to redlce the amount of contaminated waterr .
...:--
Please consider the overwhelming non-acceptance by the community o' the
~eferred plan - despite massive influx of ARCa PR dollars to this rural area over the
past few years, People say the plan would aeate new contamination and a nuisance
that would deaease their quality of life in substantial ways - inducing
environmentally, economically, socially - and that it aeates new ttYeats to human
heath, induding mental health. Please consider that this massive Superfund site is
part of the neighbahood in this community, not separate from dtizens and homes and
families. Please consider the people who live here today, those who hope to live here
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Please do not chose a remedy that appears to give gealest weight to cost or to
threats of litigation from Potentially Responsible Parties.
Thank you. Russ. ICf all your help and hard WCfK on this ~oject. Hopefully,
information wlil have come 1ct'War.d during the Public Comment Period that will enable
EPA to respond ap~oprlately to the grave concerns of the people who live on top of
and next to this Superfund site.
Yours very truly,
~~.~
Mary Kay Craig
Upper River Field Re~esentBtive
'=1'\1"I"e.. ...'"
-..-...-- ..
cc:
President Bill Clinton
Vice President AI GOrl
Senator Max Baucus
S_tor Conrad Burns
RlprlSlntatlve.Pat Williams
Govtrnor Marc Racicot
Me. Carol Browner, U.s. EPA Administrator
Mr. Bill Vellowtall, U.s. EPA Reg. Administrator
Mr. John Wardell, U.S. EPA Montana Director
Mr. Bob Robinson, Director, MontanlDHES
Mr. Jack Lynch, Butte-Sliver Bow County Chle' Executive
i -
!!
,
, .
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