xvEPA
United States         Region 6            May, 1980
Environmental Protection     1201 Elm
Agency           Dallas, TX 75270
United States         National Center
Geological Survey       Reston, VA 22092
Enforcement	

Environmental           Final

Impact Statement


Fancy Hill (Milchem) Barite

Mine and Processing Plant


Montgomery  County Arkansas

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                                FINAL
                     ENVIRONMENTAL  IMPACT STATEMENT

                    FANCY HILL  (MILCHEM) BARITE MINE
                         AND PROCESSING PLANT
                      MONTGOMERY COUNTY, ARKANSAS
                             Prepared By:

                  U.S.  ENVIRONMENTAL PROTECTION AGENCY
                                REGION 6
                             DALLAS, TEXAS

                                  and

                         U.S.  GEOLOGICAL  SURVEY
                       DEPARTMENT  OF THE  INTERIOR
                            RESTON, VIRGINIA

                         With Cooperation of:

                        FOREST SERVICE, U.S.D.A.
                        OUACHITA NATIONAL FOREST
                         HOT SPRINGS, ARKANSAS

                               June 1980
APPROVED BY:
                                                         APPROVED  BY:
        .AS
f^H. V/ILLIAM  MENARD
   DIRECTOR
   U.S.  GEOLOGICAL  SURVEY
                                                              HARRISON
                                                       REGIONAL  ADMINISTRATOR
                                                       U.S.  EPA

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                               FOREWORD
                                         \

The following pages replace similarly numbered pages which appeared in
the Draft Environmental Input Statement ("DEIS").  Those portions of
DEIS pages that were revised in order to prepare this FEIS are indicated
by a vertical line in the left margin of each page next to the appropriate
text.

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                           TABLE OF CONTENTS

Section	                     Page No.

LIST OF TABLES                                                       1
        %
LIST OF FIGURES                                                     iv

EXECUTIVE SUMMARY                                                   vi

1.0  INTRODUCTION                                                    1

     1.1  Applicant                                                  2
     1.2  EPA Responsibilities                                       3
     1.3  USGS Responsibilities                                      8
     1.4  Forest Service Responsibilities                           10

2.0  NEED FOR BARITE                                                12

     2.1  Barite Uses                                               12
     2.2  Barite Demand                                             13
     2.3  Barite Supply                                             15

          2.3.1  Barite Imports                                     16
          2.3.2  Fancy Hill Production                              20

     2.4  Summary                                                   22


3.0  PROPOSED FACILITY                                              23

     3.1  Location                                                  23
     3.2  Land Ownership                                            26

          3.2.1  History of the Barite Deposit                      26
          3.2.2  Ownership Status                                   28
          3.2.3  Land Requirement                                   28

     3.3  Construction Schedule and Procedures                      33

          3.3.1  Mine                                               37
          3.3.2  Spoil Disposal Areas                               40
          3.3.3  Tailings Pond                                      40
          3.3.4  Processing Plant and Warehouse                     41
          3.3.5  Pipelines and Tailings Pond Access Road            41
          3.3.6  Haul Road                                          43
          3.3.7  Containment Basin                                  44

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                           TABLE OF CONTENTS  (cont.)

Section 	                      Page No.

     3.4  Operation Schedule and Procedures                          44

          3.4.1  Mine                                                45
          3.4.2  Process Plant                                       47A

                 3.4.2a.  Crushing                                   47A
                 3.4.2b.  Grinding                                   47A
                 3.4.2c.  Flotation                                  48
                 3.4.2d.  Drying                                     49
                 3.4.2e.  Shipping                                   49

          3.4.3  Spoil Areas                                         49
          3.4.4  Tailings Pond and  Pipelines                         52
          3.4.5  Containment Basin                                   53

                 3.4.5a.  Emergency Spillway                         53A
                 3.4.5b.  Principal Spillway                         53B

          3.4.6  Haul Road                                           53C

     3.5  Health and Safety                                          53D


4.0  ALTERNATIVES                                                    55

     4.1  Milchem's Alternatives                                     55

          4.1.1  Alternate Sites                                     55

                 4.1.la.  Mine                                       55
                 4.1.1b.  Spoil Disposal  Areas                       56
                 4.1.Ic.  Processing  Plant                           62
                 4.1.Id.  Tailings  Pond                              63
                 4.1.le.  Warehouse                                  65

                          Mitchell  Property                          65
                          Scott Property                             66
                          Norman Site                               66

                 4.4.If.  Containment Basin                          66

          4.1.2  Process and Design Alternatives                     66A

                 4.1.2a.  Mine                                       66A
                 4.1.2b.  Excavation  Techniques                      67
                 4.1.2c.  Ore and Spoil Transport                   68
                 4.1.2d.  Tailings  Transport                         70
                 4.1.2e.  Ore Processing                             71
                 4.1.2f.  Emission  Control                           71
                 4.1.2g.  Effluent  Disposal                          77

                         Deep Well  Injection                         77
                         Demineralization                           78

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                           TABLE OF CONTENTS  (cont.)

Section	                      Page No.

          4.1.3  Production Rates                                    79
          4.1.4  Delay, Postpone, or Abandon  the  Project             80

     4.2  Administrative Alternatives                                81

          4.2.1 EPA                                                  81

                 4.2.la.  Issuance of the  Permit                     81
                 4.2.1b.  Denial of the  Permit                       81

          4.2.2  USGS                                                81
                       V

                 4.2.2a.  No Action                                  82
                 4.2.2b.  Defer Approval                             82
                 4.2.2c.  Reject the Proposed Plan                   83
                 4.2.2d.  Seek Legislation to Cancel  the  Lease      83
                 4.2.2e.  Exchange the Existing Lease               84
                 4.2.2f.  Suspend Operations                         85
                 4.2.2g.  Reacquire the  Leased Rights               85
                 4.2.2h.  Restrict Development on the Lease         86

          4.2.3  FS                                                  86

                 4.2.3a.  Haul Road Easement                         87
                 4.2.3b.  Pipeline/Access  Road Easement              87
                 4.2.3c.  Section 24 Spoil Area                      88

5.0  IMPACTS OF THE PROPOSED FACILITY                                89

     5.1  Geology                                                    89

          5.1.1  Stratigraphy                                        89
          5.1.2  Structural Geology                                  91
          5.1.3  Mineralization                                      93
          5.1.4  Spoil                                               95
          5.1.5  Paleontology                                        95
          5.1.6  Geologic Impacts                                    95

     5.2  Geological Hazards                                         96

     5.3  Soils                                                      98

          5.3.1  Soil Characteristics                                98
          5.3.2  Reclamation                                        102

     5.4  Land Use                                                  103

          5.4.1  Existing Land Use                                  103
          5.4.2  Land Use Controls                                  108
          5.4.3  Suitability for Other Uses                         109
          5.4.4  Land Use Projections                               109

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                           TABLE OF CONTENTS (cont.)

Section	                     Page No.

          5.4.5  Land Use Impacts                                  109

     5.5  Hydrology                                                112

          5.5.1  Quantity and Quality of Surface Water             112

                 5.5.la.  Mean Daily Flow                          115
                 5.5.1b.  Low Flow                                 115
                 5.5.1c.  Water Quality Characteristics            120
                 5.5.Id.  Uses of Surface Water                    128
                 5.5.1e.  Discharge Characteristics                131

                          Tailings Pond Effluent                   131
                          Spoils Area Leachate                     133
                          Mine Water                               136
                          Containment Basin                        138A
                          Sanitary Waste                           138A

                 5.5.1f.  Potential Impact on Surface              139
                          Water

                          Chemical Discharges                      141
                          Water Quality                            142
                          Oxygen Demand                            143
                          Sulfate                                  144
                          Total Dissolved Solids (TDS)             144
                          Hardness                                 149

          5.5.2  Quantity and Quality of Groundwater               149

                 5.5.2a.  Water Bearing Properties                 149

                          Arkansas Novaculite                      149
                          Stanley Shale                            150

                 5.5.2b.  Groundwater Occurrence                   150
                 5.5.2c.  Groundwater Quality                      152
                 5.5.2d.  Local Use of Groundwater                 154
                 5.5.2e.  Potential Impact on Groundwater          154

                          Tailings Pond                            154
                          Spoils Areas                             156
                          Mine Water                               156
                          Plant Make-up Water                      158

          5.5.3  Water Management                                  158
          5.5.4  Flood Hazard                                      162

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                           TABLE OF CONTENTS  (cont.)

Section	                    Page  No.

                 5.5.4a.  Flood Discharges                          165
                 5.5.4b.  Flood Elevations  •'                      165
                 5.5.4c.  Potential Flood  Impacts                   169

     5.6  Biology                                                   169A

          5.6.1  Terrestrial Systems                                169A

                 5.6.la.  Terrestrial Flora                         170
                 5.6.1b.  Terrestrial Fauna                         171
                 5.6.1c.  Potential Impacts of Construction         175
                          and Operation
                 5.6.Id.  Effects of the Tailings Pond              180

          5.6.2  Aquatic Systems                                    181

                 5.6.2a.  Aquatic Fauna                .             181
                 5.6.2b.  Potential Impacts of Plant                186
                          Construction and Operation

                          Chemical Discharges                       188
                          Water Quality                             188

          5.6.3  Unique Biotic Resources                            191

                 5.6.3a.  Unique Biota                              191
                 5.6.3b.  Threatened Biota                          192

                          Plants                                    196
                          Fishes                                    201
                          Herptofauna                               203

     5.7  Climatology and Air Quality                               208

          5.7.1  General Climatology                                208

                 5.7.la.  Temperature                               208
                 5.7.1b.  Precipitation                             209
                 5.7.1c.  Humidity and Fog                          209
                 5.7.Id.  Surface Winds                             209
                 5.7.le.  Severe Weather                            209

          5.7.2  Air Quality                                        210

                 5. 7.2a.  General                                   210
                 5.7.2b.  Atmospheric Impact  of Stationary          211
                          Sources

                          Major Sources                             211
                          Minor Sources                             213

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                           ».TABLE OF  CONTENTS  (cont.)

Section	                      Page No.

                 5.7.2c.   Impacts of Mobile Sources                 217

     5.8  Archaeology and  History                                   222

     5.9  Socioeconomics                                            224A

          5.9.1  Population                                         224A
          5.9.2  Employment       '                                  226

                 5.9.2a.   Job Opportunities                         226
                 5.9.2b.   Unemployment                              228
                 5.9.2c.   Income                                    228

          5.9.3  Potential Labor Supply and Demand                  231

          5.9.4  Community Facilities                               233

                 5.9.4a.   Water and  Sewer                           233
                 5.9.4b.   Housing                                   236
                 5.9.4c.   Schools                                   236
                 5.9.4d.   Transportation                            236

          5.9.5  Taxation  and Government Cost                       239

                 5.9.5a.   State Taxes                               239
                 5.9.5b.   County Taxes                              239
                 5.9.5c.   Government Expenditures                   241
                 5.9.5d.   Net Public Revenues                       241
                 5.9.5e.   Other Economic Benefits                   241
                 5.9.5f.   Lost Economic Opportunity                 244

     5.10 Aesthetics                                                244

          5.10.1 Noise                                              244
          5.10.2 Scenic Value                                       249
          5.10.3 Visibility                                         251
          5.10.4 Recreation                                         252

6..0  UNAVOIDABLE IMPACTS AND RESOURCE COMMITMENTS                   254

7.0  COORDINATION                                                   257

     7.1  Public Participation                                      257
     7.2  EIS Contributions                                         257
     7.3  Review of Draft  EIS                                       257

          7.3.1  Comment Letters                                    257A
          7.3.2  Public Hearing                                     257A

LITERATURE                                                          260

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                           TABLE OF CONTENTS  (cont.)

Section	                      Page  No.

APPENDICES

     A:  Draft NPDES Permit                                         265
     B:  Notice of Intent                                           277
     C:  FWS Correspondence                                         282
     0:  COE Correspondence                                         287
     E:  NSPS and NESHAPS                                           291
     F:  PSD                                                        294
     6:  Responses to Notice of Intent                              313

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LIST OF TABLES
Table No.
2.2.1
2.3.1
3.2.1
3.3.1
3.3.2
4.1.1
4.1.2
4.1.3
5.3.1
5.3.2
5.3.3
5.4.1
5.4.2
5.4.3
5.4.4
5.5.1
5.5.2
5.5.3
5.5.4
5.5.5
5.5.6
5.5.7
5.5.8
Description
PROJECTIONS OF U.S. BARITE DEMAND
U.S. PRODUCTION, CONSUMPTION AND IMPORTS
OF BARITE
SUMMARY OF SURFACE DISTURBANCE
REGULATORY AGENCY PERMITS
MAJOR MINING EQUIPMENT
COMPARISON OF ALTERNATIVE SPOIL
UNCONTROLLED POLLUTANT EMISSIONS
COAL AND WOOD FUEL AIR EMISSIONS
SUMMARY OF SOIL PROPERTIES
SUMMARY OF CHEMICAL ANALYSES (OF SOIL)
SPECIES OF VEGETATION RECOMMENDED FOR
MINE AREA RECLAMATION
LAND USE BY COUNTY
LAND OWNERSHIP BY COUNTY
DETAILED LAND USE
LAND USE PROJECTIONS
PHYSICAL CHARACTERISTICS OF DRAINAGE BASINS
ESTIMATED AVERAGE MONTHLY STREAMFLOWS
MINIMUM AVERAGE 7-DAY LOW FLOW
WATER QUALITY" SUMMARY, SOUTH FORK AND
CADDO RIVER
WATER QUALITY SAMPLES OF CADDO RIVER
TRIBUTARIES
RANGE OF WATER QUALITY PARAMETERS AT
GLENWOOD
WATER USE, OUACHITA RIVER BASIN
TAILINGS POND EFFLUENT QUALITY
Page No.
14
19
34
36
38
60
72
74
100
101
103A
104
105
106
110
117
118
119
122
123
127
129
134

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                          LIST OF TABLES (cont.)
Table No.
5.5.9
5.5.10
5.5.11
5.5.12
5.5.13
5.5.14
5.5.15
5.5.16
5.5.17
5.5.18
5.6.1
5.6.2
5.6.3
5.6.4.
5.6.5
5.6.6
5.7.1
5.7.2
5.7.3
5.7.4
Description
SPOILS AREA LEACHATE QUALITY
ASSUMED VALUES FOR EFFLUENT
FLOW AND SULFATE/TDS CONCENTRATION
ESTIMATED SOUTH FORK TDS AND SULFATE
CONCENTRATION DURING OPERATION
MAJOR DISSOLVED CONSTITUENTS OF
U.S. RIVER WATER
PERMEABILITY TEST SUMMARY
CHEMICAL ANALYSES OF GROUNDWATER
INPUT OF SOLIDS, SULFATE AND SEDIMENT .
TO DEGRAY RESERVOIR
SPECIFIC WATER QUALITY STANDARDS
ESTIMATED PEAK FLOOD DISCHARGES
ESTIMATED PEAK FLOOD ELEVATIONS
UNCOMMON FOREST COMMUNITIES
COMMON FAUNA, OUACHITA NATIONAL FOREST
HABITAT RATING
FISHES OF THE SOUTH FORK OF THE CADDO RIVER
MEDIAN TOXICITY THREASHOLD FOR VARIOUS
FISHES AND INVERTEBRATES
UNCOMMON NATIVE PLANTS AND ANIMALS
AIR QUALITY REGULATIONS
PHYSICAL PARAMETERS AND EMISSION RATES
AMBIENT AIR QUALITY DATA, ODEN, ARKANSAS
ESTIMATED MAXIMUM GROUND-LEVEL CONCENTRATIONS
Page No.
137
145
146
148
151
153
161
163
166
167
172
173
176
184
190
193
212
214
215
216
             AND REGULATORY LIMITATIONS



5.7.5        MOBILE SOURCE EMISSION RATES                        219

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                            LIST OF TABLES (cont.)


Table No.      Description	                  Page No.

  5.7.6        ASSUMED YEARLY EQUIPMENT USAGE                      220

  5.7.7        MOBILE SOURCE EMISSIONS                             221

  5.9.1        EMPLOYMENT BY SECTOR, 1977                          227

  5.9.2        POTENTIAL LABOR SUPPLY                              229

  5.9.3        ECONOMIC PROJECTIONS:  UPPER OUACHITA RIVER         230
               SUB-BASIN

  5.9.4        JOBS AND PERSONAL INCOME RELATED TO THE             234
               FANCY HILL FACILITY

  5.9.5        SEWAGE TREATMENT FACILITIES                         235

  5.9.6        VACANT AVAILABLE STANDARD HOUSING UNITS             237

  5.9.7        PUBLIC SCHOOL ENROLLMENT                            238

  5.9.8        ESTIMATED TAX REVENUES                              240

  5.9.9        ESTIMATED PUBLIC COSTS                              242

  5.9.10       ESTIMATED TAX REVENUES VS. PUBLIC                   243
               EXPENDITURES

  5.10.1       CONSTRUCTION EQUIPMENT NOISE LEVELS                 246

  5.10.2       SUMMARY OF NOISE LEVELS IDENTIFIED AS               248
               REQUISITE TO PROTECT PUBLIC HEALTH AND
               WELFARE WITH AN ADEQUATE MARGIN OF
               SAFETY

  5.10.3       RECREATIONAL USE, OUACHITA NATIONAL                 253
               FOREST

  7.1.1        CONTRIBUTORS                                        258
                                   111

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                            LIST OF FIGURES
Figure No.          Description	                 Page No.

  2.3.1              CUSTOMS VALUE OF IMPORTED BARITE,                17
                    1971-1978

  2.3.2             DOMESTIC BARITE PRODUCTION VERSUS                21
                    DEMAND, 1979-2000

  3.1.1              VICINITY MAP                                    24

  3.2.1              PROPERTY OWNERSHIP                              29

  3.2.2             CONCEPTUAL ARRANGEMENT PLAN                     31

  3.3.1              TYPICAL MINE SECTION                            39

  4.1.1              ALTERNATE SITES                                 58A

  5.1.1              GENERALIZED GEOLOGICAL MAP OF THE  FANCY         90
                    HILL BARITE DISTRICT

  5.1.2             CROSS SECTIONS ACROSS BACK VALLEY                92

  5.1.3             GEOLOGICAL MAP OF A TYPICAL SECTION             94
                    OF THE WESTERN END OF THE FANCY HILL
                    BARITE VEIN

  5.5.1              DRAINAGE MAP OF THE FANCY HILL AREA            113

  5.5.2             MONTHLY STREAM FLOW DISTRIBUTION                114
                    NEAR ALPINE, ARKANSAS

  5.5.3             EXISTING DRAINAGE AT MINE SITE                 116

  5.5.4             CADDO RIVER WATERSHED                          126

  5.5.5             SCHEMATIC OF MATERIAL AND WATER FLOW           132

  5.5.6             STAGE DISCHARGE RELATIONSHIP                   168
                    NEAR PLANT SITE

  5.6.1              FISH SAMPLING STATIONS                         182

  5.8.1              NATIONAL REGISTER PROPERTIES                   225

  5.9.1              LABOR SUPPLY AREA                              232
                                   IV

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                           EXECUTIVE SUMMARY

               ( )  Draft Environmental Impact Statement

               (x)  Final Environmental Impact Statement

                    Environmental Protection Agency

                               Region VI

                             Dallas, Texas

                                  and

                         U.S. Geological Survey

                      Department of the Interior

                           Reston, Virginia



!•    Type of Action

     (x)  Administrative

     ( )  Legislative

2.    Description of Proposed Activity and Potential Impacts

     Milchem Incorporated of Houston, Texas proposes to develop an open
     pit mine and processing facility at Fancy Hill in Montgomery
     County, Arkansas approximately 15 miles northwest of the City of
     Glenwood.   Barite ore will be mined at Fancy Hill utilizing con-
     ventional  benchmining techniques.  The ore processing plant will
     receive run-of-mine ore at a rate of 460,000 short tons per year.
     Spoil will be placed in one of three spoil disposal areas, used as
     fill during construction or returned to mined-out portions of the
     open pit(s).  Ore will be stockpiled at the plantsite and then con-
     veyed for processing through circuits of crushing, grinding, flo-
     tation, drying, final storage, and shipment.  The product will then
     be cooled, sampled, and transferred to bulk storage bins.  Trucks
     will carry the product in bulk to a warehouse at Glenwood for final
     shipment by truck or rail to Milchem's customers throughout the
     country.  The water used in the milling process will carry tailings
     to a storage pond and then be recycled to the plant.  A small
     portion of the recycle stream will be discharged into an unnamed
     tributary of the South Fork of the Caddo River.  In addition,
     leachate water from spoil disposal areas and water resulting from
     mine pit dewatering and run-off from raw ore stockpiles will also
     constitute waste water and be discharged.

     Although mitigating measures will minimize the impacts of the Fancy
     Hill facility on the environment, some adverse impacts cannot be
     avoided.  These impacts are summarized in the following paragraphs.

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Alteration of the natural topography of the mine area is unavoid-
able due to excavation of three mine pits, a portion of which may
not be completely backfilled.  Creation of three spoil piles and a
tailings pond will also create long-term alterations of local
topography.  No features now present at Fancy Hill are unique or of
outstanding or special scenic value.  The Fancy Hill mine will be
one of three mines in the area, resulting in topographic impacts
similar to those now occurring there.

Soil productivity will be reduced on less than 400 acres of land.
Soil amendments in the spoil disposal areas will be required to
assure the future growth of grasses and trees in these areas.
Long-term productivity after reclamation may be less than pre-
mining productivity.  Land used for the tailings pond and any
portion(s) of the mine pit which is not backfilled will be per-
manently withdrawn from timber production and other silvicultural
or agricultural activities.

Alternate uses of less than 500 acres of land will be precluded in
the short-term during the life of the facility.  As noted above,
this land will be predominantly restored and rendered suitable for
other uses when Milchem abandons the area.

Discharge of wastewater effluent into the South Fork of the Caddo
will cause a measurable degradation of the stream's water quality
during the period of operation.  State standards regulating the
stream's water quality are, however, not expected to be violated.
Local groundwater supplies may also be degraded by a presently
unknown amount.  Neither of these changes are expected to be sig-
nificant with respect to present or future long-term users of these
waters.

Construction at Fancy Hill will increase sediment loads to the
South Fork thereby resulting in a potential short-term stress on
South Fork aquatic biota downstream of the facility.  Following the
establishment of erosion control measures prior to and during
facility operation, the affected biota should begin to recover.
Return to preconstruction conditions may, however, require several
years.  Similarly, disturbance at Fancy Hill will cause some species
of terrestrial wildlife to leave and/or avoid the area.  Other
species will be directly affected and removed from the area popu-
lation.  An unimportant but unavoidable loss of recreational hunting
opportunity will result and will persist during the facilities'
operating life.

Fugitive dust will cause an unavoidable but temporary decrease in
area visibility.  Total air pollutants, including particulate
matter, S02 and NO emitted by the product dryer, will also cause a
short-term deterioration of ambient air quality.  The minimum
amount of impact considered significant is limited to a distance of
about 4.4 miles from the facility; additionally, both short-term
(3-hour and 24-hour) and long-term (annual average) impacts are
expected to be within regulatory limitations.  These emissions will
cease at the end of Milchem's operating period at Fancy Hill.
                             VI

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     Secondary impacts on ambient air quality due to the operation of
     vehicles not directly related to Milchem's operations at Fancy Hill
     or such other emissions as those associated with space heating and
     air-conditioning in residences and businesses are negligible.

     A cultural resources survey of the project area resulted in the
     testing of seven archaeological sites that would likely not other-
     wise have been studied.  Also, procedures to protect any archaeological
     resources uncovered during mining have been developed.  It should
     be noted, however, that Milchem's operations may preclude future
     study of any unknown sites overlain by spoil or tailings.

     Vehicle traffic on Highway 240 and other area roadways will in-
     crease during the life of the Fancy Hill facility and cause a
     temporary nuisance to other users, such as recreational travelers.
     Similarly, noise associated with traffic, the operation of Milchem's
     mining equipment, and blasting will probably be perceived as a
     nuisance by local residents and other persons in transit through
     the area.  With this exception, the facility will cause a negli-
     gible adverse impact on the local economic and public service
     infrastructure.  Offsetting this effect is the positive impact on
     the economy relating to the creation of employment opportunities,
     purchase of land from area landowners, and the payment by Milchem
     of royalties and State and local taxes.  None of these effects will
     persist after Milchem leaves the area.

     Mining and reclamation at Milchem's proposed Fancy Hill facility
     will require the commitment of presently undetermined amounts of
     natural resources including electrical power, lubricants, diesel
     and gasoline fuel, ammonium-nitrate explosive, and structural
     materials such as plastic, steel, and concrete.  Construction of
     the facility will also require that in excess of 170 man-years of
     skilled and unskilled labor be committed.  Operations at Fancy Hill
     will require in excess of 1500 man-years of skilled and unskilled
     labor.  In return, Milchem will produce in excess of two million
     tons of barite, a non-metallic mineral resource of national impor-
     tance.  This barite product will assist in decreasing the nation's
     current high level of reliance on barite imported from foreign
     sources.  Production at Fancy Hill wrll also positively impact the
     nation's balance of payments.

3.    Brief Description of Administrative Action

     The U.S. Environmental Protection Agency, Region VI, proposes to
     issue a permit for the discharge of wastewater from Milchem's
     facility into the South Fork of the Caddo River under provisions of
     the National Pollutant Discharge Elimination System.  The U.S.
     Geological Survey proposes to approve a mining and reclamation plan
     which would allow Milchem to mine the barite ore located on a
     Federal mineral lease at Fancy Hill.  Issuance of the discharge
     permit and approval of the mining and reclamation plan are the
     administrative actions evaluated in this EIS.
                                 VI1

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4.   Alternatives Considered

     The alternatives evaluated in this DEIS are the following:

          MILCHEM'S ALTERNATIVES

               Alternate Sites
                    Mine
                    Spoil Disposal Areas
                    Processing Plant
                    Tailings Pond
                    Warehouse

               Process and Design Alternatives
                    Mine
                    Excavation Techniques
                    Ore and Spoil Transport
                    Tailings Transport
                    Ore Processing
                    Emission Control

               Production Rates

               Delay, Postpone, or Abandon the Project

          ADMINISTRATIVE ALTERNATES

               EPA
                    Issuance of the Permit
                    Denial of the Permit

               USGS
                    Approve the Plan
                    No Action
                    Defer Approval
                    Reject the Proposed Plan
                    Seek Legislation to Cancel the Lease
                    Exchange the Existing Lease
                    Suspend Operations on the Lease
                    Reacquire the Leased Rights
                    Restrict Development on the Lease

               Forest Service
                    Issue or Deny Special Use Permits
                         Haul Road Easement
                         Pipeline/Access Road Easement
                         Section 24 Spoil Area

5.   Agencies and Other Interested Parties from Which Comments Mere
     Requested

     Federal  Offices

     Economic Development Administration
     Corps of Engineers
                                 vm

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Department of Housing and Urban Development
Advisory Council on Historic Preservation
Department of Health, Education and Welfare
Department of Agriculture
Department of Transportation
Federal Highway Administration
Department of Commerce
Soil Conservation Service
Department of Energy
Federal Energy Regulatory Commission
Water Resources Council
Honorable Dale Bumpers, U.S. Senate
Honorable David Pryor, U.S. Senate
Honorable John Paul Hammerschmidt, U.S. House of Representatives
Honorable James Santini, U.S. House of Representatives
Department of Labor - Mine Safety and Health Administration.
Bureau of Mines - Interior Department (Liaison Office)

State Offices

Arkansas Natural Heritage Commission
Arkansas Archaeological Survey
Arkansas Historic Preservation Program
Governor's Office
Attorney General 's Office
Game and Fish Commission
Department of Pollution Control and Ecology
Arkansas Highway Department
Arkansas Industrial Development Commission
State Planning and Development Clearinghouse
Arkansas Forestry Commission
Arkansas Soil and Water Conservation Commission
Department of Labor - Mine Inspection Section
Department of Labor - Employment Security Division
Honorable Ode Maddox, House of Representatives

Other Interested Parties

City of Glenwood
City of Norman
Montgomery County
Wildlife Management Institute
The Ozark Society
National Audubon Society
Environmental Defense Fund
Natural Resources Defense Council
National Wildlife Federation
Arkansas Ducks Unlimited
Arkansas Association of Conservation Districts
Arkansas Ecology Center
League of Women Voters
Arkansas Community Organization for Reform Now
Associated Industries of Arkansas
Arkansas Lung Association

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     Dr.  Arthur A.  Johnson
     Arkansas Federation of Water and Air Users, Inc.
     Glenwood Industrial Growth Committee
     American Mining Congress
     Society of Mining Engineers of AIME
     Arkansas Society of Professional  Engineers
     Associated General Contractors of America - Arkansas Chapter
     Industrial  Developers of Arkansas
     Hot  Springs Chamber of Commerce
     West Central  Arkansas Planning and Development District

6.    Agencies and Other Interested Parties from Which Comments Have Been
     Received

     Federal Offices

     Corps of Engineers
     Department of Housing and Urban Development
     Advisory Council on Historic Preservation
     Department of the Interior
          Fish and Wildlife Service
          Office of the Secretary
     Department of Agriculture
          Forest Service

     State Offices

     Arkansas Historic Preservation Program
     Arkansas Archaeological Survey
     Department of Economic Development
     Department of Local Services
     Soil  and Water Conservation Commission
     Department of Arkansas Natural & Cultural Heritage Natural and
       Scenic Rivers Commission
     Honorable Ode Maddox, House of Representatives

     Other Interested Parties

     American Institute of Mining & Metallurgical  Engineers
          Arkansas Section
     Associated General Contractors of America, Inc.
          Arkansas  Chapter
     Montgomery County Chamber of Commerce
     Montgomery County Quorum Court
     Ozark Society
          Pulaski  County Chapter
     Killian Lumber Company
     Mr.  Carl Smith
     Mr.  Gene Newsom
     Mr.  David Criner

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                             .SECTION 1.0





                             INTRODUCTION





The following pages were revised in this section of the DEIS:

-------
reasonable opportunity to comment with regard to the undertaking.  The
President has implemented procedures to facilitate compliance with this
provision at 36 CFR (Code of Federal Regulations) Part 800.

Executive Order 11593 (Protection and Enhancement of the Cultural
Environment) requires Federal agencies to take a leadership role in the
preservation of the nation's cultural resources.  For actions permitted
by a Federal agency, the agency must ask the Secretary of the Interior
to determine if any property in the affected area is eligible for the
National Register.  Procedures to carry out this process are being
codified at 36 CFR 63.  EPA has consulted with the Arkansas Archaeological
Survey and the Arkansas State Historic Preservation Officer ("ASHPO")
regarding cultural resources in the Fancy Hill area.  It has been deter-
mined that no properties which are on or eligible for the National
Register will be affected by the project.

Executive Order 11988 (Floodplain Management) requires each Federal
agency to evaluate the potential effects of its actions on floodplains
and to ensure that its actions minimize the impact of floods on human
safety, health, and welfare.

1.3  USGS RESPONSIBILITIES

In addition to mining barite on private lands, Milchem proposes to mine
on public domain land (territory ceded to the Federal government by the
original thirteen states, together with certain subsequent additions by
cession, treaty, and purchase) and other land acquired by the United
States government pursuant to provisions of the Weeks Law, an Act of
March 1, 1911.   This legislation allows the United States to purchase
land from private ownership for timber production, regulation of the
flow of navigable streams, and other purposes.

The "claim-patent" system for locating and subsequently mining on public
domain land (including public domain lands administered as National

-------
Forest) was established by the U.S. Mining Law, an Act of May 10, 1872,
as amended, and remains in effect today.  Under this system, miners
prospect for marketable ore bodies which, if not subject to prior claim,
are located in approximate 20-acre blocks by the miner who files a
location notice at the nearest county courthouse, a claim with the
                               8A

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                              SECTION 2.0





                            NEED FOR BARITE





The following pages were revised in this section of the DEIS:





     none

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                              SECTION 3.0

                           PROPOSED FACILITY

The following pages were revised in this section of the DEIS:
     24
     29
     34
     36
     43-51
     53

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                                                                       The "PROJECT AREA"
                                                                       boundary shown  on this
                                                                       figure is also shown on
                                                                       most subsequent map
                                                                       figures to assist the
                                                                       reader in comparing
                                                                       maps of  varying scale.
                                                                      AREA
                                                                       .. c ^ -Z-* r^ x -
  MK40URI
                                                                         VICINITY MAP
I OU Kl AMA

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                          13
                               Jm
       '23
                          8
      26
PROJECT

  AREA
      25
30
                    17
16
15
                                                                                                     N
                                                       mm"*"
                                                                                                        22

                                                                            fANCY H/U
                                                                                                    £££2£&:£^:t*£ii£ £•<£•'••*>: 'r/*;''';*^




I — J
1
1
1
1
36




ii •
''''••'- ''•:'•' '.'.'••: •••:"'••" ""I1
::-';.:y-*:::::;-:-;;;:;-':-''':
'•:'•:'••'.•'.•'/.•'• :'••'.•:•' •'•: •':*.*
J4QN'
                                                                                                                          26.
                                                                                                  PROPERTY OWNERSHIP
LEGEND:
          PUBLIC DOMAIN
                     ACQUIRED LANDS, LEASED
                        1 PATENTED AND
                        I UNPATENTED CLAIMS
                        IB UILCHEU INCORPOR/
   I     j ACQUIRED LANDS, UNLEASED   j/M$$( PRIVATE
                                                   MILCHEM INCORPORATED

                                                   PATENTED CLAIMS
                                                                                           FIGURE 3.2.1

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                              TABLE 3.2.1

           SUMMARY OF ESTIMATED MAXIMUM SURFACE DISTURBANCE
Facility Component
Ownership
Area (Acres)
Barite Mine
Processing Plant and
Plant Access Road
Tailings Pond
Containment Basin
Spoil Dump
Plant Area
Section 24
Haul Road
Pipeline Right-of-Way
Construction Office
Warehouse
Sub-total:
TOTAL
Claims
Leased Acquired Land
Private
Private
Private
Private
Public Domain
Claims
Public Domain
Leased Acquired Land
Unleased Acquired Land
Claims
Private
Public Domain
Private
Private
Private
Claims
Leased Acquired Land
Unleased Acquired Land
Public Domain
Private

57
21
21
41
17
33
81
7
5
6
3
6
6
4
5
oi/
9
72
27
3
88
132
322

—   An existing structure will be leased from private owners
    for temporary use.
                                34

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OJ
                                                            TABLE  3.3.1



                                                     REGULATORY AGENCY  PERMITS
Date
Agency
EPA

USFS
USGS
ADPCE^/ - Air Division
Water Division
Environmental
Preservation Division
ASWCC^/
Type of Permit
PSD
NPDES
Special Use
Mine Plan
Air Control
Waste Disposal
Class A Mine
Water Impoundment
ID Number
PSD-AR-144
AR-0038270
None
BLMA 057677
527-A
None
233
None
Filed
8/7/78
3/6/79
8/31/78
1/12/79
8/31/78
10/1/79
5/23/80
4/24/80
Issued
8/7/79



3/13/79

5/23/80


— ' Arlca ncsQ DpnaK-tmont nf Pollution Pontrnl anH Frnlnnu
               -*  Arkansas Soil and Water Conservation Commission

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30-feet not required for long-term access across national forest land
will be restored and revegetated in accord with FS specifications.   In
addition, the Wagner Creek crossing will be replaced with a permanent,
paved concrete slab and pipe suitable to transmit normal stream flow.

3.3.6  Haul Road

The haul road will be a 60 foot, two-lane, gravel surface roadway.  A 60
foot road width is the minimum width judged acceptable in order to
comply with recommendations of the Mining Safety and Health Administration
("MSHA") concerning safe operation of large, off-road haul vehicles.
The road will be constructed primarily by using mine spoil as fill
within a right-of-way of 80 to 120 feet.  All vegetation will be removed
from the right-of-way prior to construction.  The method of clearing,
grubbing, removal, and disposal of vegetation and other non-burnable
debris within the right-of-way across national forest and acquired land
will be as designated by the FS.

Following clearing, the surface will be graded.  Two feet of base material
will be overlain with a crown of six inches of compacted gravel.  Drain-
age ditches and culverts will be installed and other measures taken as
needed to insure that the roadway is protected from erosion.  In addi-
tion, the ditch along the upslope side of the haul road constructed
along the side slope of Fancy Ridge will be of sufficient size to inter-
cept runoff originating on Fancy Ridge during mine construction.  Water
collected in this ditch will be routed to the containment basin prior to
its discharge into the South Fork.

Maximum grade of the roadway will be four percent to allow a maximum
speed of 28 mph by Milchem's proposed 50-ton haul trucks.  Haul road
ramps leading from the pit will have a maximum 10 percent grade.  Sight
distances at curves and road intersections will be sufficient to allow
the safe operation of large off-highway haul vehicles.  Traffic control
signs will be installed at the intersection of the haul road and existing
FS Road 99.
                                43

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Back Valley Creek will be diverted from its natural course in the area
of the eastern mine pit and at several other locations in Back Valley.
In addition to preventing flooding of the eastern pit, this diversion
will also reduce from two to one the number of crossings of the waterway
by the haul road in the pit area.  To the north of the eastern pit, the
road will be routed in such a manner as to minimize the need for additional
stream diversion.  Milchem proposes to install large culverts at all
stream crossings in Back Valley.  Vehicles will not ford streams and no
low water bridges are anticipated in this area.

All disturbed soil surfaces including roadway side-slopes will be restored
in accord with FS recommendations.

3.3.7  Containment Basin

Construction of the basin impoundment will require a period of several
weeks.  After clearing the impoundment site of trees and other vege-
tation, earth fill will be placed.  The fill will be trucked to the site
from the mine pit.  It is expected that the impoundment will not exceed
40 feet in height.  The dam crest will be at elevation 990 feet with a
maximum storage capacity of 134.4 acre-feet.  The interior and exterior
slopes are expected to be about 2:1 and 3:1, respectively.  The exterior
slope will be planted with grass.

3.4  OPERATION SCHEDULE AND PROCEDURES

Mining is scheduled to begin in February of 1981 and plant production in
November 1981.  The facility is expected to operate for 11 years on the
basis of the recoverable reserves identified to-date.

The facility will employ about 135 individuals of which no more than 10
will be permanent Milchem employees transferred to administrative or
management positions in Arkansas.  This group will consist largely of
professional engineers.  The remaining workers will be recruited locally.
Of these, in excess of 70 hourly employees will work at the mine.  These
workers will consist primarily of equipment operators and a maintenance
                                44

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group.  The mine is planned to operate three shifts per day for over-
burden removal and one shift per day for ore removal, based on a 5-day
workweek.  The plant crusher and concentrator will operate two and three
shifts, respectively.  Product will be hauled to Glenwood over two
shifts.  The warehouse will operate with a normal personnel compliment
for two shifts each day.

3.4.1  Mine

The mine will be operated using conventional bench mining techniques.  A
track drill with the capacity to make a six inch hole will be used to
produce holes for explosives.  A mixture of prilled ammonium nitrate and
fuel oil (ANFO) will be used.  Blasting tests during initial production
are planned to test this explosive under field conditions and to deter-
mine the required pattern and hole size for efficient fragmentation and
proper energy distribution and blast frequency.

After fragmentation, a five cubic yard hydraulic hoe operating on an
upper bench will load ore into haul trucks on a lower bench.  Haulage
conditions were simulated by computer in order to determine the need for
seven vehicles.  Milchem is now evaluating the feasibility of operating
a smaller number of larger vehicles.

Milchem now expects to begin mining in the western end of the western
pit and then to proceed easterly.  The exact sequence of mining will,
however, depend on the specific grade of ore revealed as mining pro-
ceeds.  Therefore, it may be necessary to begin mining at another loca-
tion and/or to operate at up to five different levels in all three pits
contemporaneously to provide properly graded material to the plant.  In
any case, mining in each pit will proceed to a level no greater than 500
feet below the outcrop.  The maximum overall pit slopes and bench geometry
will be designed to enhance slope stability from data determined after
an extensive geotechnical program.  Haul roads leading from the pit
areas are designed at a maximum 10 percent grade.  No mining structures
will be constructed on tracts of acquired land.
                                45

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Water entering the mine from precipitation run-off and groundwater'
seepage will run along the mine benches.  Each bench will be sloped back
toward the face of the highwall and in an east-west direction the  length
of the pit.  Water will then drain to central low spots where it will be
collected in a flume or culvert and conducted off the slope.  Water in
the base of the pit will be channeled to sumps and pumped from the mine.

Water from the pit areas will be captured by the Back Valley containment
basin.  Suspended solids in the mine water will be retained in the
basin.  Soda ash or lime will be added as needed to achieve neutral pH.
pH adjustment will also cause certain dissolved ions to precipitate and
to be collected in the basin.

The effluent from the containment basin will be discharged to Back
Valley Creek from which it will enter the South Fork at their confluence
north of the plant site.  The discharge point associated with this site
has been identified as Discharge Number 002 in the NPDES permit  (Appendix
A).  The point of tailings pond discharge is identified as Discharge
Number 001.  These locations are shown on Figure 3.2.2.

Milchem has completed exploratory drilling and determined that there are
approximately 475,000 tons of recoverable reserves on Lease BLMA 057677.
This material will be identified at the mine site by surface boundary
markers separating it from similar reserves on the adjacent patented
claims.  After mining, the ore will be hauled to the plant site where
each truck load will be weighed over certified truck scales before the
material is stockpiled.

Other barite ore on Lease BLMA 057677 contains insufficient BaSO,  to
warrant consideration as "recoverable reserves".  Although these reserves
are not of sufficient quality to be feed ore and Milchem has no plans
for using them, they must be removed from the pit areas and will be
segregated from the other waste to prevent dilution by dumping them in a
separate place, located by ground survey techniques, within the pyritic
spoil dump or a mined-out pit.  This "non-recoverable" tonnage will be
identified in the same manner as the ore and kept discrete from similar
reserves on the patented claims.  This material will not be weighed.
                               46

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The reclamation plan for Fancy Hill will meet the current regulations of
the Arkansas Department of Pollution Control and Ecology Open-Cut Land
Reclamation Act.  The reclamation plan will include spoil pile  recon-
touring and revegetation and be reviewed and approved by the FS.

In the initial  four years of mining, overburden will be taken to one of
the disposal areas.  During the remaining life of the mine, the over-
burden will be spoiled into the mined-out area.  Complete backfilling of
the mined-out portions of the pit on the two BLM lease tracts will be
done in accord with Federal regulations as an integral part of  the
mining operation with concurrent grading as material becomes available.
Grading of backfilled portions of the pit will be consistent with the
surrounding topography with adequate drainage to minimize erosion.  The
past-reclamation land surface will approximate the original surface
shown on Figure 3.3.1.

Water control measures needed to divert Back Valley Creek and the unnamed
tributaries in Back Valley around the east mine pit include two check
dams and man-made channels.

The bottom slope of the trapezoidal diversion channel is a mild 0.005
ft/ft.  At its maximum design depth of 4.5 feet the channel capacity is
600 cfs which is slightly greater than the 100 year discharge.  To
protect the channel against erosion, riprap with a minimum aggregate
size of 4 inches in diameter will be used.  The slightly V-notched
channel bottom will concentrate flow during low flow periods.

The tributary diversion channel empties into Back Valley Creek just
upstream of a large check dam.  During periods of low flow (up to 130
cfs) the check dam will divert flow through a 48" corrugated metal pipe
("CMP") set at 0.26 ft/ft slope.  The culvert will empty into a small
trapezoidal channel that runs along the northeast edge of the haul road
around the east pit.  When the streamflow exceeds 130 cfs (ie., 1.1 year
flood) and the water surface elevation behind the Back Valley check dam
exceeds 928 feet,  water begins to spill across the haul road.
                              47

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A 100 foot wide spillway will be cut through the pre-east pit haul road
at elevation 928.  A small berm on the southwestern edge of the haul
road is designed to allow the water depth over the haul road to reach a
maximum of 2 feet.  Riprap will be necessary for the outside berm.  A
median stone diameter (d™) of 12 inches will be required.

3.4.2  Process Plant

Extensive metallurgical  tests have been accomplished by Milchem and are
currently being evaluated in connection with additional on-site explora-
tory drilling.  However, it is currently anticipated that the process
plant will receive run-of-mine ore on an annual basis of 460,000 short
tons.  This ore will be delivered to a stockpile area adjacent to the
plant.  It will be conveyed to the plant for processing through the cir-
cuits of crushing, grinding, flotation, drying, final storage, and
shipment.  These phases of processing are described in more detail in
the follow sub-sections.

3.4.2a.  Crushing.  It is expected that at least three stockpiles of
run-of-mine ore will be provided, graded according to barite content.

The run-of-mine ore will be blasted at the mine to achieve essentially
-30-inch rock which will be crushed on a two-shift basis utilizing a
front-end loader to blend from the three stockpiles and feed the primary
jaw crusher.  The jaw and cone crushers and vibrating screen are en-
closed in one building.  A "wet" system is planned to suppress dust.

Ore, crushed to minus 3/4 inch, will be stockpiled using a radial stacker,
A three-day supply of plant feed that can be withdrawn from the stockpile
using an underground or tunnel reclaim system will be maintained.  A
bulldozer may be used to move ore from a nominal back-up supply to the
draw points.

3.4.2b.  Grinding.  The grinding circuitry is critical to optimum metal-
lurgy.  Grinding, therefore,  will be completely automated utilizing an
on-line continuous particle size monitor that will measure final product
                                47A

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size.  Closed loop control systems will optimize the circuit, insuring
that properly liberated ore is presented to the flotation circuitry.

Ore will be wet-ground in a two-step rod-ball mill.  The rod mill will
reduce ore from 3/4-inch to nominally -20 mesh without producing an
excessive amount of very fine particles.  The resultant slurry will
report to the ball mill discharge sump, then to a bank of hydrocyclones
designed to classify the ore at around 200 mesh.  The +200 underflow
will report to the ball mill in closed circuit with the hydrocyclones.
The -200 mesh overflow will report directly to flotation.

The flotation circuit will also be designed with the flexibility to
handle middlings (the particles that contain both barite and waste rock
in various ratios) in order to achieve optimum recovery without exceeding
grade or grind specifications.

3.4.2c.  Flotation.  The flotation cycle is the fundamental step of the
barite processing.  This process of barite concentration results from
barite particles in mixture adhering to air and the remaining particles
simultaneously adhering to water.  Adhesion of the particles to air is
caused by the addition of small amounts of reagents.  The mineral-air
associated particles acquire a specific gravity less than that of the
remaining solution and therefore rise, forming a froth.  A mechanical
process then removes the floating froth from the flotation cell and the
product is ready to be dried.  The reagent scheme developed for the
flotation process will function well on dilute feed; therefore, Milchem
proposes no chemical feed thickener and will provide additional flota-
tion cells to insure adequate retention.

The sized, ground ore will first be conditioned with sodium silicate to
disperse and depress slime along with sodium carbonate to adjust pH and
tie up interfering cations that reduce collector effectiveness.  The
collector possesses good selectivity for barite and allows for efficient
cleaning or removal of lower grade middlings.  A small amount of frother
may be necessary to insure good froth character.
                                48

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An on-line continuous X-ray analyzer will provide data on BaSO. content
of the various flows in order to determine product grade and the effi-
ciency of BaSO, recovery.  This data, combined with that received by the
particle size monitor, will be processed in a mini-computer that will be
programmed with the required logic to make decisions in regard to auto-
matically changing the grind conditions and/or the flotation conditions.

3.4.2d.  Drying.  The final flotation concentrate will report to a con-
centrate thickener.  The thickened underflow slurry will be pumped to a
vacuum filtration system.  The thickener overflow water will be recycled
internally as needed.  Filtrate with minor solids will report back to
the thickener.  Filtercake, at about 13-15 percent moisture, will be
conveyed to the two-stage drying cycle.

Wet barite will enter a rotary dryer.  Moisture content will be reduced
to about three percent.  Exiting the rotary unit, the barite will enter
a turbo-dryer to complete the drying process.  Heat will be generated by
burning wood by-product.

The barite product will then be cooled, sampled, and transferred to bulk
storage bins.  Several bins are planned to provide final blending when
required to maintain product specifications.

3.4.2e.  Shipping.  The barite product will be loaded into bulk trucks,
weighed, and transferred to the Glenwood warehouse facility by contract
truckers.  At this location, a bulk storage-surge silo will accept
incoming loads and distribute product to rail car, truck, or to a bag
packing unit.  Warehouse space sufficient for about 2,000 tons of bagged
storage will be provided.

3.4.3  Spoil Areas

Milchem now plans to place spoil from initial mining at the Section 24
location which has been designed to accomodate ten million bank cubic
yards.  This volume will expose a 3,000-foot length of ore to the mine
limits at a proposed depth of 500 feet.  Other spoil material will be
placed into the mined-out area and as fill at the plant site.
                                49

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Spoil areas will be constructed in a conventional manner using haul
trucks and dozers to place the material in lifts approximately 50-100
feet high.  In an effort to keep areas of unreclaimed land minimized,
the side slopes of these lifts will be graded to 3 feet horizontal to 1
foot vertical  and have seeding and topsoil placement occuring as dumping
begins on the next successive level.  This practice will allow maximum
growth time on spoil areas prior to mine abandonment and will provide
soil and slope stability to the material that is supporting the next
dumping level.

Observation roads will be maintained at the toe of each succeeding lift
to provide access on the slope.  These roads will allow fertilizing to
continue during the early years of plant growth and provide access for
observation of the vegetative growth as well as monitoring possible
slope creep.  Terracing also facilitates diversion of water runoff which
prevents the formation of gullys and rills on the slope face.  A cap
will be placed at the top of all spoil areas at the completion of dumping.
The cap will reduce water seepage into the spoil pile.

A water runoff collection structure will be located near the toe of
each spoil area.  It will provide a means for sampling, and if necessary,
treatment of spoil pile runoff and seepage prior to discharge into
surface drainage.

Examination of drill core indicates that two types of spoil will be
encountered.  The first type comprises in excess of 88 percent of the
total amount of waste material not returned to the pits and is derived
mainly from novaculite and sandstone strata.  The second type, about 12
percent of the total, is derived from mineralized shale layers.  The
former contains little or no pyritic minerals.  In contrast, water may
hydrolize sulfide material in the pyrite-bearing shale layers and,
thereby, produce a leachate of poor quality.

Leachate formation is a function of the amount of water allowed to
percolate through the pile of overburden waste.  In order to minimize
the contact of water with mineralized shale, Milchem proposes to segre-
                                 50

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gate this material from the other waste and to deposit it at a special,
16-acre dump site located immediately north of the main Section 24 dump
area.  This dump site has been located near the upper end of the Back
Valley drainage.  As a result of its location, no streamflow over or
around the spoil will occur and water percolating through the spoil will
result predominantly from precipitation infiltration.  In order to
minimize long-term contact of rainwater with the pyritic spoil, Milchem
further proposes to pile the material so that its surface area is reduced
and to overlie the pyritic spoil with an impermeable substance.  This
layer, consisting of clay or a comparable substance, will be deposited
in a continuous process as the overburden is placed on the site to limit
percolation; these activities should reduce the quantity of degraded
leachate to a level significantly less than would result were the two
types of spoil intermixed and the pyritic spoil not sealed.  The disposal
areas will also be contoured to maximize run-off of precipitation.
Revegetation, also an on-going process, will further assist in limiting
the amount of rainfall percolating through these soils.

Topsoil, stripped from each spoil area and stockpiled prior to initiating
overburden removal, will first be replaced atop the recontoured pile.
Vegetative cover will be established with varieties and seeding rates of
species to conform with recommendations of State and Federal agricul-
tural and forestry agencies.  In addition, Milchem will be responsible
for maintenance of the Section 24 dump sites until such time as these
areas contains stocking acceptable to FS and the spoil slopes are
stabilized.

Leachate exiting the Section 24 spoil area will be collected in small
impoundments downslope of the piles prior to discharge into the upper
portion of Back Valley Creek.  Soda ash (sodium carbonate or Na^CO.,)
will be added as needed to neutralize pH.  Suspended solids will also
settle in the pond.  Leachate from the spoil areas as well as run-off
from the raw ore stockpiles and mine drainage will be routed to the Back
Valley containment basin.  This basin will provide additional retention
time for the settling of solids and for pH control by the addition of
more soda ash or comparable substances, as required.
                               51

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Based on estimated infiltration and percolation rates, the flow of
leachate to the containment basin is expected to average less than 30
gpm and to range between 15 gpm and 60 gpm.  Maximum flows are likely to
occur during about the third to sixth years of the mining operation when
the dump sites are approaching their design capacity but before recla-
mation and revegetation are complete.  After this time, flow will probably
recede to the lower end of the range and continue for an indefinite
period.

3.4.4  Tailings Pond and Pipelines

The proposed 41-acre tailings pond is located approximately 4,800 feet
east of the plant location on a 130 acre site.  The tailings pond will
be designed to accomodate tailings disposal proposed for the life of the
project and will be designed to meet current State of Arkansas and
Federal regulations.  The tailings area and the plantsite will be con-
nected by two pipelines.  One line will be used to transport tailings
from the plant to the pond and the other will be for return of feed
water for the plant.

Following initial fill, precipitation will contribute an average net
(i.e., allowing for evaporation) of 25 gpm (gallons per minute) to the
tailings pond.  About 980 gpm will be recirculated to the flotation
circuitry at the processing plant.  An additional 35-60 gpm will be lost
from the tailings area as ground seepage.

As the water cycles through the plant-pond circuit, the concentration of
dissolved solids in the water will slowly increase.  High solids concen-
trations will interfere with the efficiency of BaSO. recovery.  In order
to limit solids concentrations to acceptable levels, a small portion of
the recycle stream must be discharged into the South Fork.  It is cur-
rently planned to conduct this discharge (Discharge Number 001) peri-
odically in consideration of variable river flow rather than on a con-
tinuous basis.  The discharge will average about 15 gpm and will enter
the South Fork via an unnamed intermittent drainage to the east of the
tailings pond.  Final design of the outfall structure has not been
                               52

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completed.  However, the discharge will be conducted in such a manner as
to prevent channel or bank erosion and to achieve oxygenation prior to
its entry into the South Fork.

Effluent discharge, seepage, and evaporation from the pond will be
replaced by drawing water at the rate of about 125 gpm from the con-
tainment basin.   In addition, about 2 gpm of well water will be used for
potable water consumption and in facility showers and toilets.  After
treatment, sanitary waste water will be discharged into the tailings
pond.

The tailings earthdams will be designed to include both inlet and outlet
structures.  A crest roadway and downstream roadway will be provided to
allow surveillance of the dam slopes which will be seeded to control
erosion.  In addition, an emergency spillway structure will be provided
on the northern side of the pond.  The area will be fenced as a safety
precaution to prevent unauthorized persons from entering the site.

The emergency spillway will be capable of passing the 100-year rainfall
event.  After Milchem's abandonment of the area, residual effluent water
in the pond will eventually become diluted by runoff and precipitation.
In addition, the predicted seepage rate at the end of the project's life
will be in excess of the net inflow of water from precipitation and
runoff.  Hence, the pond will slowly dewater.

3.4.5  Containment Basin

The proposed 17-acre containment basin is located on the Back Valley
drainage.  The impoundment will be located about 400 feet upstream of
the confluence of Back Valley Creek and the South Fork of the Caddo
River and will be seeded to control erosion.  The basin will receive
leachate from the controlled overflow of the small collection basins for
spoil areas, mine water, and run-off from the raw ore stockpiles.
Treatment will consist of solids settlement and secondary pH control, as
needed.  The basin will also serve for flood control and as a reservoir
                                53

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of make-up water which wil'l be pumped to the processing plant.   It is
currently estimated that an average of about 125 gpm will be withdrawn
for this purpose.

Prior to Milchem's abandonment of the area, the principal spillway
(described in greater detail in Section 3.4.5b, below) will be sealed.
The emergency spillway will thereafter continue to function as the
primary basin outfall.  This structure, however, has been designed for
the 600-year rainfall event and, therefore, will not require maintenance
to preclude failure unless catastrophic flooding occurs at some  time in
the future.

3.4.5a.  Emergency Spillway.  The SCS Curve Number technique
was used to develop the probably maximum flood  (PMF) for Back Valley
Creek.  The SCS Type II rainfall distribution was used to distribute, in
6-minute increments, the 6-hour probable maximum precipitation (PMP) of
31 inches.  A curve number of 88 was used to reflect a saturated soil
condition throughout the basin (ie., AMC III).  The estimated probable
maximum flood (PMF) peak is 17,400 cfs.  The total volume of the PMF is
approximately 4,000 acre-feet.

When fully developed, the east pit could capture 93 percent of the PMF's
total volume.  Milchem estimates that the east pit volume will be 2,900
acre-feet near the end of mine year seven.  This storage volume would
decrease the PMF peak from 17,400 cfs to 3,000 cfs.

Risk analysis techniques were used to develop the design flood for the
Back Valley Containment Basin.  To be 99% confident that the design
flood will not be exceeded during a 7-year period, a 600-year flood peak
was used.  The 600-year flood peak for Back Valley Creek under saturated
soil conditions is approximately 3,900 cfs.

The basin is equipped with a side channel emergency spillway at elevation
885; its bottom width is approximately 130 feet.  The spillway is designed
to pass 3,900 cfs at an approximate water surface elevation of 989.5
feet.
                              53A

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3.4.5b.  Principal Spillway.  A mathematical model recently developed by
the University of Kentucky called DEPOSITS  (Ward, et al., 1979) was used
to size the principal spillway system for the Back Valley containment
basin.  DEPOSITS  (DEposition Performance Of Sediment In Trap Structures)
is a conceptual model that simulates the sediment transport and deposition
process in a reservoir.  Sediment deposition is a function of the basin
geometry, the inflow hydrograph and sediment loading, the sediment
characteristics, the principal spillway design and the hydraulic behavior
of the flow within the basin.  The model can be used to estimate sediment
trap efficiency once the various design parameters are specified.

Several design objectives were imposed on the sizing of the principal
spillway system.  The three most important  objectives are:

     a.   to pass the 2-year storm through  the principal spillway system
          (i.e., the emergency spillway system will function during
          storms larger than the 2-year event);

     b.   to maximize the effective suspended sediment removal; and

     c.   to provide flow regulation capabilities for storms less than
          2-year return intervals (i.e., provide storage for water
          quality control).

Several principal spillway configurations were tested with the DEPOSITS
model.  The configuration that most satisfactorily achieved the design
objectives utilizes a decant tower with an  operating crest at elevation
875 feet, which corresponds to a reservoir  volume of approximately 13.4
acre-ft.  The reinforced concrete flashboard riser has inside dimensions
of 10 feet square.  An alternative design could be a 42-inch reinforced
concrete pipe (RCCP) cast in the concrete pad (i.e., the bell end would
point downward).  The outlet pipe that will pass through the embankment
is a 42-inch corrugated metal pipe (CMP) set at elevation 865 feet.  The
220-foot pipe will have a slope of 0.24 ft/ft.
                              53B

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A sluice gate will be fabricated on the inlet end of"the 42-inch CMP.
The gate will be used to regulate outflow from the containment basin so
that downstream water quality standards can be achieved.  The containment
basin contains 58.6 acre-feet of storage between elevations 875 and 885.
Under normal antecedent moisture conditions, the containment basin could
completely capture the runoff from a rainfall of 2.55 inches.

3.4.6  Haul Road.  At four locations along Back Valley, stream channel
diversions totalling 2,380 feet will be required to protect the haul
road fill slope and ensure the free flowing nature of the stream.  All
the diversion channels have been designed to safely convey the estimated
100-year flood peak for Back Valley Creek.  These channels will be
trapezoidal shaped with a 2 to 1 cut slope on each side.  The channel
bottom width varies from 20 to 30 feet.  To protect the channels against
severe erosion, riprap with a median stone diameter (d^) of 12 inches
will be used.

Culverting will also be required at two separate locations along the
Back Valley haul road.  The first culvert will consist of three 48-inch
CMP's set at approximately .016 ft/ft slope on 6 foot centers.  The
culvert lengths vary from 520 to 680 feet with the center pipe approximately
620 feet.  The center pipe inlet invert is estimated at elevation 1005
feet and its outlet invert at 995.2 feet.

The three 48-inch CMP's will pass 300 cfs at water surface elevation
1009 feet.  The 100-year flood peak elevation is estimated at 1013 feet.
At water surface elevations greater than 1009 feet, some streamflow will
bypass the culvert along, the toe of the haul road fill.  The culverts
will handle storm flows up to the 2-year event.

The second culvert, of 165 feet, is set at a .008 ft/ft slope with
inlet and outlet inverts estimated at elevation 887.3 and 886 feet
respectively.  The 100-year maximum upstream water surface elevation for
the pre-east pit culvert crossing is estimated at 908.6 feet.
                              53C

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When the east pit is opened, the haul road alignment and elevation will
change and the culvert crossing will have to be modified.  The  diversion
channel around the east pit will have to be wider at the haul road
crossing to accommodate the 120-inch CMP.  Care will be taken in  properly
installing the culvert so that a minimum haul road cover of  30  inches  is
provided along the culvert's length.

Whenever stream flow exceeds 560 cfs, the Back Valley  haul road will
function as a channel and bypass flow around the culvert.  The  combined
culvert and haul road channel is designed to pass the  100-year  peak  post-
east pit flow of 1,430 cfs at an estimated water surface elevation of
902 feet.  This design ensures that the east pit will  not  be flooded by
backwater behind this culvert crossing.

3.5  Health and Safety

Milchem will comply with all Federal, State, and local regulations.

Fencing will encompass the perimeter of the operation  as needed.  All
boundary fences and entrances to the plantsite and minesite  will  be
marked by clearly legible signs displaying mine-property warnings.
Traffic control signs will be installed where required to  assure  safe
vehicle operations at all entrances to Michem's property.

All blasting will be conducted according to MSHA codes.  Ammonium nitrate
will be delivered to the storage area by truck and hauled  from  the
storage area to the blast area by truck.  Primers and  other  blasting
materials will be stored in approved magazines.
                     •
Fuel and other flammable materials will be stored and  transported accor-
ding to regulations and accepted safety procedures.  Temporary  storage
and/or disposal of hazardous wastes will be conducted  in accord with all
applicable regulations.

Haul roads will be designed to accomodate anticipated  traffic patterns
and be provided with traffic control signs as needed.
                               53D

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                              SECTION 4.0

                             ALTERNATIVES

The following pages were revised in this section of the DEIS:
     56-62
     66
     69-71
     73-76

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4.1.Ib.  Spoil Disposal Areas.  Spoil disposal areas receive overburden
from the mine delivered by a fleet of off-highway haul trucks.  The same
trucks also carry run-of-mine ore from the mine to the processing plant.
Unlike tailings, which are transported as a slurry and may be pumped
through a pipeline, ore and overburden must be moved by mechanical
means.  The potential for using conveyors or other devices instead of
trucks for this purpose is discussed elsewhere.

Milchem currently estimates that their truck fleet will consist of seven
vehicles which must constantly be in operation in order to transport the
target quantities of ore and overburden.   It is desirable, therefore, to
locate the processing plant and spoil dumps as close to the active
mining operation as possible in order to minimize transport costs.  In
fact, the cost of purchasing and operating the vehicles is a large
proportion of the mine's overall cost.  Adding significantly to the
preferred haul distances would require purchasing additional trucks.
The cost of these trucks might make the entire operation economically
unsound.

Selection of sites for the disposal of mine spoil is, therefore, par-
tially constrained by the economics of transporting spoil material over
long distances.  At Fancy Hill, the estimated high ratios of overburden
to ore (currently thought to be in excess of 9:1) exacerbate this
problem which is common to selection of an economically suitable pro-
cessing plant site.  Other considerations, however, are also important
and include:

     a.   Federal regulations prohibit siting spoil disposal areas on
          lands included in acquired land mineral leases held by other
          operators without the consent of these operators.  Hence,
          lands included within BLM leases held by Milchem's competitors
          in the area, Baroid and Inco, are unavailable for this use;

     b.   Federal mining regulations discourage the use of undeveloped
          mining claims because deposition of spoil could detract from
                                56

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          the potential to economically exploit the claim's underlying
          mineral resources.  This is not, however, a "rule" or regulation.
          In this case, the environmental benefits with respect to the
          preservation of water quality by developing a separate area
          for the deposition and special treatment of pyritic spoil are
          significant.  They clearly outweigh the cost of later removing
          the spoil from the mining claim should this claim be shown in
          the future to contain recoverable mineral resources.  At the
          present time, Milchem has indicated no intent to mine any
          mineral located on the portion of its mining claims that would
          be covered with spoil;

     c.   Leachate from spoil dumps has the potential to cause adverse
          impact on surface and groundwater supplies.  These areas
          should, therefore, be protected from flooding and sited in
          such a way that they minimize interception and contamination
          of water flowing in natural drainages; and

     d.   Deposition of spoil creates large piles which can alter an
          area's topography and, thereby, present a long-lasting visual
          affect to viewers of a landscape.  Such placement should,
          therefore, be done in order to minimize radical alterations of
          topography by taking maximum advantage of the screening poten-
          tial of natural variations in elevation.

The economic consideration of the cost of purchasing and operating
additional trucks limits Milchem's ability to site a spoil dump or plant
site at distances greater than a radius of about two miles from the
barite deposit on the south side of Fancy Ridge.  For example, economic
analysis indicated that use of a site in Section 21 located about 2.1
miles to the northeast would incur an estimated additional $3.8 million
in capital costs and $4.3 million in operating costs in relation to the
cost of using the two sites in Section 24.  These costs are due largely
to the need to purchase, operate, and maintain a larger fleet of haul
trucks, the added haul road construction and maintenance, the cost of a
bridge across the South Fork, and land acquisition.  The Section 24 site
                              57

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is located less than 0.4 miles from the ore deposit.  Within a radius of
two miles, mineral leases on acquired lands and mining claims effec-
tively reduce the available sites to those on private land and those on
unclaimed public domain land.

Acreage on public domain land was considered.  The public domain land
south and southeast of the proposed mine site that lies within a viable
                              57A

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haul distance is, however, separated from Milchem's operation by mining
claims or the leased acquired lands of other operators.  It is not
advisable to use these properties because Milchem's haul road would
traverse these claims or leases and create a source of potential inter-
ference and conflict with their operations.  Public domain land is
lacking within the required distance north and east of the facility.
Hence, only those lands west or southwest of the probable mine location
were examined in detail.

Section 24 was identified as a suitable location.  In contrast to other
sites which are also located on public domain land, it offers the impor-
tant advantages of minimal haul distance, an upper basin location with
no active drainage flowing through the site, lack of visibility from
public roadways, and desirable topography.  It was, therefore, selected
as Milchem's preferred site.  Milchem has accordingly made application
to the FS for a special use permit authorizing spoil  disposal in this
area.  It should be noted that the FS has recently granted Baroid such a
permit allowing the use of a 15 acre site in the S 1/2 NE 1/4 and N 1/2
SE 1/4 of Section 29, T4S, R26W.  Milchem has proposed no activity
within these quarter-sections and will, therefore, cause no interference
with Baroid's operation of a spoil dump.

Tracts of private land of sufficient size are located to the north of
the western end of Fancy Ridge (Section 13-18), northeast of the eastern
end of Fancy Ridge (one in Section 20-21 and one in Section 21), north-
east of Fancy Hill (Section 27), and southeast of Fancy Hill (Section
27).  These sites are indicated on Figure 4.1.1.  The latter tract was
not examined in detail because it is more than 2.5 miles from the ore
body and would require an uneconomically long haul.  The Section 13-18
tract is sufficiently close for economically feasible use.   However, it
is now traversed by Albert Pike Road (which would require relocation)
and is also inhabited by its owners who are unlikely to agree to sale of
the property and subsequent relocation of their homes.  Hence, the tract
was also eliminated from further consideration.
                               58

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                               ^i^ii^M^ .<2--^
                               ^222.Z2aiL—,
                 CONCEPTUAL ARRANGEMENT PLAN
                       EMANCO Inc.

                 Envimnmtnial Hanafrmem ami Consulting Servicti

-------
The tract in Section 20-21 is owned by two individuals with whom Milchem
has options to purchase.  The eastern portion of the tract will be used
for spoil and also for the benefication plant-and raw ore stockpiles.
Insufficient acreage is available, however, to contain within this tract
the entire quantity of spoil  expected to be generated at Fancy Hill.
Additional acreage is required.

Milchem has similarly purchased the tract in Section 22 and proposes to
locate its tailings disposal  pond thereon.  Because the site possesses
characteristics rendering it highly desirable as a pond site, it was not
given serious consideration as a spoil dump.  Indeed, the distance of
almost three miles separating it from the mine would likely result in
unacceptable cost.  Finally,  Milchem also considered Section 21.  This
site of about 98 acres is located about 2.1 miles from the mine. It was
examined as a potentially suitable alternative to the Section 24 sites
which, as previously noted, are located on public property.

Certain characteristics are common to the Section 21 and Section 24
locations.  They are of no utility in selecting the most desirable.
Other characteristics, however, differ significantly and are summarized
in Table 4.1.1.

Milchem proposes to deposit 10 million bank cubic yards of spoil on the
selected site and to grade the resultant side slopes to a ratio of 3:1
(3 vertical to 1 horizontal).  Because of existing topography in the
area, use of the Section 21 site requires that 10 more surface acres be
disturbed than does use of Section 24 in order to spoil the target
quantity.  Diverting of Wagner Creek and rerouting of the Gap Mountain
Trail would be needed.  The Section 21 site is also relatively flat in
comparison to Section 24.  Hence, the mound of spoil will ultimately
rise about 100 feet above the surrounding terrain, creating a pile
highly visible to passers-by on Highway 240.  Additional surface acreage
in addition to the abovementioned 10 acres would be required to signifi-
cantly reduce the over-all height of this pile.
                                59

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                              TABLE 4.1.1

                COMPARISON OF ALTERNATE SPOIL LOCATIONS
Characterstic
Ownership
Size of area (acres)
Visibility from public
roadway
Proximity to South Fork
Surface drainage condition
Topographic modification
Cultural resources
Haul road length
Economic penalty-'
Traffic hazard
Alternative
Section 24
Public
88
Slightly^/
Distant
( 2.5 mi.)
Excellent
Moderate
Absent
< 1.0 mi.
0
None

Section 21
Private
98
Highly^
Close
(0.25 mi.)
Poor
Extreme
Present-/
> 3.0 mi.
$8.1 million
Moderate

-^Visible only from the dead-end Forest Service access road to
2/Back Valley.
— Visible from Highway 240 if extended from Fancy Hill Corner to
3/mine site.
-'Two archaeological sites lie within the area; additional sites
4/are located immediately adjacent along Wagner Creek.
-'Over the 11-year life of the mine.
                               60

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In contrast, the Section 24 sites lie at the upper portion of Back
Valley drainage, an area now visible only from the Forest Service access
road.  Fancy Ridge screens the site from potential viewers travelling
along Albert Pike Road.  Milchem proposes to initiate non-pyritic spoil
deposition at the crest of the main site's west ridge and to subsequently
dump downslope.  Ridges to the north and south provide natural containment.
The resultant pile, therefore, will not protrude above the ridge crest
but will lie slightly under the crest elevation.  Contouring and revege-
tation will occur as deposition proceeds.  Following revegetation, the
large dump in Section 24 site will appear as a gradual downslope when
viewed from the valley floor as opposed to the typical pile shape which
would result at Section 21.

Leachate or runoff waters from spoil piles will be collected behind a
water control structure and treated prior to deposition; discharge of
this water into the South Fork will have affects which vary insignifi-
cantly from site to site.  However, use of the Section 21 site will
require that spoil-bearing vehicles traverse a bridge across the South
Fork.  Accidental low-level spills of spoil into the river would probably
occur over the life of the mine.  In addition, the river would be directly
impacted by construction of the necessary bridge or culvert crossing.
Finally, trucks hauling spoil to the Section 21 site would also be
required to cross the traffic lanes of Highway 240, creating a potential
safety hazard.

Reconaissance of both the Section 24 and Section 21 locations was conducted
by the Arkansas Archaeological Survey (see Section 5.8) to determine
whether use of these areas would threaten cultural resources.  No archaeo-
logical sites were found within the area to be directly impacted by the
use of Section 24.  In contrast, two apparently undisturbed sites (one
historic and one prehistoric) were located in the center of the Section
21 site.  Several additional sites are found on the edge of the site
along Wagner Creek.  Hence, the potential for disturbing cultural
resources in Section 24 is much less than at the Section 21 site.
                               61

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Based on an evaluation of these considerations, Milchem has applied for
a special use permit from the FS to use Section 24.  The Section 24
location, therefore, appears to offer significant environmental and
economic advantages not possessed by the Section 21 site.  These advan-
tages appear to out-weigh the public policy disadvantages of utilizing
Federal land instead of private land for the intended purpose.

4.1.Ic.  Processing Plant.  Several potentially suitable processing
plant sites exist in the Fancy Hill area in close proximity to the mine.
                                                             *
Most, however, consist of public land.  Milchem elected not to locate
the plant on public lands.  Hence, only sites available on private land
are discussed below.

Alternate locations on private land exist north of the South Fork.  One
site in Section 21 has been discussed in regard to use as a potential
spoil disposal area (see Section 4.1.1b., above).  The plant could also
be placed at this location.  As earlier noted two archaeological sites
were found in the center of this property and additional sites are
located along Wagner Creek at the property edge.  No such cultural
resources exist at the preferred processing plant location.  Utilizing
sites north of the South Fork would also require constructing a major
road crossing of the river.  Accidental, low level spillage of ore into
the South Fork would be likely to occur over the life of the mine as
trucks passed over this crossing.  In addition, such locations would
require an at-grade crossing of both traffic lanes of Highway 240 pre-
senting a long-term hazard to the safety of motorists as well as Milchem's
truck operators.  These sites were, therefore, rejected.

The proposed plant is located in the eastern portion of a large tract of
private land located at the confluence of Back Valley Creek and the
South Fork.  The western portion of this tract is also a potentially
suitable location for the plant.  This site, however, lies at a lower
elevation.  It presents no flood hazard; but the potential exists for
less efficient dispersion of air pollutants in comparison to the eastern
location and for possible channeling of the emissions in the South Fork
valley.
                                62

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Scott Property.  The Scott site is an undeveloped site with no improve-
ments located in a non-industrialized area north of the City of Caddo
Gap.  Haul distance is less than the distance to the Glenwood location.
However, haul route characteristics include a cross traffic turn from
Highway 240 onto Highway 8, traversing of a narrow bridge, counter-flow
turns within the city, and an additional railroad crossing.  In addi-
tion, the site is located immediately adjacent to and, therefore, highly
visible from the highway.  A public school is located nearby.  The site
is flood prone and would require fill to make it acceptable.  Except for
its economic advantage with respect to transportation costs, it offers
no benefits not exceeded by using the Glenwood location.

Norman Site.  Although requiring a haul distance rendering this location
economically non-viable, the site was examined because it was the least
expensive to purchase of any site considered.  In addition, like the
Glenwood site, it is located in an industrial area.

The site, however, lacks other necessary improvements such as sewer and
water.  Trucks travelling to the site would be required to cross two
additional sets of railroad tracks in addition to a railroad spur line.
Other traffic characteristics are similarly less favorable than are
those associated with the Glenwood location.  It also possesses an
existing drainage which would be diverted in order to fill the site and,
thereby, elevate it above the flood zone.  Like the Scott property, this
site affords no advantage not offered by the preferred location.

4.1.If.  Containment Basiji.  The site of the proposed Back Valley Containment
Basin is located on Back Valley Creek near the confluence of Back Valley
Creek and the South Fork of the Caddo River.  Use of this site will
require clearing of vegetation from and subsequent flooding of about
12-13 acres of the Back Valley floodplain.  Portions of the proposed
haul road, tailings pipeline right-of-way, and access road are also
located within the floodplain.  This use of floodplain is unavoidable
because there are no alternate sites which satisfy the design objectives
discussed in Sections 3.3, 3.4 and 4.1 while simultaneously affording
maximum opportunity for sediment control and for storage and controlled
                                66

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release of effluent.  Use of floodplain, therefore, appears to be offset
by the value of the basin and other facilities in assuring maintenance
of superior water quality in the South Fork during and after the opera-
tional life of the facility.

4.1.2  Process and Design Alternatives

4.1.2a.  Mine.  Milchem proposes to mine the Fancy Hill barite deposit
using conventional open-pit, surface-mining techniques to a depth of
             •
about 500 feet.  The only technologically feasible alternative is to
conduct underground mining which would require significantly less surface
disturbance.  Milchem's drilling program and metallurgical tests have
shown that the Fancy Hill barite deposit contains a large amount of
non-recoverable ore which is unsuitable for plant feed based on current
market specifications.
                                66A

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system would also require a right-of-way cleared of vegetation similar
to that of the proposed haul road.  Little benefit with respect to
surface disturbance would accrue.

In designing the haul road, Milchem has established minimum specifi-
cations according to the criteria of the FS "Transportation Engineering
Handbook, Exhibit A:  Minimum Standards, All Weather Roads" published
April, 1971.  In most cases, however, these standards for normal vehicles
are not acceptable for roads to be used by off-highway haul trucks and
were upgraded to reflect the particular operating characteristics of the
special, large, vehicles.  Hence, the design of the roadway is generally
more stringent than alternate designs prescribed by FS.  Less stringent
design alternatives are not acceptable.

The proposed haul road has been located in order to satisfy the fol-
lowing constraints:

     a.   to allow maximum use of the surface area within each mining
          claim for mining;

     b.   to provide multiple access in each pit allowing the removal of
          ore from different levels depending upon the ore grade en-
          countered;

     c.   to minimize the need for surface cuts and maximize the use of
          fill for roadbed construction;

     d.   to minimize crossing and diversion of Back Valley Creek; and

     e.   to utilize topography in providing grades of less than four
          percent, excellent sight distances on curves, and sufficient
          lateral road area for safe operation of oversize vehicles.

As noted elsewhere, Back Valley Creek lies within a relatively narrow,
V-shaped valley.  The Back Valley floodplain is severely restricted
between Back Valley Creek and the base of Fancy Ridge.  Therefore,
                                69

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utilization of the proposed haul road location will unavoidably encroach
on the floodplain requiring the removal of riparian vegetation.  Diversion
of the natural stream channel will also be necessary to protect the
roadbed, prevent long-term erosion,.and preserve the stream's free-flowing
character.  Therefore, although use of the floodplain represents an
adverse impact, there are no alternate road alignments which efficiently
and economically satisfy the requirements discussed above.  In addition
a road cut has been proposed only in the Gap between Fancy Ridge and
Fancy Hill.  Alternate alignments were examined in this road section.
This examination, however, indicated that the cut was necessary in order
to afford the maximum practical level of protection to the creek by
maximizing the horizontal distance between the toe of the slope downhill
from the road and the west bank of the creek.

4.1.2d.  Tailings Transport.  As a slurry, tailings must be transported
via a pipeline; no conveyor system is capable of handling this material
unless it is first dried.  In any case, return water from the tailings
pond must be carried by a pipeline.  The environmental effects of in-
stalling twin pipelines in a common right-of-way are no more severe than
the effects of a single pipeline.  Hence, no alternative to a pipeline
for tailings transport probably exists.

A pipeline laid along the surface of the ground would be advantageous to
Milchem with respect to any future need for direct access for repair or
maintenance.  However, such a pipeline would be unsightly and would
constitute a drainage impediment probably resulting in continuous erosion
at certain points along the right-of-way.  Milchem has, therefore,
alternately proposed to bury the twin pipelines in a common trench over
their entire length.  Manholes to the surface will be provided for
cleaning and repair.

Milchem has also evaluated the alternate of using steel pipe in lieu of
the proposed plastic pipe.  This analysis indicated that steel pipe, in
addition to being more costly to purchase and install, is less resistant
to abrasion than is the plastic type.  Use of high-abrasive resistant
                                70

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material is expected to preclude the periodic surface disturbance neces-
sary in replacing sections of steel pipe which may fail due to wear over
the life of the facility.

4.1.2e.  Ore Processing.  Milchem proposes to process Fancy Hill ore
using a "wet" system designed to separate barite particles from waste
material.  There are no "dry" processes which are technologically avail-
able to accomplish this separation.  For example, dry separation tech-
niques (generally using forced-air/gravity to separate waste from pro-
duct as in wheat winnowing) are now in the experimental stage for coal;
they are, however, applicable only where a high difference in specific
gravity exists between the product and the waste (i.e., coal and pyrite).
They are not applicable to finely divided barite intermixed with waste
of similar density.  Hence, no viable alternate to a froth flotation
system is available.

Milchem originally proposed to secure plant make-up water from a field
of groundwater wells.  Subsequent analysis demonstrated that wells would
be incapable of supplying water in sufficient quantity without inter-
fering with other local users.  In addition, stability analysis indi-
cated the need to dewater the novaculite forming the north wall of the
pit.  This water will be routed to the Back Valley containment basin.
As an alternate to groundwater withdrawal, Milchem proposes to use the
water from the containment basin as make-up water.  This use also reduces
the quantity of discharge.

4.1.2f.  Emission Control.  Milchem originally planned to fuel the
boiler generating heat for the rotary dryer with powdered bituminous
coal containing 0.78 percent sulfur (low-sulfur coal).  Total uncon-
trolled emission of particulate matter, S0?, and NO  resulting from coal
                                          w        A
combustion would equal about 260 tons/year.  As an alternate fuel,
Milchem has evaluated the potential for utilizing wood by-products
purchased from local sources and trucked to the Fancy Hill site.  These
by-products now present a solid waste disposal problem which will be
partially alleviated by this usage.
                                 71

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Wood is an attractive alternate to coal for potentially reducing air
pollutant emissions.  For example, on the basis of emission rates in
pounds of pollutant per ton of fuel consumed, wood emits only about 52
percent, 5 percent, and 67 percent of the amount of particulates, SC^,
and NO , respectively, emitted by coal (Table 4.1.2).
      /\

Off-setting the lower pollutant emission rate of wood combustion is the
lower heat content of the wood fuel.  Wood by-products available to
Milchem are estimated to contain net energy equivalent to about 3500-4000
Btu/pound (7-8 million Btu/ton).  In contrast, coal from Oklahoma's
McAlester seam contains about 24 million Btu/ton, almost three times the
energy content of wood.  As a result, wood must be supplied to the
boiler at about 3-3.5 times the rate of coal in order to supply an
equivalent amount of energy.  Milchem estimates that wood use would
average about 3.4 tons/hour.  Coal would be burned at the rate of 1.0
tons/hour.  Consequently, uncontrolled particulate and NO  emissions are
                                                         A
78 percent and 127 percent greater, respectively, when using wood rather
than coal.

Milchem proposes to utilize a baghouse capable of reducing emissions by
99.8-99.9 percent to control particulates.  No control equipment will be
provided for S02 and NO .  Control of PM is likely to result in total
emissions from wood combustion being greater (i.e., about 42 percent)
than comparable emissions from burning coal.  Significant, however, is a
reduction of 65 percent in S02 emission.  The net effect of Milchem's
selection of wood in preference to coal with respect to overall air
quality is to reduce Milchem's consumption of the allowable "increment"
(see Section 5.7.2) of air pollutant emissions.  Using wood also conserves
the coal which would otherwise be burned and increases coal supplies to
potential users elsewhere who lack a readily available alternate.
Similarly, using the wood eliminates the "scrubber" needed for S02
removal when burning coal.  A scrubber requires substantial capital
investment and maintenance cost and uses additional electrical energy
during operation.  Disposal of sludge generated by scrubbers also creates
a solid waste problem.  Combustion emission data for coal and wood are
summarized in Table 4.1.3.
                                73

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                              TABLE 4.1.3



                   COAL AND WOOD FUEL AIR EMISSIONS
Source:  EPA, 1977.




-^Combustion rate in tons/hour.
                                          Emissions  (tons/year)
Material /Pollutant
Coal 0.0>l/
Particulates
Sulfur dioxide
Nitrogen oxide
Total
Wood (3.4)
Particulates
Sulfur dioxide
Nitrogen oxide
Total
Control led

0.7
37.7
38.3
76.7

0.6
13.0
86. 7
100.3
Uncontrolled

145.8
75.5
38.3
259.6

260.1
13.0
86.7
359.8

                                74

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Other emissions from the Fancy Hill operation include participates from
product drying and bulk rail-car loadout, and fugitive emission.  In its
"Application for Prevention of Significant Deterioration Review" ("PSD"),
Milchem proposed to dry the barite product using a rotary dryer in a
one-step drying process.  Wet barite (i.e., barite containing about
13-15 percent moisture) from the flotation circuit would enter the dryer
and be subjected to high-velocity, forced-air heating.  Dust generated
by this process is estimated to be greater than 40 percent of the 28 ton
per hour throughput.  A low resistance cyclone, wet scrubber, and bag-
house in series would be necessary to capture the barite and, thereby,
reduce particulate emissions to an acceptable level.

As the preferred alternative, Milchem has elected to install a two-stage
dryer.  As originally conceived, wet barite will enter a rotary unit.
Instead of complete drying, however, the barite water content will only
be lowered from about 13-15 percent to about 2-4 percent.  Because the
barite remains "wet", dust is generated in significantly lesser amounts.
However, flash evaporation of moisture at the hot air-barite interface
may result in complete drying of a shallow surface layer.  This layer
will generate dust.  Exhaust air will be routed to a baghouse estimated
to remove 99.9 percent of the barite dust.

Barite leaving the rotary dryer will enter a turbo-dryer.  Hot air
velocity in the turbo-dryer is greatly reduced in comparison to the
rotary unit thereby creating little dust within the completely contained
unit.  Information obtained from a turbo-dryer manufacturer indicates
that dust generation in we11-maintained units is 0.5 percent of throughput,
often requiring no external dust control.  Exhaust from the turbo-dryer
will recirculate to the rotary unit and then to the baghouse.  As a
result, the two-stage dryer is expected to reduce overall dust from in
excess of 40 percent of throughput to about four percent of throughput
(1.1 ton per hour), a reduction of 90 percent.  Only 0.1-0.2 percent of
this dust will escape the baghouse for a net emission of about 13 tons
per year.  No cyclone or scrubber will be required to achieve these
emission rates, thereby lowering the capital and operating cost of the
facility, conserving the energy required to power this ancillary equipment,
and eliminating the scrubber sludge problem.
                              75

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Bulk rail loadout will be accomplished in a semi-enclosed structure with
ventilation hoods operating under suction over the rail cars.  Exhaust
air will be routed to a baghouse.  No feasible alternative exists.
Finally, certain ore handling stages will also generate fugitive dust.
A wet system will be installed in the crusher building for dust sup-
pression.  This system will consist of a series of spray points deliver-
ing a fine mist of liquid at all ore transfer stations.  Water use is
estimated to be two to three gallons per minute.  Control efficiency is
estimated to exceed 99.9 percent.

As an alternate, Milchem considered installing dry dust collectors
operating under negative pressure in the crusher building.  However, dry
dust collectors have been found to achieve best efficiencies when ore is
dry.  Milchem's ore will likely contain moisture which would likely
interfere with operation of the baghouse.  In any case, a dry system is
unlikely to collect dust more efficiently than a wet system in the
crusher building under Fancy Hill conditions.  Because such a system is
also more expensive to install and maintain, it was rejected for use
during ore handling.

Installing a wet system has the added advantage of providing dust suppres-
sion for the crushed ore stockpile.  After exiting the crusher, the
"wet" ore will be piled using a radial stacker.  A chemical surfactant,
such as sodium silicate or a comparable substance, added in small quantity
to the water spray will form a "crust" on the pile as it dries.  This
crust seals the surface of the open stockpile and further retards dust
generation.  The open ore stockpiles, in contrast, consist primarily of
large pieces of broken ore and contain insignificant amounts of fine
particles.  Therefore, no dust control of ore stocks is planned.

Other fugitive dust emissions are associated with vehicular traffic on
the area's unsurfaced roadways.  Routine watering and chemical treatment
of these surfaces is proposed and is the only viable means of dust
control; paving to a specification adequate to support the weight of the
oversize haul vehicles would be economically unsound.

The systems described above are thought to be the best available control
technology.  Control in addition to the preferred alternatives would be
                                76

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                              SECTION 5.0

                   IMPACTS OF THE PROPOSED FACILITY
The following pages were revised in this section of the DEIS:
     90
     95
     97
     103
     113
     116-117
     135
     138-139
     151
     169
     182
     187
     210-211
     213-214
     216-217
     224
     237

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R26W
EXPLANATION
Stanley Formation
Mappable Stanley Sandstone
Arkansas Novaculite
Missouri Mountain Shalt
Bloylock Sandstone
Polk  Cre.k Shale
Big Fork Chert
Barite Bearing Zones
Fault
                                                                          N
                                                                ' ttlf MEA

                                                               INDEX SHOWING MAP AREA
                                                                          MILES
                                                       GENERALIZED GEOLOGIC  MAP OF THE
                                                            FANCY  HILL BARITE  DISTRICT
                                                         FIGURE 5.1.1

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of the shaly groundmass and as veinlets cutting both the groundmass and
the barite.  Calcite occurs as a flooding of the groundmass in place and
also as veinlets before and later than the barite.  A few grains of
sphalerite and copper carbonate have been observed, but no other ore
minerals have been apparent.

5.1.4  Spoil

Spoil at Fancy Hill consists of sandstone and Stanley shale formations
generally downslope of the barite and novaculite upslope.  These features
are discussed in Section 5.1.3.  Soils in the proposed mining area are
discussed in detail in Section 5.3.

Spoil at Fancy Hill exists in large quantity in relation to recoverable
ore.  Currently, Milchem estimates that the ratio of spoil to ore is in
excess of 9:1.  The major topographic impact of operating the facility
is created by the need to dispose of this material in spoil dumps.  This
effect is partially mitigated by Milchem's intent to recontour and
revegetate the spoil piles and to locate the largest spoil area in
Section 24 where it lacks visibility from the area's most heavily travelled
roadway.

5.1.5  Paleontology

To date, no fossils have been found on Fancy Ridge or Fancy Hill, although
a search has been made by Milchem's on-site consulting geologist.  A
continuing effort will be made to locate and identify fossils in the
area of interest.

5.1.6     Geologic Impacts

Proposed mining activities by Milchem will, after reclamation, have only
minimal affect on the area's topography.  Topographic changes, of local
nature, are associated with creation of three spoil disposal dumps, a
tailings disposal pond, and the last-mined portion of any pit which may
not be completely backfilled.
                               95

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recent movement and appears to pose no structural threat.  Although
several faults occur in the vicinity of the two proposed impoundments
forming the tailings pond, none show sign of recent movement.  They also
appear to be tight and not likely to serve as fractures for movement of
water.

Geologic maps compiled by Milchem show a large number of faults crossing
the proposed mine.  Most of these are thought to dip steeper than 80°
and probably do not present serious stability problems.  In a few cases,
however, the faults dip flatter than 70°, or intersect in wedge-type
patterns.  If they dip towards each other flatter than 70°, forming
steeply plunging wedges, they may pose stability problems.  Most frac-
tures in the upper unit of the novaculite have been recemented by silica,
but a few low-angle faults dipping to the south may cause some wall
failure.  Likewise, the intersection of high-angle faults near the face
of the pit's north wall could cause failure if remedial measures are not
taken.  In order to mitigate this potential, unstable wedges will be
identified as the pit is taken down.  All wedges bounded by faults
dipping toward each other at less than 70° and in which the line of
intersection plunges steeper than 30° into the pit will be investigated
and monitored.  On the north wall, all such wedges will be pierced by
horizontal drains.

After mining begins, regular visual inspections on each bench will be
conducted by mine personnel observing slope behavior to detect obvious
signs of instability.  The visual inspection program will include at
least the following:

     a.   check benches and slopes for ravel and buildup of debris;

     b.   check horizontal drains for plugging;

     c.   observe drainage patterns on slopes and benches making sure
          that obstructions to drainage are removed;
                              97

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Soil amendments may be required to create a medium suitable for growth
of several species of grass.  The selection of grasses and pines adaptable
to the specific site conditions is the result of an agreement between
the Forest Service and state agronomy experts.  Following grass stabili-
zation, Short!eaf pine will be planted.  Species, planting periods, and
seed densities which have been recommended are shown in Table 5.3.3.

Spoil  material that is backfilled into open pits will be sloped and
seeded only at the completion of backfilling.  The pits will  be filled
from the crest and, therefore, dumping will continue to bury the previously
exposed slope face throughout the backfilling process.  Backfilled areas
will be reclaimed similarly to the spoil  areas.  The haul road, water
diversion structures, effluent treatment ponds and other earth structures
will be removed.

5.4  LAND USE

5.4.1   Existing Land Use

A broad scale inventory of existing land uses has been published by the
West Central Arkansas Planning and Development District ("WCAPDD") and
includes acreage data and a highly schematized land use map for each
county.  Tables 5.4.1, 5.4.2, and 5.4.3 summarize the percentage share
of each land use in the county, land ownership patterns, and a detailed
land use breakdown for Montgomery and Pike Counties.

Montgomery County has, on both absolute and percentage share bases, the
least land in urban uses in the 10 county WCAPDD region; only 494 acres
or 0.1 percent of its total land area is urbanized.  It also has the
most forest land, 84.6 percent or a total of 437,376 acres.

Montgomery County has the most land in Federal ownership, 62 percent.
It can be characterized, therefore, as rural and largely unpopulated
with little land devoted to residential, commercial or industrial uses.
                                  103

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                              TABLE 5.3.3
                   SPECIES OF VEGETATION RECOMMENDED
                       FOR MINE AREA RECLAMATION
Species
Grasses
  Tall fescue (Ky. 31)
  White clover
  Sericea lastedeza
    (scarified)
  Hairy vetch
  Tall fescue
  Rye grass (annual)
  Sericea lestedeza
    (scarified)
  Hairy vetch
Trees
  Shortleaf pine
Planting Period

  2/15-6/15
  2/15-6/15
  2/15-6/15

  2/15-6/15
  9/1-11/15
  9/1-11/15
  9/1-11/15

  9/1-11/15
Density (Ib/acre)

       41
        5
       25

       10
       45
       10
       35

       15
                           6' x 6' spacing
                                 103A

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CO
                                                                                              DRAINAGE MAP OF THE
                                                                                                 FANCY HILL AREA
                                                                                         FIGURE 5.5.1

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                                                               i\  .
                                                          W  *«F*JS
                                                          Si1-..A  JS**^-
        DESCRIPTION

SOUTH  FORK CADOO  RIVER
DOWNSTREAM  FROM FANCY HILL  }
SOUTH FORK  CADDO RIVER
NEAR  PLANT SITE
BACK VALLEY  CREEK
NEAR MINING AREA
                                         EXISTING DRAINAGE AT MINE SITE
      3iir    MIT


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                              TABLE 5.5.1

              PHYSICAL CHARACTERISTICS OF DRAINAGE BASINS
Location-^     Descrlpiton
   A
South Fork Caddo River
downstream from Fancy
Hill

South Fork Caddo River
adjacent to proposed
processing plant

Back Valley Creek
Drainage
  Area
  (mi2)

  16.4
                                          10.2
                                           2.7
Stream ?/
Length -'
(miles)

  6.9
                5.0
                2.5
Stream ^,
 Slope -'
 (ft/mi)

   55.1
                74.7
                61.3
-    Refer to Figure 5.5.3.

-/  Main channel length measured from location point to the  basin divide.

->  Main channel slope computed from elevations at points  10 percent
    and 85 percent of the distance along the main channel  length.
                                   117

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Examination of drill  core indicates that two types of spoil will be
encountered.  The first type comprises in excess of 88 percent of the
total amount of waste material  not returned to the pits and is derived
mainly from novaculite and sandstone strata.  The second type, about 12
percent of the total, is derived from mineralized shale layers.  The
former contains little or no pyritic minerals.  Water percolating through
the pyrite-free spoil is not likely to become degraded.  Its quality is
expected to be similar to that of the naturally occurring groundwater
(see Table 5.5.14).  In contrast, water may hydro!ize sulfide material
in the pyrite-bearing shale and non-recoverable barite ore and, thereby,
produce a leachate of degraded quality.  This leachate may be acidic and
may contain high concentrations of sulfate and other dissolved solids.

Leachate formation is a function of the amount of water allowed to
percolate through the pile of overburden waste.  In order to minimize
the contact of water with mineralized shale, Milchem proposes to segre-
gate this material from the other waste and to deposit it in a reserved
portion of the Section 24 dump area.  This dump site has been located
near the upper end of the Back Valley drainage.  As a result of its
location, no streamflow over or around the spoil will occur and water
percolating through the spoil will result predominantly from precipi-
tation run-off.   In order to minimize contact of rainwater with the
pyritic spoil, Milchem further proposes to pile the material so that its
surface area is reduced and to overlie the pyritic spoil with an im-
permeable substance.   This layer, consisting of clay or a comparable
substance, will be deposited in a continuous process as the overburden
is placed on the site to limit percolation; these activities should
reduce the quantity of degraded leachate to a level significantly less
than would result were the two types of spoil intermixed and the pyritic
spoil not sealed.  The disposal areas will also be contoured to maximize
run-off of precipitation.  Revegetation, also an on-going process, will
further assist in limiting the amount of rainfall percolating through
these soils.

Leachate exiting the Section 24 spoil area will be collected in a small
impoundment downslope of the pile prior to discharge into the upper
                                 135

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Water entering the mine as precipitation or upslope runoff will be
collected in a sump and pumped to the Back Valley containment basin.
The volume of precipitation is estimated to range from 0 gpm during
periods of dry weather to 2700 gpm during the 24-hour, 20-year maximum
rainfall event.  However, during periods of unusually heavy rainfall,
mine water pumped to the containment basin and eventually discharged
into the South Fork will be limited by the maximum capacity of the mine
dewatering pumps to about 1000 gpm.

Geotechnical studies of pit wall stability have suggested the need to
drain about 200 gpm of artesian water issuing from the novaculite of the
north wall.  The drains will probably consist of horizontally bored
holes installed on each bench and cased with perforated PVC pipe of
appropriate diameter.  An additional 20 gpm to 200 gpm of seepage will
collect from the south, east, and west pit walls.  This water will drain
from the mine benches into a sump and be pumped to the Back Valley
containment basin.  With the exception of suspended solids which will be
removed in the containment basin and pH prior to neutralization, the
quality of the mine water should be similar to natural groundwater.

As noted elsewhere, the mined-out pits may not be completely backfilled
prior to Milchem's abandonment of the area.  Groundwater seepage and
precipitation will continue to collect in the non-backfilled areas,
although runoff will be diverted by the ditch upslope of the north
highwall.  Under conditions of high rainfall, water may overtop the
pit(s) and flow via Back Valley to the containment basin which will
continue to function as a long-term sediment retention structure.

It is not expected that waters contained within the pit(s) will be
chemically degraded.  Long-term acidification will occur only to the
extent that pyritic shale layers are exposed to air and allowed to
oxidize.  Pyritic shales will, however, have been removed from the north
and south walls of the mine pits and completely sealed within the Section
24 pyritic spoil dump.  Only pyrite-bearing layers which might be present
in exposed strata at the pit ends and non-recoverable barite ore spoiled
into one or more pits offer this potential.
                                  138

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As discussed elsewhere, non-recoverable ore will be sealed  in a manner
comparable to the sealing of pyrite-bearing spoil.  Hence,  these  "stored"
ores are not expected to constitute a long term source of degraded
water.  Oxidation of in-situ pyrite materials may be prevented by sealing
the pyrite strata and, thereby, preventing contact of the pyrite with
air.  It should be noted that flooding also precludes air-pyrite contact.
Hence, only pyrite layers above the fluctuating water level may be
expected to contribute to this problem.

Milchem currently expects to complete mining in the western pit by year
six or seven.  Alternate sealing techniques will be evaluated as soon as
mining ceases in the pit.  Milchem will, therefore, have sufficient time
prior to the end of the project to devise a cost-effective  solution to
mitigate this potential effect.

Containment Basin.  As noted, the containment basin, to be  constructed
adjacent to the plant area, will receive leachate from the  controlled
overflow of the small collection basins for spoil areas, mine water, and
run-off from the raw ore stockpiles.  Treatment will consist of solids
settlement and secondary pH control, as needed.  The basin  will also
serve as a reservoir of make-up water which will be pumped  to the processing
plant.  It is currently estimated that an average of about  125 gpm will
be withdrawn for this purpose.

Diversionary structures and controlled withdrawal points will be  incor-
porated to allow maximum operating flexibility for control  of flow
around and through the containment basin.

Sanitary Waste.  Potable water and water for use in plant toilets and
showers will be secured from a groundwater well capable of  producing an
average of 2 gpm.  Sanitary waste will be collected and treated in a
small, package secondary treatment plant.  The disinfected  effluent will
be discharged to the tailings pond for recycle in the benefication
process.  Hence, no direct discharge of either treated or untreated
sanitary waste will occur.
                              138A

-------
Similarly, precipitation, water spilled at the plantsite, and water used
for equipment cleaning, dust suppression, and other purposes at the
plant will be collected in a sump and discharged .into the tailings pond
for recycle.

5.5.1f.  Potential Impact on Surface Uater.  Construction at Fancy Hill
will result in removal of vegetation from substantial acreage.  Areas
denuded of vegetation will be prone to increased soil erosion.  Elevated
levels of sediment will enter the South Fork and sediment deposition on
the streambed will occur during low-flow.

The Universal Soil Loss Equation (USLE) was used to generate eroded
sediment input values and test the sediment trap efficiency of the
containment basin.  An average slope length of 30 feet at 0.5 ft/ft was
assumed.  Based on soils data, the soil credibility factor (K) was
estimated as 0.43.  The annual rainfall factor (R) for the mine site is
350.  The USLE predicts an extremely conservative annual gross soil
erosion of 1,500 tons per disturbed acre.  Actual erosion will likely be
much less.

The USLE assumes that no deposition of soil lost from a surface occurs.
Between the disturbed surface and the point of final deposition (i.e.,
the containment basin), the soil will have numerous opportunities to be
deposited, reducing the sediment yield accordingly.  In order to quantify
the amount of deposition occurring, a sediment delivery ratio must be
estimated.

The sediment delivery ratio is a function of watershed size and topography.
The delivery ratio for Back Valley was estimated to be 0.15.  A maximum
of 15% of the annual  gross soil erosion (approximately 225 tons per
disturbed acre per year) is likely to reach the containment basin.  The
delivery ratio estimate reflects both natural and man-made types of
sediment deposition areas.  For example, the riffle-pool characteristics
of Back Valley Creek will provide some natural deposition.  Small check
dams used to control  leachate from the spoil areas will also provide
deposition.
                               139

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During the initial six months of construction at Fancy Hill less than 80
acres of land will be cleared in order to construct area roadways and
the plant and to open the mine.  Without sediment control such quantities
of eroded soil could increase suspended solids concentration near Location
B in the South Fork by 8,000 ppm to 10,000 ppm for short periods under
average stream-flow conditions.  This concentration exceeds the maximum
naturally occurring concentration of 250 ppm of suspended solids measured
in the Caddo at Glenwood during one storm event.  However, it is not
likely that the above levels will be reached in the South Fork.  The
Back Valley Containment Basin will intercept the flow of sediment-bearing
water resulting from activities in the Back Valley drainage.

The containment basin with the principal spillway design described
earlier will provide excellent suspended sediment settling characteristics.
The basin's length to width ratio of 3.5 greatly exceeds the minimum 2.0
value required for a well-designed sedimentation basin (Ward, et al.,
1979).  The surface withdrawal system ensures that sediment reaching the
reservoir bottom will not be resuspended during minor runoff events.

The DEPOSITS model was used to evaluate the sediment removal characteristics
of the basin.  Sediment trap efficiencies shown in this table are quite
high with an estimated 77.6 percent removal for design storms having
return intervals less than or equal to two years.  Once the emergency
spillway starts to function, the increase in flow turbulence decreases
the trap efficiencies.  In addition, the model run indicates that,
provided the emergency spillway is not used, the basin will settle out
most sediment particles greater than 15 microns in diameter.  Only fine
silts and clays should pass through the basin.

If the estimated annual sediment load is close to the actual value, the
containment basin has enough sediment storage to last approximately 10
years.  However, periodic cleaning may be necessary to maintain the
basin's high performance characteristics.  Sediment removed from the
basin will be deposited in spoil areas.  Under no circumstances should
instream values in the South Fork exceed naturally occurring values due
to Milchem's activities.
                               139A

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                             TABLE  5.5.13

                       PERMEABILITY TEST SUMMARY
                    Depth               Stratigraphic       Permeability
Borehole            (feet)                   Unit             (cm/sec)

                    30 -  40            Middle Member       4.8 x 10"}
MH65                40 -  50                 "              7.8 x 10";
                    50 -  60                 "              2.5 x 10";
                    60 -  70                 "              1.9 x 10"?
                    70 -  80                 "              2.1 x 10";
                    80 -  90                 "              2.7 x 10

MH64                20 -  40            Stanley Shale       1.9 x 10"}
                    40 -  60                 "              9.5 x 10%
                    70 -  90                 "              8.7 x 10"?
                    90-110                 "              1.4 x 10"?
                   164 - 335                 "              2.0 x 10"^

MH63                20-  30            Stanley Shale       6.7x10"!
                    30 -  40                 "              3.5 x 10";
                    40 -  50                 "              5.7 x 10";
                    50-60                 "              5.2 x 10"^

MH62                15 - TOO            Stanley Shale       7.5 x 10"4
                                         (Fractured)

MH61                19 - 100            Stanley Shale       2.8 x 10"4

MH60                16 - 100            Stanley Shale       5.5 x 10"4

MH32                43-  55            Stanley Shale       2.7x10"?
                    97 - 105                 "              5.1 x 10";
                   143 - 155                 "              1.2 x 10"?
                   193 - 205                 "              1.3 x 10":;
                   243 - 255                 "              1.0 x 10"J
                               151

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5.5.4c.  Potential Flood Impacts.  The analysis indicates that the
proposed processing plant will not be endangered by floods on the South
Fork because it is located at an elevation above the elevation attain-
able by the most severe flooding in the basin.  However, there are
several potential  hazards that may endanger mine worker safety and
interrupt mine operations.

Mine worker safety and mine operation may be endangered by the flooding
potential of Back Valley Creek.  This small tributary to the South Fork
(i.e., Location C) drains 2.7 square miles of watershed in which mfne
spoils will be stockpiled.  The barite seam transects the stream and a
mining pit is planned at Location C.  As a result, the flow from both
Back Valley Creek and a small unnamed tributary that joins the creek at
the proposed pit will be diverted.

The estimated combined mean daily discharge of these streams is 5.4 cfs
(refer to Section 5.5.1) which could easily be diverted around the
proposed pit.  However, the higher flood flows will present a problem.
The small, steep Back Valley Creek watershed makes it highly susceptible
to flash floods from short intense thunderstorms.  The probability of a
10 or 25 year flood occurring during the life of the mining operation is
extremely high.  Milchem's pre-construction analysis of the probability
of flood damage to the pit, mine dewatering needs with respect to flood,
and the probability of flood-related shutdown indicates that a flood
with a return interval of 100 years must be used to be 95 percent con-
fident that the design flow will not be exceeded during the 5-year
mining life of the eastern pit.  Thus, the pit water diversion works are
designed to safely pass the 100-year flood peak around the pit.

The combined channel and haul road described in Section 3.4.1 is designed
to carry a maximum flow of 1430 cfs which equals the estimated 100-year
flood for the post mining operation.  The haul road spillway and culvert
is designed to pass 1675 cfs at a water surface elevation of 931 feet
which is equal to the crest of the check dam.  If the check dam is ever
overtopped, the design flow of the diversion channel would have been
exceeded and the east pit would be flooded anyway.
                               169

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There is a 98 percent chance that during the east pit's mining life, the
haul road will serve as a flood channel.  At maximum discharge, the
stream velocity will exceed 8 fps, which should not be a problem for the
excavated channel, but will pose a serious erosion threat to the outside
berm.  This analysis will also be submitted to USGS for review as part
of the final  mine and reclamation plan.

5.6  BIOLOGY

5.6.1  Terrestrial Systems.

According to Bailey (1976), west-central Arkansas lies within the South-
eastern Mixed Forest Ecoregion of the U.S.  Within this area, climate,
                               169A

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       ^
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Generally, laboratory investigations have shown that cold-water trout
fisheries are more susceptible to sediment-induced mortality than are
smallmouth fisheries such as that of the Caddo.  For example, Campbell
(1954) found significant mortality of trout exposed to 1,000-2,500 ppm
suspended sediment for a 20 day period.  Herbert and Merkens (1961)
noted more than 50 percent mortality at levels between 270 and 810 ppm.
In contrast, Wallen (1951) tested sunfish, shiners, and Largemouth bass,
common warm-water fishes.  Minimum suspended solids levels resulting in
fatality of these test organisms ranged from 52,000 to 175,000 ppm over
test periods of 7.6 to 9.0 days.  Behavioral reactions were not observed
until concentrations neared 20,000 ppm.  Maximum concentrations to which
these species were exposed ranged from 150,000 to 200,000 ppm.   It is
unlikely that such levels will ever be experienced in the South Fork.
Hence, the probable direct construction impacts on the non-salmonoid
species found in the area are minimal since these species are likely to
withstand temporary increases in stream turbidity.

In a study of invertebrates in a stream receiving sediment from a rock
quarry, Gammon (1970) found a 25-60 percent reduction in invertebrate
density.  Similarly, Alexander and Hansen (1977) attributed decreased
trout abundance to loss of newly hatched fish rather than adult forms.
Hence, these indirect impacts are likely to be of greater importance in
the South Fork than are direct effects.  However, both of these studies
also demonstrated their temporary nature.  Gammon (ibid.), for example,
found that winter floodwaters removed the abnormal sediment deposits and
fish populations returned to about half of the normal standing crop by
spring.  Alexander and Hansen (ibid.) also commented on the steady
recovery which began as soon as the sediment load decreased.  Hence, the
overall adverse impact of construction activity are likely to be tem-
porary and of acceptable magnitude.  Normal conditions will likely be
resumed after construction has been completed.

The major sources of potential impact on South Fork aquatic life due to
plant operation are chemical discharges and water quality changes.  No
impact due to alteration of the normal temperature regime is expected
                               187

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The site area is often overrun by warm, moist, air from the Gulf of
Mexico, which can lead to severe thunderstorms, accompanied by strong
winds, hail, and occasionally tornadoes.  During the period 1955-1967,
in the one degree latitude-longitude square containing the site, there
were 15 windstorms of 50 knots or greater, 9 hailstorms with three-
quarter inch hail (or greater), and 20 tornadoes reported.  During
spring, hailstorms and tornadoes occur most frequently:  approximately
74 and 56 percent of the yearly totals, respectively.  The estimated
recurrence interval  for a tornado at the site is 906 years.  Little
impact on Milchem's operation at Fancy Hill due to severe weather will
occur.

5.7.2  Air Quality

5.7.2a.  General.  Requirements of the Clean Air Act, as amended, and
ambient air quality regulations enforced by the State of Arkansas were
consulted in order to estimate the impact of major stationary emission
sources.  Dispersion analysis and computer modelling techniques were
utilized with special emphasis on requirements for the Prevention of
Significant Deterioration ("PSD").  New Source Performance Standards
("NSPS") and National Emission Standards for Hazardous Air Pollutants
("NESHAPS") are not applicable to the Fancy Hill operation (Appendix F).
In addition, because National Ambient Air Quality Standards ("NAAQS")
and provisions of the Arkansas Air Pollution Control Code are generally
encompassed by the PSD limitations, attention was focused on the PSD
regulations.  These results with respect to point source emissions from
fuel combustion and product drying were documented in Milchem's
"Application for PSD Review" submitted to EPA, Region VI, on August 7,
1978 (see "Dispersion Analysis for Significant Deterioration Review -
Fancy Hill Barite Mine and Plant", July 31, 1978, an attachment to the
above referenced Application in Appendix G.)

Four modifications to the plant's proposed operation have been made
since the above report was completed producing changes in the estimated
emission rates of all three pollutants of interest, particulate matter
(PM), sulfur dioxide ($6), and nitrogen dioxide
                               210

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The first modification is a substantial increase in the number of assumed
operating hours per year.  The second modification is the use of wood
rather than coal as a combustion source in the drying cycle, thus producing
a significant reduction in the estimated SCL emission rate (see Section
4.1.2f).  The wet scrubber which was formally needed to control SCL
emissions is not required.  However, increase in hours of operation and
deletion of a wet scrubber increased estimated PM emission rates.
Therefore, a fourth modification, adoption of a two-stage drying process,
is planned to reduce PM emissions to levels which do not violate PSD
limitations.  On an annual average basis, these modifications result in
a five-fold increase in NCL emissions, a 46 percent increase in PM
emissions, and a 14 percent decrease in SCL emissions in relation to the
original application for PSD review.

5.7.2b.  Atmospheric Impact of Stationary Sources.  All major emissions
are released from a single source.  The atmospheric impacts (i.e.,
pollutant concentration produced by plant operation) were estimated by
the same methods used in the July 31, 1978 report.  Therefore, only a
brief summary of the analysis is presented herein, and the reader is
referred to Appendix G for a more complete description.  Specific Federal
and state regulations are summarized in Table 5.7.1.

In addition to emissions from the major stationary source, emissions of
particulates associated with product drying, rail-car loadout, and
fugitive emissions from ore and product handling are minor stationary
sources and were not modelled.  Similarly, secondary source and mobile
source emissions were also excluded from the model and are discussed
individually below.

Major Sources.  Estimates of long-term and short-term ground-level con-
centrations of the three criteria pollutants were made using computer
models CRSTER and VALLEY developed by EPA.  Meteorological input data
were from the National Weather Service station at Little Rock, Arkansas
and source parameters were provided by Milchem.  Background air quality
conditions were derived from Arkansas Division of Air Pollution Control
records for Oden, Arkansas.
                                211

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The estimated emission rates for SCL> PM, and N02 together with physical
stack parameters through which the pollutants will be released are
presented in Table 5.7.2.  Since the plant is in operation only 20.6
hours per day and 360 days per year the emission rates vary for the
different time periods of interest.

Existing ambient PM data for a nearby monitor are summarized in Table
5.7.3.  There are no S02 or N02 monitors in the area.  Therefore, values
suggested by EPA in its document entitled "Region 6 Steps to Determine
if Source Sponsored Monitoring is required in a PSD Application" (i.e.,
S02:  20 ugnf3 and N02:  0.01  ppm (18 ugm"3 at 287 m MSL)), were used as
background ambient conditions  at the site.

Table 5.7.4 presents the facilities' estimated impact along with appli-
cable PSD and NAAQS limitations.  For S02> N02 and PM, Table 5.7.4 shows
that both long-term and short-term impacts are expected to be within
regulatory limitations.  Furthermore, the conservative analysis of
impact areas for the facility, showing the S02> N02 and PM levels inter-
preted as representing the minimum amount of impact that is significant
would be limited to a distance of approximately 4.4 miles, suggests that
the impact on the Class I Caney Creek Wilderness Area, at a distance of
approximatley 13.7 miles (see  Figure 1 of Appendix G), will be insig-
nificant.

Minor Sources.  Bulk rail loadout will be accomplished in a semi-en-
closed structure with ventilation hoods over the rail cars; exhaust air
enters a baghouse.  Assuming two pounds of residual dust per rail car
and 8 car loads per day results in an emission of less than three tons
of particulates per year.  These emissions do not occur at the mine and
processing plant site.  Rail car loadout occurs at the Glenwood warehouse.

Fugitive emissions of particulates will also occur due to the handling
and storage of ore and product.  Ore stockpiles are assumed to contain
at least three percent moisture and little soil.  Dust generation from
these piles will be insignificant.  A "wet" system in the crusher building
                                213

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                              TABLE 5.7.2

        PHYSICAL PARAMETERS AND EMISSION RATES - PRODUCT DRYER
                   FANCY HILL BARITE MINE AND PLANT
UTM Coordinates



Stack Height (m)

Inside Diameter (m)

Exit Velocity (m/s)

Exit Temperature (C)
Emission
Rates (g/s)

S02

PM

N00
Annual
Average

 0.643

 0.440

 4.284
                                                    Zone 15
                                                    3804. N
                                                    427.E

                                                    15.24

                                                     0.91

                                                    11.18

                                                   187.78
                                        24-Hour -'
                                        Maximum

                                         0.652

                                         0.446

                                         4.344
                                                            3-Hour -
                                                            Maximum

                                                             0.759

                                                             0.520

                                                             5.059
•"   To get 24-hour and 3-hour maximum emission rates, multiply annual'
    average value by 365 day ; 360 day = 1.014 and (24 hr x 365 day)
    I (20.6 hr x 360 day) = 1.181, respectively.
                               214

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                              TABLE 5.7.4

                        	   3UND-LEVEL CC
                      AND REGULATORY LIMITAT TUNS
ESTIMATED MAXIMUM GROUND-LEVEL CONCENTRATIONS (uqnT3)
Pollutant                     Annual         24-Hour-/      3-Hour^/
S02 Concentration
PS[£/ Class II Increment
Plant's Maximum Estimated
NAAQS-/ (PSD Ceiling)
Plant & Background^/
PM Concentration
PSD Class II Increment
Plant's Maximum Estimated
NAAQS (PSD Ceiling)
Plant & Background
N(L Concentration
PSD Class II Increment
Plant's Maximum Estimated
NAAQS (PSD Ceiling)
Plant & Background
20
11
80
31
19
8
60
38
N/S
74
100
92
91
43
365
63
37
29
150
133
N/S
—
N/S
—
512
339
1,300
359
N/S^/

N/S
—
N/S
—
N/S
—

-/  Estimated concentrations for short-term periods (i.e., 24-hours
    or less) are the highest second-highest for the year.

-/  Prevention of Significant Deterioration.

-/  National Ambient Air Quality Standard.

-*  Background concentrations were determined by averaging annual data
    from ADAPC monitoring site (see Table 5.7.3), or as specified by
    EPA, Region 6 (see text).

-/  No standard is applicable to this pollutant/averaging time.
                                 216

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will afford dust suppression to crushed ore stockpiles as well (see
Section 4.1.2f).  Less than 10 tons per year of particulates will be
emitted from the stockpiles.  Finally, product will be loaded into
trucks within a semi-enclosed structure similar to the ventilation hood
installed at the warehouse; a baghouse will filter particulates from
exhaust air.  About one pound per hour (1.5 tons per year) of residual
particulates are expected.

Secondary impacts from stationary sources are caused primarily by the
use of fuel in residential space heaters.  As noted elsewhere, it is
expected that permanent growth attributable to the Fancy Hill facility
will number about 10 households.  Construction workers will occupy a
maximum of 125 units for a temporary period of six months.  Assuming, as
the worst case, that all live in individual, detached dwellings would
require the consumption of fuel with the heat equivalent of about 8.3
million cubic feet of natural gas during the construction period and
about 1.3 million cubic feet per year during the period of operation.
Particulates, S02, and NOX would be emitted at the rate of about 20
pounds, 0.6 pounds, and 80 pounds per million cubic feet of natural gas
burned, respectively (EPA, 1977). Total emissions during the construc-
tion period would be 166 pounds of particulates, 5.0 pounds of S02, and
664 pounds of NO .  Emissions during the operating period would total
                J\
about 26 pounds, 0.8 pounds, and 104 pounds of these substances per
year.  These quantities are negligible.

Milchem also proposes to equip the Fancy Hill facility with a 200 kW-
rated diesel generator to be used for emergency power.  This unit will
operate only when the usual supply of electricity is interrupted.
Hence, its contribution to air emissions will also be negligible.

5.7.2c.  Impacts of Mobile Sources.  Mobile sources include employee and
service vehicles (such as vendor and delivery trucks), off-highway haul
trucks and mining equipment, vehicles such as an explosives truck and
water truck used intermittently to support the mining operation and for
general maintenance and equipment transport, contract haul trucks de-
livering product to Glenwood and wood fuel to Fancy Hill, and mobile
generators on pumps and light towers used for night operation.
                                217

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program includes controlled surface collection and test excavation of
seven sites recommended for testing by AAS.  These seven sites are
representative of a wide range of behavioral patterns and are well
suited to provide information pertinent to the archaeological record of
the eastern Ouachitas.  The results of the testing program indicate that
no further significant data can be expected to be retrieved; the sites
are, therefore, judged to be insignificant.  By letter dated March 14,
1980, the AAS concurred with this determination.

Cultural resources may exist at Fancy Hill underlying surface soils and
lacking surficial expression.  The potential for uncovering such sites
in the mine area is probably very low due to steep slopes and the very
shallow to non-existant soil layer overlying bedrock.  In addition, the
entire tailings area was subjected to extensive subsurface sampling and
surface soil agitation during the archaeological testing and evaluation
program.  Despite similarly intensive coverage of other impact areas,
buried sites may have been overlooked in such areas as the Section 24
spoil dumps and at the processing plant site.  A potential, therefore,
exists for uncovering previously undetected sites during Milchem's site
preparation and construction activities.

However, in order to protect any archaeological resources that may be
uncovered during mining, the NPDES permit has been conditioned to require
Milchem to halt construction if archaeological resources are uncovered
and to notify the State Archaeologist for a determination of significance.
If there are resources determined eligible for listing on the National
Register, EPA in consultation with the ASHPO, will request comments from
the Advisory Council on Historic Preservation in accordance with their
procedures (36 CFR 800).

The National Register of Historic Places (Federal Register 44(26):
7424-7427) has been consulted to determine the location of any listed
properties in the vicinity of Fancy Hill.  Twenty-two listings occur in
Montgomery, Pike, Garland, Hot Spring, Clark, and Polk Counties.  Their
locations are shown on Figure 5.8.1.  None will be affected by any
development associated with the Fancy Hill project.  By letter dated
                              224

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April 16, 1980, the ASHPO agreed that no properties or sites which are
on or eligible for the National Register will be affected by this mining
development.

5.9  SOCIOECONOMICS

The major economic impact of the Fancy Hill facility will be in a six-
county region of western Arkansas.  The area will supply a sizeable
labor force, as well as communities suitable for relocating workers.
The impact region is derived from the labor supply area; an explanation
is provided in Section 5.9.3 which also discusses the facility's impact
on community services.

The six county impact area can be broken down into primary and secondary
areas, based on size, labor supply, and proximity to the facility.
These factors, coupled with road access and commutation figures, indi-
cate that Montgomery, Pike, and Garland Counties comprise primary impact
area.

5.9.1  Population

The 146,280 people residing in the impact area comprise 7 percent of the
State population, with 56.2 percent residing in the primary area and
43.8 percent in the secondary.  The communities range in size from the
                              224A

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                             TABLE 5.9.6

               VACANT AVAILABLE STANDARD HOUSING UNITS^
County
Montgomery
Pi ke 9 ,
Garland^/
Sub-Total :
Hot Spring
Clark
Total
Renter Units
38
74
950
Primary Area 1,062
105
82
1.249
Owner Units
20
13
209
242
31
22
295

Source:   West Central Arkansas Planning and Development District.
          1978.  Draft report on housing conditions.  Hot Springs,
          October.

->   Sub-standard units have been excluded.

•=/  Three managerial employees already assigned to the Fancy Hill facility
    have bought existing houses near Hot Springs.
                                237

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                              SECTION 6.0





             UNAVOIDABLE IMPACTS AND RESOURCE COMMITMENTS





The following pages were revised in this section of the DEIS:





     none

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                              SECTION 7.0





                             COORDINATION





The following pages were revised in this section of the DEIS:





     257

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                              SECTION 7.0

                             COORDINATION

7.1  PUBLIC PARTICIPATION

Responses to EPA's Notice of Intent distributed on October 5, 1978 were
received from the following:

     Advisory Council on Historic Preservation
     Arkansas State Archaeologist
     Arkansas State Historic Preservation Officer
     Arkansas Industrial Development Commission
     Arkansas Game and Fish Commission

Copies of these letters are included in Appendix G.

7.2  EIS CONTRIBUTORS

The Draft and Final EISs were prepared for EPA and USGS by EMANCO Inc.
of Houston, Texas.  Shown in Table 7.1.1 are the individuals who researched
the literature, prepared background reports, conducted field studies or
reconnaissance visits, performed consultation, prepared or reviewed
drafts of specific sections, or otherwise contributed to the task of
compiling the EIS.  Resumes describing the educational background and
professional credentials of these persons are on file at EMANCO Inc.,
Houston, Texas.

Personnel of EPA, Region VI who participated in the review of the EIS
prior to public distribution were Mr. Clinton B. Spotts, Mr. Norman
Thomas, Mr. Paul Bergstrom, Ms. Darlene Owsley, and Mr. Walt Simmons.
Mr. Edward Pickering of USGS, National Center, also participated in this
review.  EPA and USGS are responsible for the content and conclusions
contained in this document.
                              257

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7.3  REVIEW OF DRAFT EIS

The Draft EIS was distributed to the public for review and comment on
January 24, 1980.  The official 45-day review period commenced on February  1,
1980, when EPA's Office of Environmental Review published a notice of
their receipt of the document in the Federal Register.  The review
period expired on March 17, 1980.

EPA held a public hearing on the proposed NPDES permit and Draft EIS.
Input received during the comment period and at the public hearing and
our responses to those comments are presented below.

7.3.1  Comment Letters

The comment letters received during the DEIS review period and our
responses thereto are presented on the following pages.

7.3.2  Public Hearing

The public hearing on the Draft Environmental Inpact Statement for the
Fancy Hill (Milchem) Barite Mine and Processing Plant, Montgomery County,
Arkansas was held at the Montgomery County Courthouse, Mount  Ida, Arkansas
on Tuesday, March 18, 1980 at 7:00 p.m.  The proceedings of the hearing
were recorded by a professional stenographic service.  Mr. Jeff Gorman,
EPA, Dallas, Texas, served as the Presiding Officer of the hearing.
Others representing EPA were Mr. Philip Haag, Ms. Darlene Owsley, Mr.
Fred Humke, and Ms. Mary Callahan.  According to an article printed on
March 19, 1980 in the Arkansas Gazette, the hearing was attended by a
total of about 90 persons.

Mr. Gorman opened the hearing with introductory remarks which included
introduction of other EPA personnel and brief discussion of the procedures
to be followed during the hearing.  Following Mr. Gorman, Mr. Haag
briefly discussed the NPDES permit program and the requirement that an
EIS be prepared in order to comply with NEPA.  He explained that the
hearing was scheduled in order to allow concerned members of  the public
to comment on the proposed permit as well as the EIS.
                              257A

-------
Ms. Owsley summarized the EIS preparation process, noting that USGS
participated as co-author and that USFS participated as a cooperating
agency.

Mr. Humke, who prepared the proposed NPDES permit, discussed the permit
preparation process and summarized the effluent limitations contained
within the permit.  Following Mr. Humke's presentation, hearing attendees
were invited by Mr. Gorman to speak.  Their comments are summarized
below.

Mr. Ken Carl ton, representing the Montgomery County Chamber of Commerce,
Mr. Ricky Pilkington, representing Mr. Jim Alexander of the Arkansas
Department of Economic Development, Mr. Bobby Whisenhunt, representing
the Montgomery County Quorum Court, Mr. Carl Smith, Mr. Hal Goodner,
representing Honorable Ode Maddox of the Arkansas House of Representatives,
Mr. Gene Newsom, Mr. Pete Smith, representing the Arkansas Chapter of
Associated General Contractors of America, and Mr. Paul Roeber spoke in
support of Milchem's proposed project.  These speakers generally cited
the employment opportunities offered by Milchem and the potential for
economic benefit to the area.  Mr. Whisenhunt noted the apparent importance
of the project in the nation's energy self-dependence.  Mr. Pilkington
and Mr. Smith noted Milchem's comprehensive environmental planning.  Mr.
Newsom, an employee of the Arkansas Department of Pollution Control and
Ecology, cited Milchem's "extreme professional skills" in supplying the
Department with technical information in support of State permit
applications.

No responses to any of the above speakers are required.  Mr. Alexander's
letter, read into the record of the hearing by Mr. Pilkington, is also
reprinted in Section 7.3.1 of the FEIS as Comment Letter No. 7.

Mr. Paul Means spoke on behalf of the Pulaski County Chapter of the
Ozark Society.  After briefly describing his organization, he noted some
"deficiencies" in the DEIS.  Each is discussed individually below.
                              257B

-------
Impact on Smallmouth Fisheries.  Mr. Mean's comments are essentially
similar to those of Comment Letter No. 14.  See our responses F, G, and
H to Comment Letter No. 14.

Impact on Unique Aquatic Biota.  The discussion of the potential impact
on aquatic fauna of facility construction and operation in the DEIS (pp.
186-191) applies to the Caddo madtom as well as to other species.   In
addition, page 207 of the DEIS notes that Milchem's operations at  Fancy
Hill threaten the continued existence of no rare, threatened, or
endangered species of animal or plant.

Post-Abandonment Impacts.  Mr. Mean's remarks are essentially similar  to
Comment J of Comment Letter No. 13.  See our response to this comment.

Long-Term Acid Mine Drainage.  The DEIS text (pp. 138-138A) has been
revised to provide additional detail concerning the potential for  long-
term acid drainage.

Spoil Bank Revegetation.  See Response C to Comment Letter No. 13.

Quantity of Spoil.  The DEIS clearly notes (pg. 50) that the Section 24
spoil area (shown on DEIS Figure 3.2.2, pg. 31) will contain 10 million
bank cubic yards.

Long-Term Haul Road Maintenance.  The DEIS text (p. 103) has been  revised
to note that the haul road will eventually be removed and the area
restored to preclude longterm erosion.

Long-Term Maintenance of Impoundment Structures.  See Response J to
Comment Letter No. 13 and Responses A, B, C, and N to Comment Letter
No. 14.

Removal of Impoundment Structures.  Milchem has indicated no plan  to
remove the dams.
                             257C

-------
The final speaker was Mr. David Criner, an employee of the Department of
Pollution Control and Ecology.  Mr. Criner requested that a description
of the final closure of the mine and site monitoring and restoration
after Milchem's abandonment of the area be provided.  Mr. Criner's
remarks are essentially similar to those in Comment Letter No. 13.  See
our Response J to that letter.

Following Mr. Criner's presentation, Mr. Gorman noted that the hearing
record would remain open until March 15, 1980 to allow receipt by EPA of
additional questions or comments.  Mr. Gorman then concluded the proceedings,
No additional questions or comments were received.
                             257D

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                                                       COMMENT LETTER NO. 1
                       DEPARTMENT OF THE ARMY
               VICKSBURG DISTRICT. CORPS OF ENGINEERS
                                                                                                                   Response to Comment Letter No. 1
LMKPD-q
Mr. Clinton B.  Spotcs
Regional EIS Coordinator
Environmental Protection Agency
Region VI
1201 Elm Street
First International Building
Dallas, Texas  75270
                                                       12 February 1980
                                                                                                   Department of the Army
                                                                                                   Vlcksburg District
                                                                                                   Corps of Engineers
                                                                                                   12 February 1980

                                                                                                        No response needed.
                                                             , OlV-
Dear Mr. Spotts:

I refer to the U. S. Environmental Protection Agency, Regional VI,
notice, dated Ik January 1980, requesting comments on the Draft En-
vironmental Impact Statement (DEIS) for the Fancy Hill (Hllchem) Barite
Mine and Processing Plant, Montgomery County, Arkansas.

We have reviewed the DEIS and find that It adequately evaluates the
Impact of the proposed barlte mine and processing facility.  This work
will not affect any Corps of Engineers project.

The Vlcksburg District has no further comments other than those provided
In our letter of 22 June 1979 to Mr. Don Mann, Project Engineer, which
is contained in Appendix D of the DEIS.

Thank you for the opportunity to review and comment on this document.

                                   Sincerely,
                                   V. C. AHLRICH
                                   Chief, Planning Division

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                                                                COMMENT LETTER NO.  2
           IT ARKANSAS HISTORIC PRESERVATION
I Suite 500. Contmentol Building • MaiWiom and Main- Little Rock. Artcansos 722i
      February  13, 1980
      Mr. Clinton B. Spotts
      Regional EIS Coordinator
      EPA, Region 6
      1201 Elm Street
      First International Building
      Dallas. Texas  75270
      Dear Mr. Spotts:
ro
en
~n
                                                             ^....^
                                                               •'          mere (JO-i;
                                              Re:  EIS. Fancy Hill  (Milchem)
                                                   Barite Mine and  Processing Plant
                                                   Montgomery County
         Thank you for submitting the above cited document to  this office  for  review
         and comment.  Our Montgomery County Historic Resources  Inventory  contains
         no properties in the immediate area of the proposed mine and processing  plant.
         It should be pointed out that the Albert Pike homestead is located  in the
         general vicinity of the project area (see enclosed information).  However.
         it should be noted that the site Is not in the present project area.   For
         your Information, the community of Caddo Gap in Montgomery County has several
         properties which may have historical significance.
      The Arkansas Archeological Survey is responsible for the review of federal
      initiatives for their impact on archeological properties.  It is our under-
      standing that a private archeological firm is presently compiling the results
      of its survey in the area.

      If the survey of the area identifies potentially historic properties in this
      area, this office will evaluate the findings and make the appropriate response
      either concurring or not concurring.
      If we can be of further assistance, please let us know.
      Joan (Williams Baldridge'
      StateVHistoric Preservation Officer

      JWB/FK/kt
                                                                                                                             Response to Comment letter  Ho.  2
Arkansas Historic Preservation Program
February 13. 1980

A.   A reconnaissance survey of the project area for the purpose of
     identifying any cultural resources potentially Impacted by the
     proposed project was conducted by the Arkansas Archeological Survey
     ("AAS") in 1978.  A report prepared by AAS notes no historical site
     of potential significance, although further testing and evaluation
     of seven archaeological sites 1s recommended In the AAS report.


     The test and evaluation program was subsequently undertaken by New
     World Research, Inc. ("NWR") of Pollack, Louisiana, a private cul-
     tural resources consulting firm.  NWR's report entitled "Archaeological

     Testing at Seven Sites In the Fancy Hill Area. Montgomery County.
     Arkansas" has been reviewed by the State Archaeologist (see Comment
     Letter No. 4).  The State Archaeologist has concurred with the
     finding of NWR that no further archaeological work  1s required.
                           A Oivhion of lh« D«portm«nl ol Notufol & Cultural Hirilog*

                                   An Equal Opportunity Employer

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                                                                    COMMENT  LETTER  NO.  3
                     ARKANSAS  ARCHEOLOGICAX  SURVEY
PO
CD
CD
       Director • Charles R. McGlmiey III
       Stale Archeologist • Hester A. Davis
                                                       Coordinating Office
                                                       University of Arkansas Museum
                                                       Fayetteville. Arkansas 12701
                                                       Phone: M1-S7S-IU*
                                                                  February 21,  1980
           Mr. Clinton B. Spotts
           Environmental Protection Agency
           1201 Elm Street
           First International  Bank
           Dallas, TX   75270

           Re:  Draft Environmental Impact Statement for Fancy Hill  (Milchem)
                Barlte Mine  and*Processing Plant

           Dear Mr. Spotts:
                According  to section 5.8  Archaeology and History of  the Environmental
            Impact Statement, Milchem has had a testing program conducted to determine
            whether   seven  sites are significant and eligible  for the  National Register.
            The  Environmental Impact Statement goes on to say  that it  was determined
            that the  sites  are not significant and that no further work will be necessary.
            I  cannot  concur with this conclusion without reviewing the report where
            these  conclusions are reached.
                                                                                                                                Response  to  Comment  Letter No.  3
                                                                                                    Arkansas  Archeologlcal  Survey
                                                                                                    February  21.  1980

                                                                                                    A.    The  referenced report was  provided to AAS In February, 1980; con-
                                                                                                         currence with  EPA's  determination 1s contained In Comment Letter
                                                                                                         No.  4.

                                                                                                    B.    The  text of the DEIS (p.  224) has been revised to Indicate that
                                                                                                         mining and  construction activities at Fancy Hill provide the remote
                                                                                                         possibility of revealing previously undiscovered archaeological
                                                                                                         resources.   Should such an event occur, project personnel will stop
                                                                                                         work and notify the  State  Archaeologist for a determination of
                                                                                                         significance.   Additional  procedures to be followed are also
                                                                                                         discussed on Page  224 of the EIS.
     The Environmental  Impact  Statement  makes  no mention of the possibility
that previously undetected archeological resources could be uncovered by
                     A  statement of  this possibility and of the procedures
            tne mining project.  	
            to be followed In the event that.it occurs  should  be  Included in the
            Environmental Impact Statement.  Project personnel should be advised to
            notify the State Archeologist immediately if  archeological materials are
            uncovered so that an evaluation of their significance can be made and
            recommendations as to their disposition be  given.
                                                            Sincerely,
                                                           ' Hester A. Davis
                                                            State Archeologist
            HAD/lcm
            cc:   State Planning and  Development  Clearinghouse
                 State Historic Preservation Officer
                 EMAN^O, Inc.'.
                 Ann Early
                              Th* University of A/Konioi il on Equal Opportunity Employtr

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                                                                    COMMENT LETTER NO. 4
                      ARKANSAS  ARCHEOLOGICAL  SURVEY
   PO
   cn
®
        Director • Charles R. McC.lmsey III
        Suit Archeologifl • Hester A. Davit
          Mr. Clinton B. Spotts
          Environmental Protection Agency
          1201 Elm Street
          First International Bank
          Dallas, TX   75270
Coordinating Office
University of Arkansas Museum
Fayelleville. Arkansas 12101

March 14, 1980
          Re:
               Draft Environmental  Impact  Statement  for Fancy Hill (Milchem)^/^-,
               Barite Mine and Processing  Plant                              '"•«.<>
Dear Mr. Spotts:

     1 have reviewed the report by New World  Research of the testing of
seven archeological sites in  the proposed  Fancy Hill barite mining area.
On the basis of the report, I believe the  sites have been adequately tested,
and as a result, significant  archeological data have been recovered.  1
concur with the conclusions that the development of the barite resource
should be permitted to proceed in  the areas of these sites.  I also concur
with the recommendation that  if the current project is modified and additional
impact areas are identified,  the impact  to other archeological sites should
be evaluated.

   .  According to the Environmental Impact Statement, three mine pits, three
spoil piles, and a tailings pond will create  long-term alterations of the
local topography.  These operations will destroy any archeological sites
which may be present and preclude  future study of them for all time—a
permanent loss of our natural heritage.  The  known sites in the project
area have been evaluated, seven of them  have  been tested, it has been
determined that adequate Information has been obtained from them, and no further
archeological work is required on  them.
                                                                                                                      Response  to  Comment Letter Ho.  4
                                                                                                                AAS
                                                                                                                March  14,  1980

                                                                                                                A.   See Response  B  to Comment Letter No.  3.
                                               B.    The  report by Martin documenting results of the AAS 1978 field
                                                    reconnaissance  Is currently 1n the process of being extensively
                                                    revised,  and 1s expected to be released for distribution by AAS In
                                                    the  near  future.  Similarly, NWR's report on the test and evaluation
                                                    program was not available at the time the DEIS was prepared for
                                                    public  distribution.  NWR's preliminary findings concerning the
                                                    lack of archaeological  significance of the tested sites were,
                                                    however,  briefly mentioned In the DEIS.
     Archeological sites, which occur  in  or under the ground surface, are
often undetected.  As mentioned in my  letter of February 21, the Environmental
Impact Statement should make note of the  possibility that a site c'ould be
encountered during the mining  excavations and outline the procedures to be
followed.
               Section 5.8, Archaeology and  History,  is a rather muddled account
          of the work that has been completed  In preparation for the Fancy Hill
 B)
                              I fit On i stilly ol Arkansas is **» eoutf OPCMMIumiV' aUi"n<*li*e J

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      (Spotts, C.)
                                          -2-
                                                                     3-14-80
      barice mine.  References do not include Martin's report of the 1978
      archeological work or Hew World Research's report of the testing of
      seven sites.
                                                      Hester A.  Davis
                                                      State Archeologist
      HAD/1cm
      cc:  State Planning and Development Clearinghouse
           State Historic Preservation Officer
           New World Research
           Ann Early
ro
tn

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                                              COMMENT LETTER HO.  5
   AMERICAN INSTITUTE OF MINING £c METALLURGICAL ENGINEERS

                     ARKANSAS SECTION                 ^-T
                                                                                                 Response to Comment Letter Ho. 5
1980 March 10                                      •    ^ iSBSO^
                                                           i-SVI
                                                                C
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                                                          COMMENT  LETTER  NO.  6
                                        ARKANSAS  CHAPTER

                  ASSOCIATED GENERAL CONTRACTORS OF AMERICA. INC.
                       P. O. BOX 141 • QUAPAW TOWERS • UTTLE ROCK. ARKANSAS 12201 • 
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in
                                                                COMMENT LETTER NO.  7
                      ARKANSAS DEPARTMENT OF ECONOMIC DEVELOPMENT
                      One State Capitol Mall • Little Rock, Ark. 72201 • SOI/371-1121
     February 27, 1980
Mr. Clinton Spotts
Regional EIS Coordinator
EPA, Region 6
1201 Elm Street
First International Bldg.
Dallas, Texas.' 75270

Dear Mr. Spotta:

Our agency first became Involved with the Milchem project in the State of Arkansas
on the 20th of January, 1977.  Mr. Neimeler and Mr. Prostak visited our office and
told of their Intentions to mine barite in Montgomery County at Fancy Hill.  At this
same time, the two representatives of the company had contact with the Arkansas
Department of Pollution Control and Ecology.  Until June 7, 1978, all of our dealings)
with Milchem was very confidential but during this period of time, Mllchem1s concern
for building an operation that would not harm the environment was their greatest
concern.  Our agency has worked directly with many manufacturing companies that
located within the State of Arkansas, but I have not worked with any company that
has been more deligent with their attempt to build a facility that will not harm
Che natural beauty of our great state.

1 have attended numerous meetings with the Arkansas Department of Pollution-Control
and Ecology, the Arkansas Health Department and the U.S. Forestry Service.  At these ]
meetings different consulting firms that Mllchem retained have been present for
the purpose of designing a mining and packaging facility that will provide the best
known controls for water and air pollution.  1 have not heard a question asked by
any party that Milchem or its consulting agencies have not answered to the satis-
faction of all concerned parties.

Our agency can see this operation at Caddo Gap providing an economic boost to
Montgomery and surrounding counties.  With 150 people employed at the wage rates
Milchem plans on paying, it will provide good wages to some of our citizens which
they rightly deserve.  We also see this operation helping the U.S. balance of
payment problem since barite is now Imported from the mid East because the U.S.
cannot produce enough.

Our agency is concerned with the environment and in no way would we want a company
to locate within our state that would harm the Cod given beauty that our state has,
but I personally,  in all honesty, can see nothing but good things that will develop
once Milchem is able to start production.

Sincerely,
                                                                                                                            Response to Comment Letter No.  7
                                                                                                            Arkansas Department of Economic Development
                                                                                                            February 27,  1980

                                                                                                                 No response  needed.
     Jim Alexander
     Director of Consultants
     JA/pm

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                   DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                              FORT WORTH REGIONAL OFFICE
                              221 WEST LANCASTER AVENUE
                                    P.O. BOX 2805
                               FORT WORTH. TEXAS 70113


                                March  3, 1980
Mr. Clinton B. Spotts,
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, Texas  75270

Dear Sir:

The Draft Environmental Impact Statement, Fancy Hill  (Milchem)  Barite  Mine

and Processing Plant in Montgomery County, Arkansas,  has been reviewed in

the Department of Housing and Urban Development's Little Rock Area Office

and Fort Worth Regional Office and it has been determined  that  the Depart-

raent will not have comments on this statement.

              r
       I'. Hancock
Environmental Clearance Officer
                                  AHIA OFFICES
                                                                                                                           Response to Comment Letter No. 8
                                                                                                     Department of Housing and Urban Development
                                                                                                     March 3. 1980

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 Advisory
 Council On
 Historic
 Preservation
COMMENT LETTER NO. 9
This response tf:°s not constitute
Council comn.;;.t puifuani to
Sec'Jon 106 oi In: Noiional Historic
Preservation Act, nor Section 2(b)
«l Executive Order 11593.
                                                                                         Response to Comment Letter No. 9
 1522 K Street NW.
 Washington D.C.
 20005
                                        SUITE 616
                                        44 UNION BUD.
                                        UKEWOOO. COLORADO  80228
February 22, 1980
                                                                        Advislory Council on  Historic Preservation
                                                                        February 22,  1980

                                                                             A.   By  letter dated  April  16,  1980 (Comment Letter Ho. 16), the
                                                                                  Arkansas State Historic Preservation Officer concurred with
                                                                                  EPA's determination of no  effect.
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
First International Building
Dallas, Texas   75270

Dear Mr. Spotts:

This Is In response to your request of  January 24, 1980, for comments
on the draft environmental statement  (DES)  for the Fancy Hill
(Mllchem) Barlte Mine and Processing  Plant,  Montgomery County,
Arkansas.

The Council has reviewed the DES and  notes  that the Environmental
Protection Agency has determined that the proposed undertaking
will not affect properties Included In  or eligible for inclusion
in the National Register of Historic  Places.   Accordingly, the
Council has no further comment to make  at this time.  It is
suggested, however, that the final environmental statement contain
the Arkansas State Historic Preservation Officer's concurrence in
the Environmental Protection Agency's determination of no effect.
Should you have any questions or  require  additional information
regarding this matter, please contact Mrs.  Jane King of the
Council's Western Division at (303)  234-4946,  an FTS number.

Sincerely,
Lou0/S. Wall
Chief, Western Division
  of Project Review

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IV)
01
                                                               COMMENT LETTER NO.  10
                                  STATE OF ARKANSAS
                           DEPARTMENT OF LOCAL SERVICES
                                  NUMBER ONE • CAPITOL MALL
                                    LITTLE ROCK 722OI
BILL CLINTON
  GOVERNOR
 B J MCCOY
  DIRECTOR
                                               Response to Comment  Letter  No.  10
           February  29,  1980
           Mr.  Clinton B. Spotts
           Regional EIS  Coordinator
           Environmental Protection Agency
           First  International Building
           1201 Elm Street
           Dallas, Texas 75270
           Dear Mr. Spotts:
           We appreciate the opportunity to review the draft environmental impact
           statement for the Fancy Hill (Milchem) Barite Mine and Processing Plant
           in Montgomery County, Arkansas.  Our responsibilities include the prep-
           aration and implementation of Arkansas's Statewide Comprehensive Outdoor
           Recreation Plan, and the comments which follow are offered because of
           our  interest  in  the recreational environment:
                 1)  Both the Caddo River and its South Fork are streams of
                    high water quality.  In fact, the Department of
                    Pollution Control and Ecology has given each an "AA"
                    rating for:
                               Extraordinary recreational and aesthetic
                               value.  Suitable for primary contact re-
                               creation, propagation of desirable species
                               of fish, wildlife, and other aquatic life,
                               raw water source for public water supplies,
                               and other compatible uses.
                 2) Largely because of their clear, clean waters, the streams
                   support a wide variety of aquatic life.  "For its small
                   size," the di-aft EIS notes, "the South Fork possesses a
                   relatively diverse assemblage of fish species."  At least
                   two unique species are known to inhabit the Caddo watershed,
                   and one--the Caddo Madtom--was abundant at collecting
                   station 9, just downstream from the proposed plant site.
                               State of Arkansas
                               Department of Local Services
                               February 29, 1980
                               A.   No response needed.
                               B.   No response needed.

                               C.   The DEIS discussion of sediment Input to the South  Fork of  the
                                    Caddo River 1n Sections S.S.lf (pg.  139) and 5.6.2b (pg.  186) were
                                    based upon the worst-case assumption of little  or no effective
                                    sediment control during the construction period.  Data presented  1n
                                    discussions on pg. 187 of the DEIS clearly supports the contention
                                    that South Fork biota are unlikely to suffer significant  adverse
                                    Impact due to the elevated suspended sediment load.

                                    Subsequent to DEIS preparation, Milchem has agreed  to Initially
                                    construct the Back Valley (sediment) Containment  Basin (see DEIS
                                    Figure 3.2.2, pg. 31).  According to a draft report recently
                                    received by Milchem from Us mine design consultant, the  con-
                                    tainment basin will provide "excellent suspended  sediment settling
                                    characteristics."  The text of the DEIS has been  revised  to reflect
                                    this change.  As a result, overall sediment Input will  be reduced
                                    during construction to less than 25 percent of the  levels predicted
                                    in the DEIS.

                                    Suspended sediment during facility operation is limited by  the
                                    proposed NPDES permit for the maintalnance of water quality in
                                    compliance with all requirements of the Federal Water Pollution
                                    Control Act, as amended.  These limitations are fully consistent
                                    with applicable Arkansas Water Quality Standards.

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          Mr. Clinton B. Spotts
          Page Two
          February 29, 1980
ro
en
                3) We are concerned about the scenario developed on page 186
                  under "Potential Impacts of Plant Construction and Operation"
     Suspended sediments may cause direct mechanical damage
     to exposed gills and other sensitive organs of fishes,
     benthic invertebrates, and plankton in addition to
     altering habitat, altering behavior patterns, smothering
     benthic food organisms, and damaging fish eggs and lar-
     vae.  Reduction of dissolved oxygen content may occur
     due to elevation of oxygen demand should the stream
     receive organic materials in addition to inert soil
     particles.  The summation of these adverse effects on
     the aquatic system may not be significant in the long-
     term since the system experiences variations in roost
     of these parameters due to varying'flow or other
     seasonal phenomena which may differ little in magnitude
     from those caused by the construction activity (emphasis
     added).
This claim that adverse effects on the streams "may not be
significant in the long term" provides us little assurance that
water quality will necessarily be safeguarded.
                4)  According to Table 5.5.11, the expected concentrations of sulfate
                   and total dissolved solids will in many instances equal--and in
                   one case exceed--the maximum amount allowable under state guidelines.
                   Since both factors can have a pronounced ijnpact on water quality,
                   we would encourage the establishment of water quality monitoring
                   stations downstream from each outfall,  in addition to the upstream
                   stations! mentioned in the draft EIS (p. 149).
           There is no question that the proposed barite mine in Montgomery County
           would have a positive short-term impact on the local, state, and national
           economies.  The question is, what effect will the project have on the
           Caddo River and its tributaries? We think that, if proper safeguards are
           used, it is possible to extract the mineral while protecting the biological,
           recreational, and aesthetic values of the streams.  Therefore we are
           asking that stream quality be closely monitored before, during and after
D.   The expected concentrations of sulfate and TDS shown In DEIS Table
     5.5.11  (pg.  146) are. In all cases,  equal  to or below the maximum
     amount  allowable under state water quality standards.  In addition.
     the proposed NPDES permit specifically limits 1n-stream Increases
     In sulfate and TDS to a value no greater than the water quality
     standard limitation of 1/3 over naturally occurring values.

E.   Dally total  flow from each of Mllchem's proposed outfalls is to be
     calculated according to formulae specified 1n the proposed NPOES
     permit  (DEIS,  Appendix A, pg. 276).   Actual  measurements of  1n-
     stream  flow and of mineral quality 1n both the stream and the
     effluent are used In the calculations to ensure that Instream
     Increases 1n sulfate and TDS do not  exceed the amounts allowable
     under state water quality standards.   Determination of noncompH-
     ance with the  permit conditions, therefore,  does not depend  upon
     downstream monitoring.  Rather, It can be  determined Immediately if
     recorded flow  from either outfall  1s  greater than the calculated
     allowable value.  Hence, no downstream monitoring stations for this
     purpose are  necessary.

     It should be noted that Milchem must  also  secure a state wastewater
     discharge permit Independently of the NPDES  permit.   Preapplication
     meetings with  the Water Division of  the Arkansas Department  of
     Pollution Control and Ecology ("ADPCE") have been held.   Discussions
     during  these meetings indicate that  the state will likely require
     Applicant to operate an Instream water quality monitoring station
     downstream of  the mixing zone below  outfall  001.  In addition, the
     sample  required to determine values  for parameter "P3" in the NPDES
     permit  must  be taken at a station  downstream of the mixing zone
     associated with outfall 002.   Comparison of  data from the latter
     stations with  that from the NPDES  station  upstream of outfall  002
     will  provide a secondary means to  assess compliance  with permit
     conditions.
                                                                                                           F.   Milchem has complied with all state and Federal water quality
                                                                                                               monitoring requirements  including those specified  in the proposed
                                                                                                               NPOES  permit.  Water quality monitoring will be required to continue
                                                                                                               in compliance in the future.

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          Mr. Clinton B. Spotts
          Page Three
          February 29, 1980
          plant construction and operation, and that appropriate steps be taken
          to maintain the natural attributes of the Caddo River and its South
          B. J. Md
          "iirectdr/State Liaison Officer

          BJNfcCtfbw
          cc:  State A-95 Clearinghouse
 ro
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-o

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                                           COMMENT  LETTER NO. 11

United States Department of the Interior
          FISH AND WILDLIFE SERVICE
                 Ji SPRING STREET. S.w.

               ATLANTA. GEORGIA 30303
                                                                                                    Response to  Comment Letter No. 11
                          HSR 4  1980
Mr. Clinton B.  Spotts
Regional  EIS Coordinator  (6 ASAF)
U. S. Environmental Protection Agency
1201 Elm  Street
Dallas, Texas  75270

Dear Mr.  Spotts:

This Is In reference to your correspondence dated February 7, 1980,
concerning the  proposed Fancy Hill Barite Mine  and processing
facility  In Montgomery County, Arkansas (Log number 4-3-79-1-10).

After an  inspection of the proposed project area, a review of the
Biological Assessment contained In the draft EIS, and an evaluation
of data In our  files, we  concur with your conclusion that there are
no Federally listed species In the area and, therefore, no effect
will result from  the issuance of permits for the Fancy Hill Barite
Mine and  Processing Plant.

If at any time  in the future you determine that listed species or
Critical  Habitat  do occur in the project area and may be affected
by project activities, 1t Is your responsibility to contact this office
and again request consultation.

We appreciate your concern for endangered species and look forward to
future assistance.

                                       Sincerely yours.
                                                                                    U.S.  Department of the Interior
                                                                                    Fish  and Wildlife Service
                                                                                    March 4, 1980

                                                                                         No response needed.
                        oeputxRegional Director
                 RECEIVED
            i.    MAR  71980"

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                                                              COMMENT LETTER NO.  12
                                                c/lrkansas
                                            Soil  and  'Water
                                     Conservation   Commission
                                                                                                                       Response  to Comment Letter No.  12
ro
en
co
         JohnRS«xlon
           Oiricloi

            February 21, 1980
Mr.  Clinton B. Spotts
Regional  EIS Coordinator, EPA
Region-6,  1201-Elm Street,
First International Building,
Dallas, Texas  75270

Subject:    Draft EIS - Fancy Hill (Milchem) Barite Mine and Processing
           Plant, Montgomery County,  Arkansas.

Reference:  Letter from Regional Administrator  (6A) dated January 24,  1980.

Dear Mr.  Spotts:

     With reference to comments invited on Draft EIS on the Subject cited
above, we have to offer the following comments  for your consideration.

     It was stated a dam will be constructed on Back Creek for containment
basin on  page-44.
                 According to Act 81 of  1957 of Arkansas General Assembly,  Section 6,
             any person impounding water  on any stream shall obtain a penait from our
             office.
                 We support the location of  the project as it will involve  development
             of  industry, employment and increasing revenues in the State  of Arkansas.

                 The Draft covers almost all aspects of environmental  quality and is we
             presented.

                 We hope that our comments will be useful during the public hearing
             scheduled for 7 P.M. on March 18,  1980 at Mount Ida, Arkansas,

                                              Sincerely,
Arkansas Soil  and Water Conservation  Commission
February 21.  1980

A.   Milchan  Is aware of Us responsibility to secure a state permit
     for the  dam on Back Valley Creek creating the containment basin.
     By letter of October 22, 1979 from  Lynn A. Burton to Amerlc Brynlarskl,
     Hllchem  Initiated state permitting  requirements by submlttal  of
     preliminary review materials. Formal application for the permit
     via submission of the detailed engineering drawings and construction
     specifications required by the Commission was made on April  24,
     1980.
             JPS:JRY:MVGC:bs
                                              JoKn P. Saxton
                                              Director

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                                                                 COMMENT LETTER  NO.  13
ro
in
                           UNITED STATES DEPARTMENT OF AGRICULTURE
                                       FOREST SERVICE
                                    Ouachita  National Forest
                                         P. 0. Box 1270
                          	Hoe Springs, AR  71901	
     BEPtrro:   1950 FS NEPA Process
                                                              March 14, 1980
               Fancy Hill (Milchem) Barice Mine
               & Processing Plant (DEIS)

               Mr.  Clinton B.  Spotts
               Regional EIS Coordinator
               U. S. Environmental Protection Agency - Region 6
               1201 Elm Street
               Dallas,  Texas  75270
We reviewed the Draft Environmental Impact Statement for Fancy
Hill (Milchem) Barite Mine and Processing Plant. Our concerns
are about the spoil area, stream quality and site maintenance
after operations cease.

Spoil Area                         '
               Location,  operation and maintenance of the Section 24 spoil area,
               for which  a Forest Service special-use permit is required,  is
               unclear. Figure 3.2.2 and some text refer to two areas,  a main
               area of  about  75 acres south of Back Valley Road,  and a  smaller
               dump containing 16 acres north of the road (page 33). Other EIS
               text refers to only one spoil area In Section 24.  This smaller
               16'-acre  site was not in the original special-use application.
               Seven acres (page 33) or nine acres (page 34) would be located on
               mining claims.  This violates the rule (page 56)  that "Federal
               mining regulations discourage the use of undeveloped mining
               claims because deposition of spoil would detract from the poten-
               tial to  economically exploit the claim's mineral resources. Conse-
               quent, (sic) Milchem's patented and unpatented claim lands, as
               well as  those  held by others, are similarly unavailable".
               How these or other spoil areas will be used for storage of non-
               recoverable  reserves segregated from other waste needs to be
               addressed.  Location needs to be identified, leaching and its ef-
               fects  need  to be discussed and revegetation should be described.
               Milchem proposes to pile pyrite-bearing shale spoil  separately
               and Co overlay it with an impermeable substance consisting of
               clay or a  comparable substance.  The source of this clay or imper-
               meable substance and the effects of obtaining it  should be ana-
                                                                                                                          Response  to  Comment  Letter Ho. 13
U.S. Department of Agriculture
Forest Service
Ouachita National Forest
March 14, 1980

A.   The DEIS text (pp. 49-51, 57-62) has been revised to more clearly
     note that two spoil areas are to be located at the upper end of
     Back Valley.

B.   Page 56 of the DEIS notes that Federal mining regulations "dis-
     courage" spoil placement on undeveloped claims.  This Is not, how-
     ever, a "rule" or regulation.  Page 56 of the DEIS has been revised
     accordingly.


C.   Location

     The DEIS text (p. 46) has been revised to indicate that non-recoverable
     barlte ore will be stored 1n the pyrltic spoil dump or 1n mined-out
     pits.
                                                                                                 The DEIS text  (p.  135)  has  been  revised  to  Indicate  that leachate
                                                                                                 from the storage of  non-recoverable barlte  ore  Is expected  to  be
                                                                                                 similar to leachate  resulting  from pyritlc  spoil.


                                                                                                 Revegetation

                                                                                                 The DEIS text  (p.  103-103A) has  been  revised  to Include Information
                                                                                                 on revegetation which has  become available  following DEIS preparation.


                                                                                            D.   Clay will be used to cap the pyrlte-bearlng spoil pile.   Explora-
                                                                                                 tory drilling  conducted by Applicant  Indicates  that  clay  soil
                                                                                                 strata are located on-slte.  These soils would  be removed as  part

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                                                                     Page 2
              Stream Quality
Ol
              Effects of activities on the riparian ecosystem of Back Valley
              Creek are vague.  The relationship of Fancy Hill, the haul road
              and Back Valley Creek make protection of the ecosystem difficult.
              A ditch is planned upslope of the proposed haul road to route
              water to a sediment basin prior to Its release into Back Valley
              Creek. Space may not exist for this sediment basin, and alterna-
              tive mitigating measures are not presented. A 40-foot road with
              60-100 foot right-of-way may be the solution; reasons for a wider
              road are not evident in the DEIS.
              More than a sp*illway will be needed in the containment basin dam
              since the basin ts to be used for solids settlement and  secondary
              pH control. Assurance is needed that  this basin  is large enough
              to be effective for the life of Che operation, or alternatively,
              that measures for clean out are provided.
Executive Order 11988, Floodplain Management, needs to be ad-
dressed. This Executive Order establishes a general policy and
specific requirements to avoid the long and short-term adverse
impacts associated with the occupancy and modification of flood-
plains, and to avoid the direct or indirect support of floodplain
development whenever a practical alternative exists. Where an
action must be located on the base floodplain, the Executive
Order requires that agencies minimize potential harm to people
and property and to natural and beneficial floodplain values. The
containment basin and parts of the ore stockpile, plant area,
tailings pond pipeline and access road all are in the base
floodplain.

After Operations Cease
               retain water; this is especially important  In the containment
               basin through which Back Valley Creek flows. Water in these ponds
               will likely require treatment as long as runoff from mined areas
               is allowed to enter them. The pyrite spoil  could present a leach-
               ing problem many years  in the future.
               Details
               Questions  of detail must  be  answered  before  the  Forest  Service
               can  issue  special  use  permits  for  the spoil  area,  roads and  pipe-
               line.  These details can be covered in Milchem's  final mine  and
               reclamation plan.  An example is location,  construction, mainte-
               nance  and  vegetation to Forest Service specifications of the
     of normal  preconstructlon, site preparation activity.   If not used
     as a sealant,  they would otherwise constitute waste and be placed
     1n the Section 24 spoil dump.  There are, therefore, no Incremental
     effects of obtaining this material.

E.   The DEIS text  (pp. 44.  47-47A, 53C-53D, 66-66A, 69-70) has been
     revised to Include additional analysis of the effects of Applicant's
     activities In  Back Valley.

F.  .The DEIS text  (p. 43) has been revised to provide additional detail
     concerning Applicant's  need  for a 60-foot haul  road.

G.   The DEIS text  (pp. 44,  53A-S3D) has been revised  to provide  additional
     details concerning design of the containment basin.

H.   The DEIS text  (p.  139A) has  been revised to reflect analysis of
     containment basin  function over the life of the project.

I.   The DEIS text  (p.  8) has been revised  to include  a discussion of
     Executive Order 11988.
                                                                                                                The DEIS  text  (pp. 51. 53. 103, 138-138A) has been revised to
                                                                                                                provide additional detail regarding Milchem's responsibility following
                                                                                                                abandonment  of the project.

                                                                                                                Figure 3.2.1 has been revised  in accord with this information.

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small impoundments below the spoil areas.  Another example,
shaping the western edge of the Section 24 spoil  areas Co insure
all runoff will flow into Back Valley Creek and not into the
drainage to the west. Still another detail is abouc restoration
of the Forest Service road through the gap between Fancy Ridge
and Fancy Hill.
A corrected Property Ownership map is attached
JOHN V. ORR
Forest Supervisor
     RO
     Caddo District

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  Xv.
                                                                  COMMENT LETTER NO. 14
 DEPARTMENT OF ARKANSAS NATURAL & CULTURAL HERITAGE
1 BILL CLINTON - GOVERNOR
 ROSE CRANE - DIRECTOR     ARKANSAS NATURAL AND SCENIC RIVERS COMMISSION
          6 March 1980
          Mr. Clinton B.  Spotts
          Regional EIS Coordinator
          Environmental Protection Agency
          First International Building
          1201 Elm St.
          Dallas, Texas 75270

          Dear Mr. Spotts:
          I appreciate the opportunity to  review the draft environmental impact statement
    ro    (ElS)for the Milchem (Fancy Hill)  Barite Mine and Processing Plant planned for
    01    Montgomery County, Arkansas.  The  Arkansas Natural and Scenic Rivers Ccmnission
    ^    was created by Act 257 of 1979.  The Caimission is charged with the identifi-
          cation of streams, rivers,  or segments of these waters, which have  exceptional
          natural, scenic,  educational,  geological, fish and wildlife, etc., character-
          istics for possible inclusion into a state Natural and Scenic Rivers System.
          We are also to review related State and Federal water projects for their impact
          on Arkansas' streams. The South  Fork of the Caddo River, as well as any tribu-
          tary to the South Fork,has a Class "AA" water quality status, and has been recog-
          nized as a snallmouth bass fishery.  We are concerned about the effects of this
          barite plant on the water quality  of the South Fork of the Caddo River.
          I have some questions and comnents pertaining to the draft EIS:
              Sec 3.3.3, Tailing Pond (p.41):  "...  review under provisions of the Dam
              Safety Act is not required."  Because of  the nature of the waters contained
              in the tailing pond, the stress on Milchem's pollution control systems if
              the dam fails during heavy rains,  and the likelihood of large levels of
              pollutants entering the South Fork if pollution control systems are stressed
              beyond the engineering design, we suggest that Milchem's tailing pond dam
              be reviewed under the provisions of the Dam Safety Act regardless of it
              blocking an "inactive" drainage.
           2.  Sec 5.5.1e, Tailing Pond Effluent into the South Fork (p.133): "... analysis
              indicated that the required discharge rate under normal operation conditions
              at Point 001 should not exceed 15 gallons per minute (gpm) at mean daily
              river flow." This 15 gpm  discharge rate is only for normal conditions.
                                                                                                                                Response  to Comment Letter No. 14
Department of Arkansas Natural & Culture Heritage
Arkansas Natural and Scenic Rivers Commission
6 March 1980
                                                                                                            A.
     Analysis of flood potential  in the Fancy  H111 area has been conserva-
     tively  based on an assumed 100-year,  6-hour rainfall of 6.48 Inches
     (equivalent to Input of precipitation to  the tailings pond with no
     allowance for evaporation of approximately 2.400 gallons per minute
     (gpm)).  The DEIS notes (Table 5.5.10) that tailings pond effluent
     flow under a "high rate" scenario  1s  assumed to be 24 cubic feet
     per second (cfs) which 1s equivalent  to more than 11,000 gpm.
     Hence,  the assumed design discharge rate  for the tailings pond Is
     almost  five times greater than the 100-year rainfall event.  No
     "stress" on the discharge control  system  nor failure of any
     Impoundment is likely to occur under  these conditions.

     Milchem proposes to comply with all necessary regulatory permits
     and requirements (see DEIS Table 3.3.1. pg. 36; Section 3.5. pg. 53;
     response to Comment Letter No.  12,  above).  Additionally, Milchem
     proposes to construct all elements  of Its facility at Fancy Hill in
     accordance with sound, prudent engineering standards and appropriate
     margins of safety.   The design of  tailing pond Impoundments is of
     an  especially critical nature  In this  regard to the overall operation
     because the pond also serves as a  reservoir of essential  flotation
     plant recycle water.

     Milchem, however,  has no legal  responsibility to comply with the
     Dam Safety Act.   Nor  is compliance  in  this case an appropriate
     engineering measure.   The tailings  impoundments will  not be subject
     to  "flash floods"  (see the following  response)  because they are not
     located across  an  active drainage.  Rather, the pond  will  be within
     a "saddle".   The Dam  Safety Act applies to the  former situation,
     not the latter.
  SUITE 500
  CONTINENTAL BLDG.
  MAIN & MARKHAM
  LITTLE ROCK. ARK. 72201

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                                      page 2
    How will this rate be altered for the frequently occuring flash floods in
    the area, especially after three years when the effluent levels in the
    tailing pond reach those noted in Table 5.5.8?  The effect of floods on the
    effluent discharge rate should be dealt with in the final EIS.
    5.5.1e, Containment Basin (p.138):  The average rate of 125 gpm is noted for
    the discharge of effluent into the South Fork.  No notation is node concern-
    ing the location of the variable flow valve.  Will this valve drain water
    from the surface of the containment basin, the middle, or the bottom? How
    will this 125 gpm discharge rate be affected by the flash floods in this
    area?  During periods of heavy rains, rainwater entering this shallow basin
    will re-suspend settled solids from the bottom of the containment basin.
    The final EIS should deal with how this type of situation will be dealt with,
    and construct models to predict how much of the sediment in this basin would
    be expected to escape during severe rains.
4.  5.5.If, Potential Impact on Surface Waters (p.139):  Under what conditions
    could the level of suspended soilds be increased 8000 to 10000 ppm above
    the normal TDS levels?
5.  (p.140):  In reference to the stability of stream banks,  the final EIS
    should stipulate the amount of vegetation to be left along stream banks.
    No mention is made of ephaneral streams.  I suggest that  to further control
    sediments in this highly erosive area, vegetative buffers should be main-
    tained on ephemeral streams. The final EIS should deal with this topic.
6.  (p.141):  A statement is made to the effect that no impact is expected due
    to the alteration of the normal temperature regime of the area streams. The
    water temperatures in this area remain cool all year.  Aquatic organians
    present are adapted to a cool temperature regime.  The clear nature of the
    area's water,  as well as the surrounding vegetation protects it from large
    amounts of heat absorption.  Small streams are even more susceptible to
    heating by direct sunlight. Silt in the water absorbs heat,  raising the
    surrounding water temperature.  Slowing the rater allows for little heat
    loss. Ihless the containment basin is shaded, there will be a substantial
    increase in the containment basin temperature relative to those levels "in the
    South Fork.  During periods of low flow in the South Fork, this could raise
    the stream's temperature substantially, resulting in lower dissolved oxygen
    levels available for respiration by aquatic organisms.  The final EIS should
    deal with this to a greater degree than it was delt with in the draft EIS.
7.
    Oxygen Demands (p.143):  Water's ability to absorb oxygen is inversely pro-
    portional to the temperature,  j..£.,  the higher the water temperature,  the
    lower the dissolved oxygen in  the water available for respiration.  Some of
    the aquatic biota present are  adapted to cool temperatures and lugh dissolved
    oxygen concentrations. An increase in dissolved oxygen could be realized by
    mechanical airatlon (by splash board or sprinkler) of the water released
    fron both the containment basin and the tailing pond.  In times of  low flow,
    the low dissolved oxygen concentration could further stress already stressed
    inhabitants of the stream. Efforts should be made to increase the amount of
    dissolved oxygen in the discharge from the containment basin and the tail-
    ing pond.
B.   As noted 1n Response A,  above,  "flash floods" will  have no effect
     on the tailings pond due to Its location In a saddle.   In addition,
     the design of the pond discharge structure Is capable  of handling
     In excess of the assumed 100-year,  6-hour rainfall ..event.


     DEIS Table 5.5.8 discusses effluent quality not "effluent levels".
     Table 5.5.10 (pg. 145),  however, discusses the range of effluent
     flow from 0.003 cfs (low flow)  to 24.00 cfs (flood  flow) conditions.


C.   The DEIS text has been revised  to provide additional detail con-
     cerning design and operation of the proposed containment basin.
     See also Response C to Comment  Letter No. 10 and Responses H and I
     to Comment Letter No. 13, above.


D.   See Response C to Comment Letter No. 10, above.


E.   Mllchem proposes to disturb streambank vegetation only when
     necessary to do so and when no  feasible alternate to a streambank
     location exists.  However, specification as to the  "amount" or
     width of the vegetative buffer  strip to be left Is  not possible
     until the final locations of the haul road and other potential
     streambank facilities have been certified by grant  of  Forest
     Service Special Use Permits or  approval by USGS of  the final mine
     design.


     Soils In the area are not all "highly erosive" as sta'ted in the
     comment.  DEIS Table 5.3.1 (pg. 100) notes that the erosion hazard
     of area soils ranges from slight to severe.


F.   DEIS Table 5.5.6 (pg. 127) indicates that the range of temperature
     in the Caddo River at Glenwood  has  been found to be 5.6° C to
     29.9° C (42.6° F-89.8" F) over  a year.  Fewer measurements have
     been made in the South Fork (DEIS,  Table 5.5.4, pg.  122; Table
     5.5.5, pg. 123) but water temperature In excess of  77° F has been
     measured.  For fishery classification, warm water streams are often
     considered to be those which maintain a viable population of aquatic
     organisms at temperatures in excess of 75° F.  Horning and Pearson

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                                               page 3
(M)
             (p.149):  I believe that to adequately determine the quality and effects of
             Milchera's mine effluent, an automatic monitoring station should be placed
             downstream, as well as upstream, of each outfall.
         9.  5.5.2e, Potential Impact on Groundwater (p.155): To decrease the amount of
             seepage into the water table, would it be feasible to place a layer of clay
             (or other impermeable material) on the bottom of tailing pond?
            -K£
            Tug
10. 5.5.3. Water Htnagment (p.162): " It has been further classified as a
     otential smallmouth bass fishery, but unsuitable for a trout fishery, the
     ighest fishery classification."  I feel that the word "potential" indicates
    a questionable classification of this stream. All tributaries of the Caddo
    River above lake DeGray nave been classified as smallmouth bass fisheries
    by the state Department of Polution Control and Ecology (PC&E).

    In the state of Arkansas, few streams have trout fishery classification,
    these streams having abnormally cold waters caused by springs or the cold
    tailwaters of dams. Trout do not naturally occur within the state, and
    their fisheries are atypical examples of Arkansas' streams. The smallmouth
    fishery classification is the highest type natural fishery in the state.
    The final EIS should reflect this fact.
         11. 5.5.4c, Potential Flood Impacts (p.169): Although the flooding potential
             of Back Valley was noted as presenting  potential hazards:to miners and
        	mine operations, no mention, again, was made of possible flood impacts on
             the tailing pond. I would like to see operations proceedures, expected
             discharge rates, and the  composition of this high water discharge vs.
             normal discharge added to the final EIS.
         12. 5.6.2b, Potential Impacts of Plant Construction  and Operation  (p.187):
             'The Caddo River and all of the tributaries of the Caddo River  above Lake
             Degray are classifies as smallmouth bass fisheries, not wamiwater fisheries
             as stated. Tests on trout streams are  not applicable to conditions on the
             South fork of the Caddo.  References to warmwater species of fish in the
             discussion of resistance to turbidity  deals with fishes which  have a broad
             range of tolerances. The tolerance of  fishes of  a amllmouth fishery are
             not nearly so great. Reference to'such studies that are considering only
             warmwater fishes fails to include! the  more specific requirements of the
             fishes which are used to classify this fishery (anallmouth bass, hogsuckers,
             ect.). In doing so,  comnents made concerning the fishery of the Caddo River
             and its tributaries completely ignores those organians which would be most
             adversely affected by a long-terra increase in the silt load (for reasons
             of gill constriction, damage to  spawing grounds,  increased temperature and
             subsequent decrease in dissolved oxygen).

             I  feel that the final EIS should correct the fishery classification used
             in the final EIS, and references to tolerance parameters for trout and
             warmvater fishes should be deleted for studies concerning anallmouth bass
             fisheries.
     1n a paper entitled  "Growth, temperature requirements and lower
     lethal  temperature for juvenile smallmouth bass (Hlcropterus dolomleu
     Lacepede)" published as a  1972 draft manuscript by the U.S. National
     Water Quality  Laboratory In Duluth, Minnesota, and Peek In a 1965
     University of  Arkansas Master's Thesis entitled "Growth studies of
     laboratory and wild  population samples of smallmouth bass (Micropterus
     dolomleu Lacepede) with applications to mass marking of fishes"
     also note that the optimum temperature for the growth of Smallmouth
     bass Is 26.3°  C (79.3° f)  and 28.3° C (82.9° F). respectively.
     Hence,  classification of area stream waters as "cool all year" and
     Smallmouth bass as an organism adapted to cool temperatures are
     matters of Interpretation  not necessarily supported by the available
     data.


G.   The contention that  containment basin waters will demonstrate
     "substantial"  temperature  Increase relative to South Fork waters Is
     speculative.   The tendency for silt-laden waters within the basin
     to absorb heat will  be offset by several factors.  First, the basin
     is designed to be a  "flow  through" structure under all but extreme
     low flows.  Retention time is achieved by a high length to width
     ratio and discharge  occurs through a surface decant tower.  Second,
     natural vegetation will be preserved to the maximum degree practicable
     to maintain shading.  Third, effluent resulting from mine dewaterlng
     will, under normal flow conditions, comprise more than 90% of the
     effluent flow  to the basin.  About 85% of the mine water will
     consist of groundwater.  The normal temperature of this groundwater
     is lower than  the temperature of the area's surface water during
     warm seasons of the  year.  The effect of adding groundwater to
     normal  surface water flow  into the basin should be to depress water
     temperature by an unknown  amount.


     Effluent flow  from the containment basin will also vary according
     to natural stream flow and natural variation in instream mineral
     quality.  The  abundance of natural groundwater discharge areas
     throughout the headwaters  of the South Fork indicates that flow per
     unit area near the mine under drought conditions is probably greater
     than the flow  per unit area further downstream; mine area flow

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©

(Rl
  ro
  en
  r-j
                                               page 4
13. 5.6.2b.Water Quality (p.188):  I feel that discussions concerning the trout
    and warmwater species avoids the issue of the possible effects on the fishes
    characteristic of the smallmouth bass fishery present in the upper Caddo
    River drainage. Oxygen levels 30% below target levels prescribed by PC&E
    could have a serious impact on the smallmouth fishery present. The largeroouth
    b?s^ gf\K^eg deal with a fish with a vast range and broad genetic tolerence
    to conditions. References to aquatic insects in this section deal with
    families and orders. Studies refering to these organisms are too general at
    that taxononic level to suggest that tolerance parameters for members of
    aquatic insect orders in waimvater streams are the same for the members
    of the same order in a anallmouth bass stream.
         14. In reading the draft E1S I did not notice any information on the fate of
             the tailings pond and the containment basin after the 11 year life of the
             barite mine has ended..The final EIS should detail the plans for these
             structures in the section on reclamation of the mine site.
             Tnank you for allowing me to ccnment on this project.
                                         Sincerely.
                                                  Stephen Winters
                                                  Technical Assistant
             cc: Steve Smith - Governor's Office
                 Jarrell Southall - Pollution Control and .Ecology
                 Joe Rice - Local Services
     under such  conditions,  therefore,  consists  principally  of  ground-
     water discharge  at lower temperature  than the  normal  basin surface
     runoff.   The tendency  for temperature Increase to  occur 1n the
     basin under low  flow conditions  due  to reduction In  basin  discharge
     rate will be offset by the lower ambient temperature of basin
     Inflow.   It 1s doubtful that temperature elevation even under these
     conditions  will  exceed the state standard of 86° F or the  assumed
     upper lethal limits of area aquatic  fauna (estimated to be about
     95° F for Smallmouth bass).  Under extreme  low flow  conditions,
     basin discharge  will be curtailed.

H.   There Is no evidence that stream Inhabitants In the  Fancy  Hill  area
     are "already stressed" due to deoxygenatlon of the water.   DEIS
     Tables 5.5.4, 5.5.5, and 5.5.6 (pg.  122, pg. 123,  and pg.  127,
     respectively) Indicate relatively high oxygen  content.   In all
     cases, sampled  values  are greater than the  state standard  of
     6.0 mg/1 and the EPA recommended value of  6.3  mg/1 calculated
     according to procedures contained In EPA's  1972 publication entitled
     "Water quality criteria", A Report of the Committee  on  Water Quality
     Criteria, National Academy of Sciences, Washington,  D.C.

I.   Milchem will make all  practical  efforts to  Increase  the amount  of
     dissolved oxygen in the discharge by allowing  for mechanical aeration.

J.   See Response E  to Comment Letter No.  10,  above.
                                                                                                             K.   The DEIS notes (pp. 154-155) that seepage from the tailing pond to
                                                                                                                  groundwater will move locally to groundwater Interceptors.  No
                                                                                                                  groundwater aquifers or groundwater wells will be affected.  In
                                                                                                                  addition, a gradual reduction in seepage rate over the life of the
                                                                                                                  project is expected.  A system of monitoring wells will be installed
                                                                                                                  by Milchem to detect unforeseen movement of pond seepage.  Finally,
                                                                                                                  efficient operation of the processing plant-tailings pond recycle
                                                                                                                  circuit would require that decreased seepage be offset by increased
                                                                                                                  surface water discharge.  Seepage at the rates proposed by Milchem,
                                                                                                                  therefore, appears to present no significant environmental Impact

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                                                                                                                which cannot be mitigated; the Incremental cost of sealing the
                                                                                                                bottom of the pond and the potential effects on plant operation and
                                                                                                                short-term surface water quality are not justified.

                                                                                                           L.   DEIS Section 5.10.4 (Recreation) notes that the South Fork near the
                                                                                                                mine site receives limited fishing pressure.  The stream, unlike
                                                                                                                the Caddo malnstem. 1s not sufficiently deep to support viable bass
                                                                                                                populations In size classes considered desirable by fishermen.
                                                                                                                It's administrative classification as a smallmouth fishery reflects
                                                                                                                water quality characteristics not the presence of a viable sport
                                                                                                                fishery.
ro
en
M.   The fisheries classification referenced In the DEIS is in accord
     with Section 3 (Use Classification), paragraph (d) of the Arkansas
     Water Quality Standards (Regulation No. 2, as amended), published
     September. 1975, by ADPCE.
                      •
N.   See Responses A and B, above.
                                                                                                           0.   The DEIS text has been amended to substitute the words
                                                                                                                fishery" for "warm-water fishery" or the equivalent.
                                                             'smallmouth
                                                                                                           P.   The discussion of turbidity on DEIS page  187 includes the observa-
                                                                                                                tion that fish species found In the South Fork are resistant to
                                                                                                                turbidity.  A comparison to the turbidity intolerance of cold water
                                                                                                                species  1s made to  illustrate this observation.

                                                                                                                Families such as the Centrarchidae (sunfishes),  Ictaluridae  (catfish),
                                                                                                                and Cyprinidae (minnows), typical warm-water associates, are well
                                                                                                                represented in the  South Fork.  In fact,  the typical "warm-water"
                                                                                                                taxa cited in the DEIS discussion as examples (sunfish, shiners,
                                                                                                                and Largemouth bass) are very common components of the South Fork's
                                                                                                                "smallmouth fishery" as demonstrated by the data presented in DEIS
                                                                                                                Table  5.6.4 (pg. 184-185).  There is no evidence that the largemouth,
                                                                                                                for example. Is less tolerant of turbidity than 1s the smallmouth,
                                                                                                                both inhabiting the same stream.  More Importantly, however, is  the

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R.
fact that turbidity levels known to cause mortality or behavioral
changes to these taxa are not likely to occur due to Applicant's
activities.  (See also Response C to Comment Letter No. 10, above.)

The DEIS on pages 144 and 188 does not state that oxygen levels
will be "30% below target levels prescribed by PC&E".  Rather, the
DEIS notes that oxygen demand (measured as BOO) caused by Mllchem's
facility will not be significant because the total BOD of effluent
discharged by Mllchem Is estimated to be 30 percent less than the
target effluent load determined for the South Fork by ADPCE.

The studies cited 1n the DEIS regarding the TDS tolerance'of aquatic
Insects represents the most specific Information available and are
used to Illustrate the low toxiclty of TDS at levels many times
greater than the levels which will occur in the South Fork due to
Mllchem's operations.

See Response K to Comment Letter Ho. 13, above.

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ro
en
                                                       COMMENT LETTER NO. 15

                 United States Department of the Interior
                            OFFICE OF THE SECRETARY
                             WASHINGTON. D.C.  20240
       ER-80/1U
                                                MAR 2 4 1980
Mr. Clinton  B.  Spotcs
Regional EIS  Coordinator
U.S. Environmental Protection Agency
1201 Elm Street
Dallas. Texas   75270

Dear Mr. Spotts:

We have reviewed  the draft environmental statement for  the
Fancy Hill  (Milchem) Barite Mine  and Processing Plant in
Montgomery County,  Arkansas.  In  general,  we find the state-
ment to be comprehensive and well written.

Fish and Wildlife Resources

If development  and operations plans  are executed as  proposed,
detrimental  impacts on fish and wildlife resources will not
be long-lasting or significant.   However,  structural failure
of the dam for  the containment basin or tailings pond,  for
example, could  result in the death of the South Fork of the
Caddo River  and its aquatic resources for its entire down-
stream reach.   Severe detrimental impacts would also likely
occur for some  distance down the  Caddo River.  For this
reason, we urge the Environmental Protection Agency  to  include
every possible  constraint in the  NPDES permit, if issued,  to
ensure execution  of development and  operational plans only as
proposed.  Similarly,  adequate provisos concerning site recla-
mation activities should be included in the permit to minimize
long-lasting  adverse environmental impacts.

Waste Disposal

With a high  stripping ratio (9:1), waste disposal will  present
a land-use and  an economic problem as well as a potential  haz-
ard.  A 16-acre dump containing only pyrite-bearing  spoil  will
be located north  of the principal waste dump (p. 33).   Although
a pyrite dump can present a serious;environmental hazard,  no
specific information on mitigating this problem is evident in
the report.   It is true that on pages 50 and 135 duplicative
summaries appear  regarding prevention of leachate formation
from pyritic  spoil, but it is not clear that this applies  to
                                                                                                             Response to Comment Letter No. 15
United States Department of the Interior
Office of the Secretary
24 March 1980

A.  The DEIS text  has been revised to clarify the discussion of  the
    spoil  dumps.'  (See also Responses A, D. and  E to Comment Letter
    No. 13.)


B.  The DEIS text  has been revised to provide additional discussion
    concerning spoil pile revegetatlon. (See also Response D to
    Comment Letter No. 13.)


C.  Milchem has successfully concluded all negotiations concerning
    the necessary  acquisition of private lands 1n the area.  No  use of
    condemnation authority on Mllchem's behalf 1s anticipated.  Nor
    will alteration of the proposal or delay due to such negotiations
    occur.


D.  Most of the maps 1n the DEIS have been revised to Include an over-
    print  of comparable project area boundaries.

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the pyrice dump mentioned earlier (p. 33) or simply to the
pyrite-bearing shale that will be mixed into the Section 24
dump.  The summaries also state that revegetation to limit
raintall percolation will be an on-going process, but this
will be extremely difficult on an active waste dump.  Addi-
tional discussion may be necessary to resolve this question.
Ownership of Land
If the State of Arkansas has condemnation powers, is such
authority contemplated on behalf of Milchem should indi-
vidual land owners not exercise their options to sell (p.28)7
Could the proposal be altered or delayed should negotiations
falter?  More importantly, would the preferred alternative
or other alternative configurations change any of the antic-
ipated impacts?
We experienced some difficulty in using and comparing the
maps, which are at various scales.  It would be helpful to
overprint each map with the outline of the project area.
We appreciate the opportunity to review this draft.

                                   Sincerely,
                                Jao9s\H. Rathlesberger
                                    .al Assistant  to
                                   SCRETARY

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                                                              COMMENT LETTER NO.
 •••• MMsi- 'ARKANSAS HISTORIC PRESERVATION PROGRAM
Suite 500. Connnenlol Building • MCNKIW ana Main  Linie KOC». .Aivsnsas 72201

      April 16, 1980
       Mr.  Clinton B.  Spotts
       Environmental Protection  Agency
       1201 Elm Street
       First International  Bank
       Dallas, Texas  75270
                                                                feHWtO
                                                                     EPi,
                                                                    FED.
                                                Re:  Draft EIS for Fancy Hill  (Milchem)
                                                     Bauxite Mine and Processing Plant
       Dear Mr.  Spotts:
       Thank you for your cooperation  in  the  review of the above cited project.

       In our letter of February  13, 1980, we  indicated that this office would make
       a final  determination  upon receipt of  the Arkansas Archeological Survey
       comments.   This  office concurs  with the  findings of the Arkansas Archeological
       Survey letter of March 14, 1980, that  no properties or sites which are on or
       eligible for the National  Register of  Historic Places will be affected by this
       mining development.

       If we can be of  any  further assistance,  please feel free to contact.our office.

       Sincerely,
.' ,-i, ' Joan Williams Baldridge
'      State Historic Preservation  Officer

       JWB/FK/lg
                                                                                                                         Response to Comment Letter No.  16
                                                                                                          Arkansas  Historic Preservation Program
                                                                                                          April  16,  1980

                                                                                                            •  No response needed.
                                    ol ih« Oeoonmcnl ot Noiurol & Culluiol Hernog*

                                     '>n Equcl Opportunity Employei

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                              LITERATURE
The following pages were revised in this section of the DEIS:
     none

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                              APPENDICES





The following pages were revised in this section of the DEIS:





     276

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                                                         PART III
                                                         Page 12 of 12
                                                         Permit No. ARoo38270

F.  If archeological resources are uncovered during mining, work will  be
    halted and the State Archeologist will  be notified for a determination
    of significance.  If there are resources determined eligible for list-
    ing on the national  Register, EPA in consultation with the Arkansas State
    Historic Preservation Officer, will  request corrments from the Advisory
    Council  on Historic Preservation in  accordance with their procedures
    (36 CFR Part 800).
                                  276A

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