MINING INDUSTRY SOLID WASTE




          AN INTERIM REPORT
        Office of Solid Waste



U.S. Environmental Protection Agency



            February 1981
         PRELIMINARY DRAFT

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                             CONTENTS






                                                            Page




Introduction                                                  1




Site Selection Method                                         6



     Step I - The selection of mining industry segments       8



     Step II - The selection of waste management practices   21



     Step III - Selection of sites for monitoring            40



Future Plans for Comprehensive Monitoring                    89




     Company contacts                                        89



     Initial site visits                                     89



     Comprehensive monitoring research plan                  91



     Comprehensive monitoring                                92



     Final report                                            93
                               11

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                              FIGURES


Number                                                      Paqe
          Waste Management Practice and Site Selection        7
            Process - Application of Criteria and Other
            Input

          Geographic Distributions and Copper Ore Produc-    33
            tion Contributions of Major Producing States

          Geographic Distribution and Phosphate Ore          35
            Production Contributions of Major Producing
            States

          Geographic Distribution and Uranium Ore Produc-    36
            tion Contributions of Major Producing States

          Geographic Distribution and Gold/Silver Ore        37
            Production Contributions of Major Producing
            States

          Geographic Distribution and Lead/Zinc Ore Pro-     38
            duction Contributions of Major Producing States

          Geographic Distribution and Molybdenum Ore Pro-    39
            duction Contributions of Major Producing States

          Schedule for Comprehensive Monitoring Program      90
                               111

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                              TABLES
Number                                                      Page
  1       Annual Solid Waste Production Statistics at        12
            Surface and Underground Mines

  2       Evaluation of Study Industry Segments              13

  3       Major Industry Segment Management Practices        22

  4       Evaluation of Waste Management Practices           23

  5       Waste Management Practices Selected for Further    28
            Consideration

  6       Major Producing Regions Within Industry Segments   34

  7       Mining Districts to be Studied for Each Waste      40
            Management Practice

  8       Evaluation of Specific Southwest Copper Tailings   47
            Pond Sites

  9       Evaluation of Specific Southwest Copper Leach      53
            Dump Sites

 10       Evaluation of Specific Florida and Idaho           57
            Phosphate Waste Rock Dump Sites

 11       Evaluation of Specific Florida Phosphate Tail-     62
            ings Pond Sites

 12       Evaluation of Specific Wyoming Uranium Waste       66
            Rock Dump Sites

 13       Evaluation of Specific New Mexico and Wyoming      71
            Uranium Mine Waste Pond Sites

 14       Evaluation of Specific Nevada and South Dakota     76
            Gold/Silver Tailings Pond Sites
                               IV

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                        TABLES (continued)
Number                                                      Page

 15       Evaluation of Specific Missouri and Tennessee      81
            Lead/Zinc Tailings Pond Sites

 16       Evaluation of Specific Molybdenum Tailings Pond    85
            Sites

 17       Mine Sites Selected for Comprehensive Monitoring   88

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                          INTRODUCTION






     The mining industry, which has been a part of this country's



industrial base from before its founding as a nation, has already



accumulated some 30 billion tons of solid waste.  It is estimated



that approximately 2.3 billion tons are added to this figure each



year.



     Over the past several years, the Congress has shown increas-



ing interest in the environmental effects of the disposal of this



massive amount of material.  Two segments of the industry have



been singled out for particular attention.  The Surface Mining



Control and Reclamation Act of 1977 (SMCRA), administered by the



Department of Interior, is exclusively focused on coal mining and



controls the disposal of coal mining waste.  The Uranium Mill



Tailings Radiation Control Act of 1978 focuses on the need for



proper disposal of the highly radioactive waste material produced



when uranium ore is processed.  This act is enforced by the



Nuclear Regulatory Commission.



     All other mining wastes come under the authority of the most



comprehensive of all solid waste legislation, the Resource Con-



servation and Recovery Act of 1976, and the recently passed



amendments to the Act, the Solid Waste Disposal Act Amendments of



1980.  Mining wastes are specifically mentioned as being included

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in the definition of "solid waste" [Section 1002(a) (27)].  In

addition, Section 8002 instructs EPA to carry out the following

study:

     "(f) Mining Waste - The Administrator, in consultation with
     the Secretary of the Interior, shall conduct a detailed and
     comprehensive study on the adverse effects of solid wastes
     from active and abandoned surface and underground mines on
     the environment, including, but not limited to,  the effects
     of such wastes on humans, water, air, health, welfare, and
     natural resources, and on the adequacy of means  and measures
     currently employed by the mining industry, Government agen-
     cies, and others to dispose of and utilize such  solid
     wastes and to prevent or substantially mitigate  such adverse
     effects.  Such study shall include an analysis of-
          "(1) the sources and volume of discarded material
          generated per year from mining;
          "(2) present disposal practices;
          "(3) potential dangers to human health and  the environ-
          ment from surface runoff of leachate and air pollution
          by dust;
          "(4) alternatives to current disposal methods;
          "(5) the cost of those alternatives in terms of the
          impact on mine product costs; and
          "(6) potential for use of discarded material as a
          secondary source of the mine product.
     In furtherance of this study, the Administrator  shall, as he
     deems appropriate, review studies and other actions of other
     Federal agencies concerning such wastes with a view toward
     avoiding duplication of effort and the need to expedite such
     study.  The Administrator shall publish a report of such
     study and shall include appropriate findings and recommenda-
     tions for Federal and non-Federal actions concerning such
     effects."

This mandate has been slightly changed in the amendments of 1980:

     "Sec. 29, Section 8002 of the Solid Waste Disposal Act is
     amended by-

     (1)  by striking out the last sentence of subsection (f) of
     such section and inserting in lieu thereof the following:
     "Not later than thirty-six months after the date of the
     enactment of the Solid Waste Disposal Act Amendments of 1980
     the Administrator shall publish a report of such study and
     shall include appropriate findings and recommendations for
     Federal and non-Federal actions concerning such  effects.
     Such report shall be submitted to the Committee  on Environ-
     ment and Public Works of the United States Senate and the
     Committee on Interstate and Foreign Commerce of  the United
     States House of Representatives."
                                2

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     The Solid Waste Disposal Act Amendments of 1980 also add a

new mining study as follows:

     "(p)  Materials Generated From the Extraction,  Beneficiation,
     and .Processing of Ores and Minerals,  Including Phosphate
     Rock and Overburden From Uranium Mining-The Administrator
     shall conduct a detailed and comperhensive study on the
     adverse effects on human health and the environment, if any,
     of the disposal and utilization of solid waste from the
     extraction, beneficiation, and processing of ores and min-
     erals, including phosphate rock and overburden from uranium
     mining.  Such study shall be conducted in conjunction with
     the study of mining wastes required by subsection (f) of
     this section and shall include an analysis of-
          "(1)  the source and volumes of such materials generated
          per year;
          "(2)  present disposal and utilization practices;
          "(3)  potential danger, if any, to human health, and the
          environment from the disposal and reuse of such mate-
          rials;
          "(4)  documented cases in which danger to human health
          or the environment has been proved;
          "(5)  alternatives to current disposal methods;
          "(6)  the costs of such alternatives;
          " (7)  the impact of those alternatives on the use of
          phosphate rock and uranium ore,  and other natural
          resources; and
          "(8)  the current and potential utilization of such
          materials.
     In furtherance of this study, the Administrator shall, as he
     deems appropriate, review studies and other actions of other
     Federal and State agencies concerning such waste or materi-
     als and invite participation by other concerned parties,
     including industry and other Federal and State agencies,
     with a view toward avoiding duplication of effort.  The
     Administrator shall publish a report of such study,  which
     shall include appropriate findings, in conjunction with the
     publication of the report of the study of mining wastes
     required to be conducted under subsection (f)  of this sec-
     tion.  Such report and findings shall be submitted to the
     Committee on Environment and Public Works of the United
     States Senate and the Committee on Interstate and Foreign
     Commerce of the United States House of Representatives."

     To eliminate duplication of effort and in recognition that

the two studies are very similar, the Agency has decided to pre-

sent a single report to the Congress by October 21, 1983, touch-

ing on all points mentioned in both Sections  (f)  and  (p)  of 8002.

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The overall focus of that report will be slightly different,



however, based on the perceived intent of the 1980 amendments.



These amendments also contain (Section 7) an exclusion from the



Subtitle C hazardous waste regulations for "solid waste from the



extraction, beneficiation, and processing of ores and minerals



including phosphate rock and overburden from the mining of urani-




um ore."  This exclusion is to remain in effect until six months



after the submission to the Congress of the 8002 studies mentioned



above.  Clearly, the Congress intended EPA to make significant



use of these studies in determining the need for hazardous waste



regulation of waste streams within the mining industry.  While



the original goal of EPA's efforts under Section 8002(f) of RCRA



were the study of mining industry and its waste streams in the



broadest context possible, we feel that the amendments recently



passed instruct us to focus our efforts on those waste streams



which appear at this time to have the greatest potential for



environmental harm.



     This refocusing has come at a most opportune time.  The last



two years have been spent gathering data in the following three



areas:



     0    Broad based statistical information on the industry and



          its disposal practices as a whole, primarily from the



          existing literature.



     0    Overviews of 65 major mining operations from limited



          site visits and the literature.

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     0    Complete characterization and chemical analysis of over



          400 waste samples taken at 65 mining sites (Presurvey).



     Due to the acquisition of the above information, the Agency



is now in a position to focus its efforts on the monitoring of



actual disposal sites to determine the extent of environmental



impact from the disposal of selected mining wastes.  Approxi-



mately $2 million has been allocated for this task.  Although the



exact number of sites which can be adequately monitored given



this amount of money is presently unknown,  it will probably not



exceed 15.  The Agency is now proceeding to its next and most



difficult step, the selection of mining waste disposal sites to



be monitored.  The purpose of the remainder of this document is:



     1.   To explain the method developed by the Agency for



          selecting mining disposal sites to be monitored.



     2.   To pull together all data presently available on



          mining sites for comparison within the framework of



          this method.



     3.   To choose candidate sites for monitoring.



     4.   To describe the future plans and schedule for the



          comprehensive monitoring of these sites.

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                      SITE SELECTION METHOD






     The United States Mining Industry encompasses more than 100



major segments  (e.g., gold, copper, nickel, etc.) and consists of



in excess of 14,000 individual mining sites.  The selection of 10




to 15 sites from a universe of 14,000 is the most difficult



conceptual task of this project.  Clearly, 10 to 15 sites will



not give a cross section view of so diverse an industry.  Thus,



the task here is to develop criteria which will narrow the focus



of the project so that useful, rather than random data can be



produced.



     For the reasons mentioned in the preceeding section of this



report, EPA has decided that it will focus its efforts on those



industry segments, solid waste streams and solid waste management



practices which appear at this stage of the investigation, to



present the greatest potential for environmental damage.  To



achieve this focus EPA has developed a three step method  (Figure



1) which first narrows the possible list of industry segments;



then further narrows the list of practices and waste streams



within these segments to those with the most potential for pol-



lution migration; and then finally assists in choosing sites



typical of those industries, wastes, and practices.



     A major undertaking in the development of the site selection



method was the summarizing of a massive amount of information to




                                6

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STEP I
DETERMINE MINING INDUSTRY
SEGMENTS HO STUDY
           INPUT

•MAGNITUDE  OF  WASTE  GENERATION

 WASTE  CHARACTERISTICS

•POTENTIAL  FOR OTHER IMPACT
STEP II
DETERMINE WASTE MANAGEMENT
PRACTICES AND LOCALES WITHIN
EACH INDUSTRY SEGMENT
 MAGNITUDE  OF  WASTE  GENERATION

 PRESURVEY  WASTE  CHARACTERISTICS

•POTENTIAL  FOR OTHER IMPACT

-TENDENCY  FOR  ENVIRONMENTAL  TRANSPORT

-SIGNIFICANCE  OF  LOCATION  OR DISTRICT
 WITHIN INDUSTRY  SEGMENT
STEP III
SELECT SITES TYPICAL OF
MANAGMENT PRACTICES FOR
COMPREHENSIVE MONITORING
PROGRAM
•PRESURVEY  WASTE  CHARACTERISTICS FOR
 SPECIFIC SITES/PRACTICES

-ENVIRONMENTAL  FACTORS  AFFECTING
 POTENTIAL  FOR  IMPACT

-MONITORING CONSIDERATIONS
     Figure 1.  Waste management practice and site selection process -
                 application of criteria and other input.

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enable the Agency to make decisions.  As such, it is a tool and




is in no way an indication that any specific waste stream is neg-




atively affecting the environment.  In the process of assessing



first the industry segments (Step I) and then individual waste



streams and disposal methods (Step II), values were assigned



ranging from 0 to 3 pluses (+++).  These values signify different



things in different criteria.   Each will be explained clearly in



proper sequence.  No attempt has been made, nor should be made,



to total the number of pluses to assign a "degree of hazard"



rating.  The purpose of the method is to summarize information,



primarily from existing literature, and to visually display



relative, rather than absolute values in order to make choices.



In Step III, negative (-, =)  as well as positive values are



assigned to indicate, for example, the typicality of a specific



site.  A detailed description of the process follows.






STEP I - THE SELECTION OF MINING INDUSTRY SEGMENTS



     The mining industry has been singled out by the Congress for



special study largely because of the enormity of the waste streams



involved.  Clearly, the size of the waste stream is a major cri-



teria in selecting industry segments.  It is not alone, however.



The literature on this subject points to various degrees of po-



tential environmental danger from the waste streams themselves in



the form of radioactivity or cyanide content, for example.  This



step has been designed to narrow the choice of industry segments



to those which have the greatest potential for environmental
                                8

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effect whether through shear size,  inherent waste stream charac-



teristics, or a combination of the  two.




     Four industry segments have been excluded from consideration



in this evaluation.   The basis of the exclusion of these segments



is addressed in the following.



     0    Coal Mining and Preparation.  Wastes from this industry



          are regulated by the Surface Mining Control and Recla-



          mation Act of 1978,  which is administered by the Office



          of Surface Mining within  the Department of Interior.



          The recently passed Solid Waste Disposal Act Amendments



          of 1980 contain sections  instructing EPA to defer to



          the Department of Interior in writing permits under



          Subtitle C of RCRA.   EPA  is now reviewing the SMCRA



          waste disposal regulations and will shortly transmit



          its analysis to the Department of Interior.  As Inte-



          rior is clearly the lead  agency in this area and as



          such, is coordinating its own disposal studies, EPA has



          determined that it would  be needlessly duplicative and



          not in keeping with Congressional intent to include



          coal mining wastes in this study.



     0    Uranium Milling.  Section 1004 of RCRA states, "The



          term "solid waste" means  any garbage, refuse, sludge



          [etc.]...but does not include...source, special nuclear



          or by-product material as defined by the Atomic Energy



          Act of 1954 as amended."   Uranium mill tailings fall



          under this designation and thus are excluded both from

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RCRA and this study.  The proper disposal methods for



this waste product are being developed and regulated



under the Uranium Mill Tailings Radiation Control Act



of 1978 which is enforced by the Nuclear Regulatory



Commission.



Oil Shale Mining Wastes.  Oil shale mining and benefi-



ciation wastes are covered by RCRA and are included in



the exclusion from the Subtitle C regulations (see Page



4).  They are not included in the present study for two



reasons.  First, this investigation has concentrated on



existing mining industry segments.  Although oil shale



mining has been practiced on a small scale in the past,



there are presently no commercial operations nor are



any planned to begin for some time.  At this point,



there is little to study in the context of monitoring



for environmental effects.  Secondly, EPA's Industrial



Environmental Research Laboratory in Cincinnati is now



conducting various studies in the oil shale area and



has more elaborate ones in the planning stage for the



future.  EPA's final report to the Congress will in-



clude the subject of oil shale wastes; however, this



study will not.



In-situ Mining.   Both uranium and shale oil are re-



covered through in-situ mining techniques.  Because



this practice takes place well below the surface of the



earth and leaves most of its residuals "in-situ" or in





                     10

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     place, the Agency has decided to study its effects and to

     regulate it through the underground injection control pro-

     visions of the Safe Drinking Water Act rather than RCRA.

     In-situ mining residues will be dealt with primarily through

     the Safe Drinking Water Act and will not be included in

     either this study or the 8002 (f) and (p) report.

Step I Criteria

A.   The first criteria in the selection of industry segments is

     the magnitude of the waste stream.  Table 1 presents the

     latest available statistics on the tonnage of waste material

     generated by the mining industry.  These statistics have

     been transferred to Table 2 using the following grading

     system to indicate the relative volume of wastes generated

     by individual segments.

            0 = less than 10 million tons per year
            + = 10 to 50 million tons per year
           ++ = 50 to 100 million tons per year
          +++ = greater than 100 million tons per year

     This comparatively simple quantitive ranking indicates  the

     clear importance of the copper, iron, uranium, and phosphate

     segments, all of which generate waste in excess of 100

     million tons per year.  Only crushed stone is in the 50 to

     100 million tons per year category.  The rest of the seg-

     ments are somewhat equally divided between those above  and

     below the 10 million tons per year dividing line.

B.   The second criteria of Step I is that of waste character-

     istics or perceived potential for hazardous environmental
                                 11

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TABLE 1.   ANNUAL  SOLID WASTE PRODUCTION  STATISTICS  AT  SURFACE
                        AND UNDERGROUND  MINES9
                        (thousand  short  tons)

Industry
segment
Metals
Bauxite
Copper
Gold
Iron
Lead
Molybdenum
Silver
Tungsten
Uranium
Zinc
Other'1
Total metals
Nonmetals
Asbestos
Clays
Diatomite
Feldspar
Gypsum
Mica (scrap)
Perlite
Phosphate rock
Potassium salts
Pumice
Salt
Sand and gravel
Sodium carbonate
(natural )
Stone:
Crushed or
broken
Dimension
Talc, soapstone,
pyrophyllite
Total
nonmetal s

Mine
waste5

11,500
378,000
11,800
277,000
2,270
13,100
2,010
210
306,000
1,270
17,000
1,020,000

4,150
43,000
NA
192
2,700
467
107
420,000
163
108
NA
NA
332


82,400

1,620
1,460


572,000

Tailingsc

1,480
260,000
5,400
175,000
8,900
30,400
1,900
1,750
16,200
6,700
NA
508,000

2,180
0
NA
920
700
1,310
294
136,000
17,200
210
1,100
6,000
5,080


0

2,830
420


174,000
Total non-
coal minerals

Total

13,000
638,000
17,200
452,000
11,200
43,500
3,910
1,960
322,000
7,970
17,000
1,510,000

6,330
43,000
NA
1,110
3,400
1,780
401
556,000
17,400
318
1,100
6,000
5,410


82,400

4,450
1,880


724,000
2,230,000

Percent of
total for all
noncoal minerals

<1
29
1
20
<1
2
<1
<1
14
<1
1
68

<1
2
NA
<1
<1
<1
<1
25
<1
<1
•O
<1
<1


4

<1
<1


32


 Based on data obtained from  1978-79 Minerals Yearbook,  U.S. Bureau of Mines.
 Includes overburden from surface mining  operations and  waste discarded
 on the surface from underground mining operations.

cEstimated by PEDCo from data in the 1978-79 Minerals Yearbook.
 Antimony, beryllium, manganiferrous ore,  mercury, nickel,  rare earth metals,
 tin, vanadium.

NA - Quantitative information on these wastes are not compiled since
     relatively insignificant amounts are generated.
                                    12

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                  TABLE 2.   EVALUATION  OF  STUDY INDUSTRY SEGMENTS
Industry segment
Metals
Bauxite
Copper-
Gold
Iron
Lead
Mercury
Molybdenum
Si Iver
Tungsten
Uraniur.3
Zinc
Otherb
Nonmetal s
Asbestos
Clays
Diatomite
Feldspar
Gypsum
Mica (scrap)
Perlite
Phosphate rock
Potassium salts
Pumice
Salt
Sand and gravel
Sodium carbonate
Stone
Crushed and broken
Dimension
Talc, soapstone,
pyrophyll ite
A. Magnitude
of waste
generation

+
444
4
44 +
4
0
4
0
0
444
4
oc

0
4
0
0
4
0
0
444
4
0
0
0
0

44
0

0
B. Waste characteristics
Toxicity

0
44
444
4
44
444
4
444
4
4
44
4

0
0
0
0
0
0
0
4
0
0
0
0
0

0
0

0
Corrosivity

0
44
4
0
4
0
4
4
4
4
4
0

0
0
0
0
0
0
0
0
0
0
0
0
0

0
0

0
Radioactivity

0
0
0
0
0
0
0
0
0
444
0
0

0
0
0
0
0
0
0
44
0
0
0
0
0

0
0

0
C. Other
potential
impacts

4
4
4
4
4
0
4
4
4
4
4
4

4
4
0
0
0
0
4
4
0
0
0
4
0

4
0

0
a Mining  wastes only.
 Antimony,  beryllium,  manganiferrous ore, monzonite, nickel, platinum group metals, rare earth metals,
  tin,  titanium, ilmanite,  vanadium.

cAlthough the  "other" industry segment generates 17 million tons of solid waste annually (Table  1),
 a zero was assigned to it because  no single industry  of the eight segments  included in "other"  generates
 over 10 million tons per year.
                                              13

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impact through the properties of the individual waste

streams.  It should be noted that this step (Step 1)  was

formulated prior to carrying out the Presurvey in which grab

samples were taken at 65 mining sites and extensively

analyzed.  Thus, the information used to construct the

results of this criteria were taken from the literature

available approximately one year ago (October 1979) .   The

results of the Presurvey have, for the most part, substan-

tiated these relative values.  The ranking system for this

criteria falls into three categories:  toxicity, or the

presence of toxic elements in the waste capable of leaching;

corrosivity as determined by pH; and radioactivity,  or the

presence of the radioisotope radium-226.  Because few

specific data were available at the time Step I was formu-

lated, the ranking system is somewhat subjective and con-

tains no numerical boundaries.

            0 = no potential
            + = minor potential
           ++ = moderate potential
          +++ = significant potential

Column B of Table 2 indicates the following:

0    Toxicity - The potential impact of the gold and silver

     segments of the mining industry was believed to be

     significant because of the relatively high concentra-

     tions of cyanide in the tailings from the cyanide-leach

     beneficiating process employed by these precious metal

     industries.  A significant potential hazard was also

     assigned to the mercury segment because of the toxicity

                          14

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          associated with the mercury itself and other heavy



          metals associated with it.  Copper, lead, and zinc




          wastes were believed to have moderate potential for



          hazardous impact because acidic conditions produced by



          the pyritic ores provide a mechanism for dissolution of



          the heavy metals present.  The other metals industries



          were believed to have minor potential for toxicity.  Of



          the non-metal segments, only phosphate was thought to



          have any potential at all and that was minor.



     0    Corrosivity - The copper, gold, lead, molybdenum,



          silver, tungsten, uranium, and zinc industries were



          believed to pose a potential hazard due to the corro-



          sive atmosphere associated with the pyritic ores, which



          are associated with many of these mines.  In addition,



          gold and silver employ a cyanide leach process, which



          was thought to produce tailings which are potentially



          corrosive.



     0    Radioactivity - Uranium mining was believed to have a



          significant potential for hazardous impact because of



          the radioisotopes associated with uranium ores.  The



          phosphate mining segment was believed to have a moder-



          ate potential for hazardous environmental impact be-



          cause of the radioisotopes associated with phosphate



          ores.



C.   The third criteria under Step I has been titled Other Poten-



     tial Impact.  A preliminary evaluation of the potential of





                                15

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various industry segments to either produce sediment loading

of surface waters, degrade air quality through the emission

of fugitive dust, or to negatively effect environmentally

sensitive areas such as floodplains, wetlands, and the

habitats of endangered species.  The grading system under

this criterion is less wide, advancing only to one rather

than three plusses, because the effects are assumed to be of

less importance than the hazardous effects of Criteria B

above.  This criterion is also somewhat subjective and is

based solely on the literature.  The ranking system is as

follows:

          0 = no potential
          + = some potential

Column C indicates the following:

0    Of the metals, copper was expected to show a signifi-

     cant potential for environmental impact under this

     heading, largely because of the potential for fugitive

     dust emissions from the dried-out portions of the

     copper tailings ponds located in the arid West and

     Southwest (Utah, Arizona, and New Mexico).  Uranium

     mine waste dumps and molybdenum tailings ponds were

     believed to have a less significant potential for

     fugitive dust emissions.

0    Almost all of the metals are expected to have some

     effect because of the sediment loading on surface

     waters from erosion of waste rock piles and tailings

     pond dikes.

                          16

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     0    Eighty percent of all phosphate mining takes place in

          Florida; much of this Florida phosphate district is

          located in wetlands, which increases the potential for

          neaative impact from the large volumes of waste materi-

          als generated in these environmentally sensitive areas.

     0    Sand and gravel and crushed stone mining often take

          place within floodplains,  which increases the potential

          impact from these industries in these environmentally

          sensitive areas.

     0    The ore and host rock materials associated with several

          mining industries are known to contain asbestos and as-

          bestos like fibers which can be released to the envi-

          ronment during mining and waste disposal activities.

          These industries include the direct mining of asbestos

          and selective operations in the taconite, vermiculite,

          copper, gold, and talc mining industries.  The asbestos

          association with these industry segments was the major

          contributing factor to the plus value assigned to each

          of these industries.

Results of Step I

     Based on the overall evaluation by criteria (Table 2), and

input from the nine Solid Waste Coordinating Committee*, nine
 This committee was established by FPA to assist in this study
 and in the development of PCRA guidelines and standards for the
 raining industry.   The MSVCC consists of representatives of the
 following:  EPA Regional Offices, EPA's Office of Solid Waste,
 EPA's Office of Pesearch and Development, Bureau of Mines, the
 Geological Survey, the Soil Conservation Service, and the Fish
 and Wildlife Service.  Representative of the American Mining
 Congress and the Interstate Mining Compact acted in an advisory
 capacity.
                               17

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mining industry segments were selected for study:




     0    Copper mining and beneficiating



     0    Uranium mining




     0    Phosphate mining and beneficiating



     0    Zinc mining and beneficiating



     0    Lead mining and beneficiating




     0    Molybdenum mining and beneficiating



     0    Gold mining and beneficiating



     0    Silver mining and beneficiating



     0    Iron mining and beneficiating



     The rationales for these selections are described below:



     0    Copper -- This industry segment had at least some indi-



          cation of potential environmental effect in every



          category.  An industry which generates 29 percent of



          all non-coal mineral waste, wastes which have at least



          some degree of toxicity, corrosivity, and radioactivity,



          was an obvious choice for inclusion in the study.



     0    Uranium - This segment also had some indication of po-



          tential environmental effect in every category.  As the



          fourth largest producer of mining waste as well as the



          waste most likely to prove hazardous due to radioactiv-



          ity, uranium was another obvious choice.



     0    Phosphate - The phosphate segment, because of the mag-



          nitude of the wastes generated (25 percent of all non-



          coal wastes), radioactive contents, and potential neg-



          ative impact on wetlands, was included in the study.




                               18

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Molybdenum - This industry segment was chosen because



of the potential for corrosivity and toxicity from



heavy metals in the 44 million tons of wastes generated



annually.




Zinc and Lead -- Although these industry segments gener-



ate relatively lesser amourits of waste than do the



phosphate, copper,  and uranium segments; nonetheless,



these wastes are significant in size.  In addition,



they were chosen because of the potential for corro-



sivity and toxicity from heavy metals in the waste-



streams, both of which are associated with the pyritic



ores often characteristic of these industries.



     The ores mined for the recovery of lead and zinc



(primarily galena for lead and sphalerite for zinc) are



very often associated with each other in nature, due to



the similar geochemical processes which formed them.



Many ore bodies contain appreciable recoverable quan-



tities of both, such as in the Couer d'Alene lead/zinc/



silver mining district of Northern Idaho.  In other



areas, either lead or zinc is the principal metal



mined, such as in the Missouri Lead Belt or the Eastern



Tennessee zinc mining district.  Regardless, the waste



rock produced from mining these ores, the beneficiating



process employed to concentrate these ores, and conse-



quently the tailings from beneficiating these ores, are



very similar.  Because of these similarities, lead and






                     19

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zinc are discussed together in Steps II and III of the



site selection process.




Gold and Silver - These two industry segments primarily



were chosen because of their potential for corrosivity



and toxicity from heavy metals and particularly because



of the cyanide employed in the beneficiating of these



nrecious metals.



     The association of gold and silver is analogous to



the lead/zinc association, i.e., the ores associated



with these precious metals very often occur together in



nature, due to the similar geochemical processes which



formed them.  Nany ore bodies contain recoverable quan-



tities of both metals; however, depending on the rela-



tive quantities of each, they may be principal gold or



silver mines, or gold/silver mines.  In any case, the



mining operations and beneficiating processes (cyanida-



tion)  and the characteristics of their associated waste



rock and tailings are very similar.  Consequently, gold



and silver are addressed together in Steps II and III



of the site selection process.



Iron - This segment was chosen because it generates ap-



proximately 20 percent of total wastes generated by



non-coal mining industries, and because it was believed



that the taconite tailings posed a potential impact



through toxicity from heavy metals.
                     20

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STEP II - THE SELECTION OF WASTE MANAGEMENT PRACTICES

     Comparatively few waste management practices are used in the

mining industry.  Table 3 presents a matrix of the industry seg-

ments chosen in Step I, and the waste management practices common

to those industries.  As can be seen, waste rock dumps* are com-

mon to all segments.  Tailings ponds are also universally uti-

lized, although this study does not address them in the uranium

area for reasons given on Page 9.  Low grade ore dumps are common

to the copper, uranium, iron, and precious metals industries;

mine water ponds in the uranium, lead/zinc, and molybdenum seg-

ments.  Leach dumps are unique to the copper industry as are sand

tailings piles to phosphate.

     The objective of this step is to determine which industry

wastes and waste management practices are most likely to have an

effect on the environment.  The criteria in this step is closely

akin to that in Step I in that size of the waste stream and

characteristics of the waste are again important determiners.  A

major difference at this step, however, is that actual sampling

data from the presurvey is utilized, making waste characteriza-

tion determinations more defensible.  Table 4 has seven criteria-

A.   As in Step 1, the first criterion is that of size of the

     waste stream as an indicator of the magnitude of the possi-

     ble environmental impact.  The grading system is as follows:
 For simplicity of terminology, waste rock dumps include over-
 burden from surface mining operations and waste discarded on
 the surface from underground operations.

                               21

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                        TABLE 3.   MAJOR INDUSTRY SEGMENT MANAGEMENT PRACTICES
NJ
Management
Practice
Mine waste
rock dumps c
Low grade
ore dumps
Mine water
ponds
Tailings
ponds
Leach dumps
Sand tail-
ings piles
Industry Segment
Copper
X
X

X
X

Uranium
X
X
X
N/Ab


Phosphate
X


X

X
Gold/silver
X
X

X


Lead/zinc
X

X
X


Molybdenum
X

X
X


Iron
X
X

X


            alsolated instances may exist in  which  a  management  practice is occasionally
             employed at some of the industry segments.
             Not within the scope of this study.
            clncludes overburden from surface mining  operations  and/or waste discarded
             on the surface from underground  mining operations.

-------
                                        TABLE 4.    EVALUATION  OF  WASTE MANAGEMENT  PRACTICES
K)
U)
Industry/waste
management practice
Uranium mining
Hine waste rock dumps'
Low grade ore dumps
Hine water ponds
Phosphate
Hine waste rock dumpsa
Tailings ponds
Sand tailings piles
Copper
Mine waste rock dumps
Low grade ore piles
Leach dumps
Tailings ponds
Lead/zinc
Mine waste rock dumps
Tailings ponds
Mine water ponds
Gold/silver
Mine waste rock dumps*
Low grade ore piles
Tailings ponds
Molybdenum
Hine waste rock dumps3
Tailings ponds
Mine waste ponds
Iron
Hine waste rock dumps
Low grade ore piles
Tailings ponds
A. Magnitude
of waste
generation

++t
4-
0

++*
+4
4+

+44
4
•f 4
+++

0
•f
0

•f
0
4

•f
•f
0

+++
-t-t
4-44-
B. Waste characteristics
EP toxicity

4
4
++

+
44
0

+
4-
4-44-
++

44
++
4-f

+
4
+++

0
4
-f

0
0
0
Corrosivity

0
+
0

0
0
+

+
•f
+++
++

0
•f
0

0
+-f
+

4
++
0

0
0
0
Radioactivity

•f-f
+++
•f++

+4
+ 4-
0

0
0
0
0

0
0
0

0
0
0

0
0
0

0
0
0
Cyanide

0
0
0

0
0
0

0
0
0
4-

0
+
0

0
0
+4-4

0
4
0

0
0
0
C. Other
potential
impacts

+
0
0

+
4-
4-

4-
+
4-
+

+
4-
0

4-
+
4-

4-
+
0

4-
4-
4-
D. Tendency
for
environmental
transport

0
0
4-

0
4
0

0
0
+
4-

0
+
+

0
0
+

0
+
4-

0
0
4-
                aWaste rock dumps include overburden from surface mining operations and waste discarded on the surface from underground operations.

-------
                 0 = less than 10 million tons per year
                 + = 10 to 50 million tons per year
                ++ = 50 to 100 million tons per year
               +++ = greater than 100 million tons per year

          The four largest waste streams were uranium and phos-

     phate mine waste rock dumps and copper and iron tailings

     ponds, all of which exceed 100 million tons per year in

     generation.  The phosphate, copper, and iron segments have

     two streams each which are generated at more than 50 million

     tons per year.

B.   The second set of criteria assign values to the character-

     istics of the wastes.  The waste characteristics or proper-

     ties addressed in the current and previously proposed RCRA

     hazardous waste regulations that relate to the mining indus-

     try are EP toxicity  (acetic acid extraction), corrosivity,

     radioactivity, and the use of cyanide in flotation and cya-

     nidation processes.  These properties were determined for

     the Presurvey waste samples and employed as a measuring de-

     vice to evaluate the relative potential hazardous impact of

     each industry segment waste management practice.  (For fur-

     ther details on mining waste characteristics see the Pre-

     survev Report for this study).  The following values were

     assigned under the waste characteristics criteria:

EP Toxicity;

      0 = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP* are less
          than specified in "primarv drinking water standards"
          (PDWS).
*
 Waste Management Practice.
                                24

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      + = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than specified in PDWS,  but less than 10 times the
          PDWS.

     ++ = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than 10 times specified  in PDWS, but less than 100
          times  the PDWS.

    +++ = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than 100 times the PDWS.

Corrosivity:

      0 = Liquids within the WMP have a pH between 4 and 10;
          solids have a potential  acidity* of less than 500 yg
          carbonate/g of material.

      + = Liquids within the WMP have a pH between 3 and 4 or
          between 10 and 11; solids have a potential acidity of
          greater than 500 but less than 5000 yg carbonate/g of
          material.

     ++ = Liquids within the WMP have a pH between 2 and 3 or
          between 11 and 12.5; solids have a potential acidity of
          greater than 5,000 but less than 50,000 yg carbonate/g
          of  material.                                          *

    +++ = Liquids within the WMP have a pH less than 2 or greater
          than 12.5; solids have a potential acidity of greater
          than 50,000 yg carbonate/g of material.

Radioactivity:

      0 = Liquids or solids within the WMP have radium 226 values
          of  less than 4.0 pCi/liter or 4.0 pCi/g, respectively.

      + = Liquids or solids within the WMP have radium 226 values
          greater than 4.0, but less than 10 pCi/liter or 10
          pCi/g, respectively.

     ++ = Liquids or solids within the WMP have radium 226 values
          greater than 10 but less than 50 pCi/liter or 50 pCi/g,
          respectively.

    +++ = Liquids or solids within the WMP have radium 226 values
          greater than 50 pCi/liter or 50 pCi/g, respectively.
 Potential acidity of solid samples was determined to measure
 their acid forming potential.
                               25

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Cyanide;




      0 = Cyanide is not added or used in the processing of ore.




      + = Sulfide flotation process employs cyanide.



    +++ = WMP includes leach cyanidation process waste.



     This rating system revealed the following:




     0    Wastes from copper leach dumps/ lead/zinc tailings



          ponds and mine water ponds, and gold/silver tailings



          ponds have the highest potential for EP toxicity;



     0    Wastes from copper leach dumps and tailings ponds,



          lead/zinc tailings ponds, gold/silver low-grade ore



          piles, and molybdenum tailings ponds have the highest



          potential for corrosivity;



     0    Wastes from uranium mine waste rock dumps, low-grade



          ore dumps, and mine water ponds, and phosphate mine



          waste rock dumps and tailings ponds have the only ele-



          vated levels of radioactivity.



     0    Wastes from gold/silver tailings ponds appear to be the



          only wastes having significant concentrations of cyanide,



C.   The third set of criteria, other potential impact,  as in



     Step I, assigns values for impact from sediment loading of



     surface waters, air quality degradation from fugitive dust,



     and location within environmentally sensitive areas.  The



     following rating system was used for this criterion:



          0 = No potential



          + = Some potential
                               26

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     The potential impact from copper mine waste rock dumps and

copper tailings ponds is believed to be significant because of

the possible degradation of air quality by fugitive dust emis-

sions.  The potential for impact from the three waste management

practices used in the phosphate mining segment is believed to be

significant because much of the Central Florida phosphate dis-

trict is located in wetlands.

D.   The last criterion to be considered, factors affecting

     tendency for environmental transport of waste, addresses the

     potential for transport of waste material and its hazardous

     constituents into the surrounding environment.  The major

     factors contributing to this tendency are small particle

     size and the presence of water in the disposal area, both of

     which can increase the dissolution of waste constituents

     that may ultimately contaminate ground water and/or surface

     water.

     The following rating was used for this criterion:

          0 =  Physical characteristics of material disposed of
               within WMP and the disposal area have significant
               potential for dissolution of constituents.

          -I- =  Physical characteristics of materials disposed of
               within WMP or the disposal area itself can con-
               tribute signficantly to increased potential for
               dissolution of constituents.

Small particle size and prevailing wet conditions are character-

istic of tailings; therefore,  tailings ponds in each of the nine

industry segments were considered to have a significant tendency

for environmental transport.  Mine water ponds in the uranium,
                               27

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lead/zinc, and molybdenum mining  segments also have these  char-
acterisitcs  and  are similarly rated.
Results of Step  II
     The major results of this  step  are the following:
     0    Of the seven industry segments resulting from  Step I,
          the only  industry which does not appear to  pose  a sig-
          nificant  risk to the  environment is the iron industry.
          Each of the other industry segments employ  one or more
          waste  management practices which appear to  pose  a po-
          tentially significant impact.  From the remaining in-
          dustries, nine waste  management practices were selected
          for study (Table 5).  The  rationales for their selec-
          tion are  given below.   (See Table 4 for waste  manage-
          ment practice criteria  and results).

              TABLE  5.  WASTE MANAGEMENT  PRACTICES SELECTED
                       FOR FURTHER CONSIDERATION
                      Uranium mine waste rock dumps
                      Uranium mine water ponds
                      Phosphate tailings ponds
                      Phosphate mine waste rock dumps
                      Copper leach dumps
                      Copper tailings ponds
                      Lead/zinc tailinqs ponds
                      Hold/silver tailinqs ponds
                      Molybdenum tailings ponds

                                 28

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Copper Mining Segme'nt--




     0    Tailings Ponds - The copper mining industry disposes of



          approximately 260 million tons (12 percent of all non-



          coal mine wastes) of potentially corrosive and toxic



          tailings annually (elevated levels of cadmium and sele-



          nium in fresh tailings, settled tailings, and dike ma-



          terial) .  Tailings ponds scored pluses in 6 out of 7



          categories and became an obvious choice for inclusion



          in this study.



     0    Leach Dumps - The leach liquors from this management



          practice exhibited corrosivity characteristics that



          could be detrimental to the environment (pH <2).   Cor-



          rosivity is believed to be attributable to both the



          pyritic constituents of the dump leach material and the



          sulfuric acid which is often employed to enhance the



          leaching process.  Also, elevated levels of cadmium and



          selenium were found in dump leach piles, constituting



          the potential for negative impact from toxicity.   This



          management practice had pluses in five of the seven



          possible categories, based on potential for toxicity



          and corrosivity, making this management practice anoth-



          er obvious choice.






Phosphate Mining Segment--



     0    Mine Waste Rock Dumps - A management practice which an-



          nually disposes of 420 million tons  (19 percent of



          total non-coal mine wastes) of potentially radioactive






                               29

-------
          (many samples had radium 226 concentrations greater



          than 5 pCi/g) and toxic (elevated levels of selenium



          and cadmium)  wastes is another obvious choice for the



          comprehensive monitoring phase.  This waste management



          practice had pluses in four (toxicity, radioactivity,



          magnitude of waste and under ''other impacts" for fugi-



          tive dust emissions)  of the seven possible categories.



     0    Tailings Ponds - This waste management practice had



          pluses in all but two (corrosivity and cyanide) of the



          seven possible categories.  The presurvey results



          revealed elevated levels of radium 226 (some of the



          tailings liquid fractions exceeded 50 pCi/liter) and



          heavy metals (cadmium, selenium, chromium, and lead).



          Because there appears to be a significant potential for



          migration of the radium 226 and heavy metals from the



          68 million tons of phosphate clay tailings generated



          annually, this waste management practice was selected



          for more comprehensive study.






Uranium Mining Segment--



     0    Mine Waste Rock Dumps - Each year, the uranium industry



          disposes of more than 300 million tons of waste rock



          (approximately 14 percent of all non-coal mine wastes).



          Analytical results from the presurvey show this materi-



          al to exhibit radioactivity levels ranging from 1.71 to



          46.6 pCi/g.  Because of the magnitude of these wastes,



          their radioactive and toxic characteristics, and the



                               30

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          potential for fugitive dust emissions, this management



          practice scored four pluses out of seven categories and



          became another obvious choice for comprehensive study.



     0    Mine Water Ponds - Although these ponds represent rela-



          tively lesser volumes of wastes than the other practices



          chosen for comprehensive study, there appears to be po-



          tential for impact to groundwater with elevated, levels



          of heavy metals and radium 226 in these waste streams.



          The Presurvey data indicated elevated levels of radium



          226 (concentrations as high as 416 pCi/liter) and ele-



          vated levels of barium, apparently from the barium



          chloride employed to remove radium 226 from the mine



          water prior to discharge.   For these reasons, uranium



          mine water ponds were chosen for further study, despite



          the fact that this waste management scored pluses in



          only three of the seven categories.






Lead/Zinc Mining Segment--



     0    Tailings Ponds •- The Presurvey results indicated the



          presence of elevated levels of lead, zinc, mercury,



          cadmium, chromium, selenium, and silver in lead/zinc



          tailings.   Because of the great potential for migration



          of these heavy metals from the 16 million tons of lead/



          zinc tailings generated annually, this management prac-



          tice was selected for more comprehensive study.  This



          management practice rated pluses in all but one (radio-




          activity)  of the seven categories.




                               31

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Gold/Silver Mining Segment—




     0    Tailings Ponds - This waste management practice scored




          pluses in all but one (radioactivity)  of the seven pos-



          sible categories.  The Presurvey results revealed ele-



          vated levels of lead, cadmium, selenium, mercury, sil-



          ver, chromium, and cyanide.  Because of the great po-



          tential for migration of these heavy metals and cyanide



          from the 8 million tons of gold/silver tailings gener-



          ated annually, this management practice was selected



          for comprehensive monitoring.



Molybdenum Mining Segment--



     0    Tailings Ponds - This waste management practice scored



          pluses in six of the seven possible categories.  The



          Presurvey results indicated slightly elevated levels of



          arsenic, lead, selenium, and cadmium.   In addition,



          cyanide is used in the beneficiating processes.  Corro-



          sivity characteristics were also reported in the Pre-



          survey results.  Because there appears to be a signif-



          icant potential for migration of these heavy metals



          from the 30 million tons of molybdenum tailings gener-



          ated annually, this waste management practice has been



          selected for further study.



Selection of Specific Mining Districts



     Having selected the waste management practices listed above,



it was necessary to focus on the geographic location of these



industries to choose the most significant locations for study.



As will be seen on the maps which follow, each industry segment





                               32

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has one to three major producing  locales.   These  major mining

districts naturally tend to have  mining  sites  which are similar

to each other in soils, geologic  strata,  and climatic  conditions.

The maps-clearly point out these  major districts.   Because fund-

ing limits the number of sites which can  be visited, each map is

accompanied by an explanation of  the Agency's  decision to study

one district over another.  Table 6 gives  the  major ore producing

districts for each of the industry segments.
        Figure 2.  Geographic distributions and  copper ore production
                contributions of major producing states.


 Copper .Mining Industry Segment

      The major copper producing district is  the  Southwest (Ari-
 zona and New Mexico), which accounts for 78  percent  of U.S.  pro-
 duction (Table 6, Figure 2).  The  large  open-pit mines and asso-
 ciated waste management practices  in this  area are also fairly
 typical of open pit operations in  Utah and Montana.   This region
 has consequently been selected to  comprehensively monitor both
 copper tailings ponds and leach dumps.

                                33

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        TABLE 6.  MAJOR PRODUCING REGIONS WITHIN INDUSTRY SEGMENTS'
         Industry
          segment
  Major
producing
  states
Ore production
1000 short tons,
 (% of total)
         Copper
         Lead/zinc
         Molybdenum


         Phosphate rock




         Gold/silver
         Uranium
Arizona
Utah
New Mexico
Montana
Missouri
Tennessee
Idaho
Colorado
New Mexico

Florida       .
Western states
Tennessee
Nevada
South Dakota
Idaho
Colorado
New Mexico
Wyoming
Other0
 152,000  (68)
   30,900  (14)
   22,100  (10)
   14,000   (6)
    7,430  (60)
    2,930  (24)
     680   (6)
   26,400  (83)
    5,330  (17)

  157,000  (94)
    7,310   (4)
    2,890   (2)
    4,180  (55)
    1,580  (21)
      775  (10)
      205   (3)
    3,400  (37)
    3,320   36
    2,480  (27
Information obtained from 1978-1979 Minerals Yearbook.   U.S.  Bureau of Mines.
Includes Alabama,  Idaho,  Montana,  Utah,  and Wyoming.
Includes Colorado, Texas, Utah,  and Washington.
                                    34

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                                                         94%
      Figure 3.  Geographic distribution and phosphate ore production
               contributions of major producing states.
Phosphate Mining Industry Segment

     The domestic phosphate mining industry consists  of  about  40
mines.  All the mines except one, which  is located  in Montana,
mine phosphate rock by surface mining methods.  Florida  is  the
major producing state accounting for more than  90 percent of the
U.S. production (Table 6, Figure 3).  Idaho, the next major pro-
ducing state, is responsible for about 4 percent of the  domestic
production.  Although this production is considerably less  than
that for Florida, phosphate mining is nonetheless a significant
and major industry in Idaho.

     Large quantities of overburden and waste rock  are generated
by both Florida and Idaho phosphate mining operations.   Both of
these states have therefore been chosen as the  areas  in  which  the
impact from phosphate waste rock piles may be comprehensively
monitored.  The specific reasons for selecting  both areas are  as
follows:  1) both states are leading producers  of phosphate rock;
2) the chemical characteristics of Florida phosphate  waste  rock
are distinctly different from those of Idaho waste  rock; and 3)
waste management practices utilized in these two areas are
distinctly different.

     Operations in Florida and Idaho both produce tailings; how-
ever, the amount generated by the Florida industry  is substan-
tially larger than the amount generated by the  Idaho  industry.
This is mainly due to the larger amount  of phosphate  rock that  is
concentrated by the Florida industry and the lower  grade of Flor-
ida phosphate rock.  Therefore, Florida has been chosen  as  the
area for monitoring phosphate tailings ponds.
                                 35

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       Figure 4.  Geographic  distribution and uranium ore production
               contributions of major producing states.
Uranium Mining Industry Segment

     Uranium is mined at more than  200  operations  in western
states, (Table 6, Figure 4) with New Mexico  and  Wyoming the
leaders, producing 37 percent and 36 percent of  this country's
uranium oxide, respectively.  About 75  percent of  all uranium
mines are underground operations, the largest of which are lo-
cated in New Mexico.  The remaining mines  are large, open pit
operations, concentrated primarily  in Wyoming.

     The vast majority of uranium mine  waste rock  is generated by
the large, open pit mines in Wyoming  (underground  mines produce
relatively insignificant amounts of mine waste rock as compared
to surface mines).  Therefore, Wyoming  has been  chosen as the
mining area in which the impact from uranium mine  waste rock
piles will be comprehensively monitored.

     Mine water ponds in the uranium mining  industry are commonly
employed at both the underground operations  of New Mexico and the
large surface mines in Wyoming.  Because both of these areas are
major producers of uraniun, New Mexico  and Wyoming have been
chosen as the mining areas in which the impact from uranium mine
water ponds will be comprehensively monitored.
                                 36

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     Figure 5.  Geographic distribution and gold/silver ore production
               contributions of major producing states.
Gold/silver Mining Industry  Segment

     The domestic gold/silver mining  industry consists of more
than 175 mines, nearly all in Western states.   About a third of
these mines produce gold and silver as a principal product; the
remainder are base metal mines  (e.g., copper,  lead, zinc) which
recover gold and silver as byproducts at smelters.  The principal
gold/silver producing states are  Nevada (55%),  South Dakota
(21%), and Idaho (10%)(Table 6, Figure 5).   The one mine in South
Dakota and all the mines in  Nevada employ the cyanidation tech-
nique for beneficiating the  ore.  Because the environment of the
principal gold/silver producing states of South Dakota and
Nevada are considerably different, both these areas have been
chosen for the comprehensive monitoring phase.
                                37

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      Figure 6.  Geographic distribution and lead/zinc ore production
               contributions of major producing  states.
Lead/Zinc Mining  Industry  Segment

     One of the most widely  scattered of the industry segments  is
the lead/zinc segment.   Lead/zinc ores are recovered as a primary
product at about  50 mines.   Missouri, Tennessee, and Idaho account
for about 60, 24, and  6  percent of these ores, respectively
(Table 6, Figure  6).   Missouri  is the major lead producing region,
while Tennessee is the major zinc producer.  The majority of
mines in the lead/zinc industry are underground operations.
Because both Tennessee and Missouri are the major producing
mining districts  of these  metals, each district has been chosen
to be included in the  comprehensive monitoring program.
                                 38

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     Figure 7.  Geographic distribution and molybdenum ore production
               contributions of major producing states.
Molybdenum Mining Industry Segment

     There are only three primary molybdenum  mines;  two are lo-
cated in Alpine/sub-Alpine environments  in  Colorado  while the
third is situated in the mountainous  region of  northern New Mexi-
co  (Table 6, Figure 7).  One of the Colorado  mines  is an under-
ground operation while the other has  both surface  and underground
workings.  The New Mexico mine has recently changed  from open pit
to underground.  The two Colorado mines  accounted  for over 83
percent of the total molybdenum produced in 1979.  Production
from the New Mexico mine has dropped  off due  to the  ongoing
changeover from surface to underground operations.

     The two Colorado mines currently contribute about 80 percent
of the mill tailings generated by the primary molybdenum industry,
In addition, future expansion of this industry  segment will prob-
ably involve development of one or more  primary molybdenum mines
in Colorado.  For these reasons, Colorado has been  chosen as the
mining area in which the impact from  molybdenum mill tailings
ponds will be comprehensively monitored.
                                 39

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     Table  7  presents the  final list of waste management prac-

tices selected for the study  in Step II.


            TABLE 7.  MINING  DISTRICTS TO BE  STUDIED FOR EACH
                       WASTE MANAGEMENT PRACTICE

             Southwest copper tailings ponds

             Southwest copper leach dumps

             Florida and Idaho phosphate mine waste rock dumps

             Florida phosphate tailings ponds

             Wyoming uranium waste rock dumps

             Wyoming and New  Mexico uranium mine water ponds

             Nevada and South Dakota gold/silver tailings ponds

             Missouri and Tennessee lead/zinc tailings ponds

             Colorado molybdenum tailings ponds


STEP III  -  SELECTION OF SITES FOR MONITORING

     The  objective of this final step is to choose sites for  air,

surface,  and  groundwater monitoring which  are typical or most

representative of the industry segments and waste management

practices which have been  chosen in Steps  I and  II.

     This step is thus significantly different from the first

two.  As  mentioned earlier, Steps I and II have  sought to find

the streams and practices with comparatively high levels of risk

for the environment.   The  criteria in Step III will now be uti-

lized to  find  sites which  are (1)  typical  of the  practices which

they will represent and  (2) amenable to monitoring and data in-

terpretation.   The criteria for each industry segment, and each
                                 40

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industry segment will be explained separately, will thus fall in-

to two major categories:  typicality of the site and ability to

monitor.

Step III Selection Criteria

     The somewhat complex criteria used in Step III are explained

in the following paragraphs.


Typicality of the Site—

     There are two subcriteria for consideration in this section,

waste characteristics and environmental factors.

     Waste characteristics—Although the waste managment practices

were considered to be fairly consistent among sites within a

district, as was expected, the degree of variation of waste

characteristics was greater from site to site.  Since it is the

Agency's intention to select sites that are typical of the se-

lected mining districts, it was important to choose sites whose

wastes exhibited characteristic values (0 to +++)  most frequently

repeated with other site wastestreams.  This minimized, the chances

for selecting sites whose wastes are more/less representative of

the norm.

     The grading for this subcriteria is similar to that already

discussed in Step II; however, it is applied to individual sites

for each of its waste management practices.  The grading system

is outlined below:

EP Toxicity:

      0 = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are less
          than specified in "primary drinking water standards"
          (PDWS).
                               41

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      + = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than specified in PDWS,  but less than 10 times the
          PDWS.

     ++ = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than 10 times specified  in PDWS, but less than 100
          times the PDWS.

    +++ = Concentrations of one or more metals in liquids or acid
          extracts of solid materials within the WMP are more
          than 100 times the PDWS.

Corrosivity:

      0 = Liquids within the WMP have a pH between 4 and 10;
          solids have a potential  acidity of less than 500 yg
          carbonate/g of material.

      + = Liquids within the WMP have a pH between 3 and 4 or
          between 10 and 11; solids have a potential acidity of
          greater than 500 but less than 5000 yg carbonate/g of
          material.

     ++ = Liquids within the WMP have a pH between 2 and 3 or
          between 11 and 12.5; solids have a potential acidity of
          greater than 5000 but less than 50,000 yg of carbonate/g
          of material.

    +++ = Liquids within the WMP have a pH less than 2 or greater
          than 12.5; solids have a potential acidity of greater
          than 50,000 yg carbonate/g of material.

Radioactivity:

      0 = Liquids or solids within the WMP have radium 226 values
          of less than 4.0 pCi/liter or 4.0 pCi/g, respectively.

      + = Liquids or solids within the WMP have radium 226 values
          greater than 4.0 , but less than 10 pCi/liter or 10
          pCi/g, respectively.

     ++ = Liquids or solids within the WMP have radium 226 values
          greater than 10 but less than 50 pCi/liter or 50 pCi/g,
          respectively.

    +++ = Liquids or solids within the WMP have radium 226 values
          greater than 50 pCi/liter or 50 pCi/g, respectively.
                                42

-------
Cyanide:

      0 = Cyanide is not added or used in the processing of ore.

      + = Sulfide flotation process employs cyanide.

    +++ = WMP includes leach cyanidation process waste.

     Environmental factors—The effects from climate and hydro-

geological conditions were another important consideration for

selecting typical sites.  With few exceptions,  differences in

precipitation/evaporatranspiration ratios were  not anticipated

for sites within a given district; however, proximity to surface

and groundwaters was expected to be more variable.  Once again,

the intent was to select sites whose underlying hydrogeological

profiles are most representative of the district.   Specific con-

ditions considered and the grading system for each are as follows:

Precipitation/Evapotranspiration Ratio:

      - = Ratio for the area in which a particular WMP exists is
          less than 0.5.

      0 = Ratio for the area in which a particular WMP exists is
          equal to or greater than 0.5 but less than 1.0.

      + = Ratio for the area in which a particular WMP exists is
          equal to or greater than 1.0 but less than 1.5.

     ++ = Ratio for the area in which a particular WMP exists is
          equal to or greater than 1.5.

Proximity of Waste Management Practice to Surface Water:

      0 = Surface water greater than a mile from the WMP.

      + = Surface water is between 200 yards and a mile of the
          WMP.

     ++ = Surface water is within 200 yards of WMP.
                                43

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Proximity of Waste Management Practice to Groundwater:

      0 = Groundwater depth at WMP is expected to be more'than
          150 feet.

      + = Groundwater depth at WMP is expected to be between 50
          and 150 feet.

     ++ = Groundwater depth at WMP is expected to be less than 50
          feet.
Monitoring Considerations—

     A second major criterion for selecting sites under Step III

was various monitoring considerations, including existing moni-

toring installations and external influences that would adversely

affect an effective monitoring program.

     Existing monitoring program—Under this criterion, a site

having an existing monitoring installation would be favored over

another site where monitoring is nonexistent.  The advantages

would be a saving of monies and an existing bank of historical

data to verify new data collected under this study.

     External influences—The external influences that were con-

sidered included the following:

     The location of the waste management practice in proximity

to another mining or non mining operation—Isolated management

practices were favored over management practices in close prox-

imity to other operations.  This gave added assurance that the

data will demonstrate a direct cause and effect relationships for

the specific management practice being studied.

     Age of operation—Established sites were favored over newly

developed sites to allow potential contamination to be mobilized


                                44

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and thus detectable.  In most cases, waste management practices

in existence less than four or five years were given less consid-

eration for final selection than older practices.

     Mixing of two or more waste streams—Some sites routinely

mix wastes from different sources.  These practices were less

preferable for selection than wastes that were maintained sepa-

rately.

     The following rating system was used for monitoring consid-

erations :

Monitoring Program:

      0 = There are no monitoring programs for surface water and/
          or groundwater.

      + = General site monitoring of surface water and/or ground-
          water is being conducted.

     ++ = Monitoring of the WMP for surface water and/or ground-
          water is being conducted.

External Influences:

      0 = No problems are expected in the monitoring of ground-
          water or surface water at a particular WMP.

      - = Some problems are expected in the monitoring of ground-
          water or surface water at a particular WMP, but they
          are believed to be resolvable.

     — = Unresolvable problems are expected in the monitoring of
          groundwater or surface water at a particular WMP  (elim-
          inates management practice from further consideration).

Step III - Results

     The sites selected based on Step III criteria for the com-

prehensive monitoring program are presented for each industry

segment waste management practice in the following sections.
                               45

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Southwest Copper Tailings Pond Sites

     Approximately 200 million tons of tailings are generated an-

nually at copper mines in the Southwest, accounting for about 9

percent of the total non-coal mining industry solid wastes.  Cop-

per in this district is recovered from sulfide ores (principally

chalcopyrite).  Typically, tailings are disposed of in on-site,

unlined ponds with recycle of tailings water to the beneficiating

process.  Tailings dikes are typically constructed of coarse

tailings.

     Based on the application of Step III Criteria to the six

Southwest Copper Presurvey Sites (Table 8),  four sites were

selected for comprehensive monitoring:
     0    Pima Mine (No. 28)
     0    San Manuel Mine (No. 30)
     0    Sierrita Mine  (No. 31)
     0    Morenci Mine  (No.  32)
Pima Mine—

     The Pima Mine is owned by the Cyprus Pima Mining Company,

which is owned by Cyprus Mines Corporation, Union Oil, and Utah

International and is located about 20 miles southwest of Tucson,

Arizona.  This site was selected because:

     (1)  The waste management practice is typical of other
          Southwest copper tailings ponds.

          0    Unlined pond with recycle of tailings water to
               beneficiation process  (no discharge).

          0    Tailings dike construction consists of a small
               earthen starter dam and coarse tailings.

     (2)  Presurvey waste characteristics are typical of other
          Southwest copper tailings ponds sampled during the Pre-
          survey.


                               46

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TABLE 8.  EVALUATION OF SPECIFIC SOUTHWEST COPPER TAILINGS POND SITES



Site
Ho.
28
29
30
31
32
33
Typicality of waste management practice
Haste characteristics

EP
toxlclty
44
4+
4-f
44
44
44


Corros1v1ty
0
0
4
44
4
44

Radio-
activity
0
0
0
0
0
0


Cyanide
4
0
4
0
0
0
Environmental factors
Precipitation/
evapotrans-
plratlon ratio
-
-
-
-
-
-

Proximity to
surface water
0
0
+
0
+
•f

Proximity to
groundwater
0
0
0
0
0
0


Existing
monitoring
program
++
4
4
+-f
44
4

External
Influences
0
0
-
0
-
-

-------
          0    Some liquid samples and/or EP acid extracts of
               settled solids or dike material revealed concen-
               trations of certain metals which were greater than
               10 but less than 100 times the PDWS (2 pluses in
               Table 8).

          0    Cyanide is employed in the sulfide flotation
               process (one plus in Table 8).

     (3)  Environmental factors are typical of other Southwest
          copper mining operations.

          0    Elevation is approximately 3,000 feet with rela-
               tively flat terrain.  Located on a pediment of the
               Sierrita Mountains.  Climate is semi-arid.

          0    The substrata underlying the tailings pond con-
               sists of relatively thin layer of sand and gravel,
               soil, siliceous material with some carbonate ce-
               mentation (50-200 feet thick) overlying siliceous
               igneous bedrock.

          0    It is located in the Santa Cruz drainage basin,
               more than a mile from the Santa Cruz River—(a
               rating of zero in Table 8).

          0    Groundwater in the area of the tailings ponds
               occurs at a depth of 200 to 400 feet  (a rating of
               zero in Table 8).

     (4)  Monitoring Considerations

          0    Several water supply wells located on site are
               periodically monitored.  Also, some groundwater
               monitoring around the tailings pond area has been
               conducted by the Pima Association of Governments.
               (2 pluses in Table 8.)

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


San Manuel Mine--

     The San Manuel Mine is owned by the Magma Copper Company, a

subsidiary of Newmont Mining Corporation, and is located about 34

miles northeast of Tucson,  Arizona.  This site was selected be-

cause :

                                48

-------
(1)   The  waste  management  practice  is  typical  of  other
     Southwest  copper  tailings  ponds:

     0     Unlined  pond with  recycle of decant  water  to  the
          beneficiation process.

     0     Tailings.pond dike is constructed  of coarse tail-
          ings  separated through  the use  of  cyclones placed
          on  the birm.

(2)   Presurvey  waste characteristics are  typical  of  other
     Southwest  copper  tailings  ponds sampled during  the Pre-
     survey :

     0     Some  liquid  samples and/or EP acid extracts of
          settled  solid or dike material  revealed concentra-
          tions of certain metals which were greater than 10
          but less than 100  times the  PDWS  (2  pluses in
          Table 8).

     0     Cyanide  is employed in  the sulfide flotation
          process  (one plus  in  Table 8).

(3)   Environmental factors are  typical of other Southwest
     copper mining operations.

     0     Sparsely vegetated, gently rolling terrain in a
          semi-arid setting  typical of copper  mining opera-
          tions in the Tucson area.

     0     The substrata underlying  the tailings pond con-
          sists of siliceous material  with  some carbonate
          cementation  overlying siliceous igneous bedrock.

     0     It  is located in the  San  Pedro  River drainage
          basin less than  one mile  from the  river (a rating
          of  one plus  in Table  8).

     0     Groundwater  in the area of the  ponds occurs at
          depths of 200 to 300  feet (a rating  of  zero in
          Table 8).

(4)   Monitoring Considerations

     0     Groundwater  obtained  from 1,000 foot deep  wells
          pumping  from a supply aquifer is  periodically mon-
          itored  (one  plus in Table 8).

     0     Plant wastes, other than  beneficiation  tailings,
          are sent to  the  tailings  ponds.  These  wastes in-
          clude smelter wastewaters and solid  and liquid
                          49

-------
               domestic wastes.   This practice of combining
               wastes results in a minus under External Influ-
               ences in Table 8.  This practice is common at a
               number of copper  mining operations and domestic
               wastes discharged to the tailings pond is rela-
               tively insignificant.


Sierrita Mine—

     The Sierrita Mine is owned  by the Duval Corporation, a sub-

sidiary of Penzoil Company and is located about 15 miles south of

Tucson, Arizona.   This site was  selected because:

     (1)  The waste management practice is typical of other
          Southwest copper tailings ponds:

          0    Unlined pond with recycle of tailings water to
               beneficiation process (no discharge).

          0    Tailings dike construction consist of a small
               earthen starter dam and coarse tailings.

     (2)  Presurvey waste characteristics are typical of other
          copper tailings ponds  sampled during the Presurvey:

          0    Some liquid samples and/or EP acid extracts of
               settled solids or dike material revealed concen-
               trations of certain metals which were greater than
               10 but less than  100 times the PDWS  (2 pluses in
               Table 8).

     (3)  Environmental factors  are typical of other Southwest
          copper mine operations.

          0    Gently rolling topography  (elevation 3,500 feet)
               in a semi-arid setting typical of copper mining
               operations in the Tucson, Arizona area.

          0    The substrata underlying the tailings pond con-
               sists of siliceous material with some carbonate
               cementation overlying siliceous igneous bedrock.

          0    It is located in the Santa Cruz drainage basin,
               with drainage to  the east  (approximately 5 miles
               from the Santa Cruz River—a rating of zero in
               Table 8).

          0    Groundwater in the tailings pond area occurs at a
               depth of 200-500  feet (a rating of zero in Table 8)

                                50

-------
     (4)  Monitoring Considerations

          0    The groundwater in the tailings pond area is being
               monitored; 13 monitoring wells located east and
               south of tailings dike (two pluses in Table 8).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Morenci Mine--

     The Morenci Mine is owned by the Phelps Dodge Corporation,

and is located in Morenci,  Arizona along the Arizona-New Mexico

border.  This site was selected because:

     (1)  The waste management practice is typical of other
          Southwest copper tailings ponds:

          0    Unlined pond with recycle of tailings water to
               beneficiation process (no discharge).

          0    Tailings dike construction consists of a small
               earthen starter dam and coarse tailings.

     (2)  Presurvey waste characteristics are typical of other
          copper tailings ponds sampled during the Presurvey:

          0    Some liquid samples and/or EP acid extracts of
               settled solids or dike material revealed concen-
               trations of certain metals which were greater than
               10 but less than 100 times the PDWS  (2 pluses in
               Table 8).

     (3)  Environmental factors are typical of other Southwest
          copper mine operations.

          0    Mountainous topography (elevation 3,600 - 6,500
               feet) in a semi-arid setting typical of copper
               mining operations in Southeastern Arizona - South-
               western New Mexico.

          0    The substrata underlying the tailings pond con-
               sists of siliceous material with some carbonate
               cementation overlying siliceous igneous bedrock.
                                51

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          0    It is located in the San Francisco drainage basin,
               with drainage to the east (approximately 3/4 mile
               from the San Francisco River—a rating of one plus
               in Table 8).

          0    Groundwater in the tailings pond area occurs at a
               depth of 115-240 feet (a rating of zero in Table 8)

     (4)   Monitoring Considerations

          0    The groundwater level in the tailings pond area is
               monitored on a weekly basis.  In addition, there
               are process water supply wells within 1/4 mile of
               the tailings pond.  (2 pluses in Table 8).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Southwest Copper Leach Dump Sites

     Mine waste material is leached to recover its copper content

at some Southwest copper mining operations.  Typically copper

bearing material is piled above grade and leached with water or

acid.  The leachate or pregnant leach liquor is collected and the

copper is subsequently recovered from the leachate by precipita-

tion with iron scrap.  The portion of the total mine waste mate-

rial generated at a site which is subjected to leaching varies

considerably from site to site.

     Based on the application of the Step III Criteria to the two

Southwest copper leach dumps sites visited during the Presurvey

(Table 9), one site was selected:

     0    Chino Mine (No. 33)


Chino Mine—

     The Chino Mine is owned by the Kennecott Corporation and is

located near Hurley, New Mexico which is in the southwest portion

of the state.  This site was selected because:

                                52

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                  TABLE 9.  EVALUATION OF SPECIFIC SOUTHWEST COPPER LEACH DUMP SITES
en
Site
No.
31
33
Typicality of waste management practice
Waste characteristics
EP
toxlclty
+++
4-M-
Corros1v1ty
+++
++
Radio-
activity
0
0
Cyanide
0
0
Environmental facto
Precipitation/
evapotrans-
plratlon ratio
-
Proximity to
surface water
0
•f
rs
Proximity to
groundwater
0
0
Monitoring considerations
Existing
monitoring
program
+
++
External
Influences
0

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(1)   The  waste management  practice  is  typical of other  cop-
     per  leach dump  operations.

     0     Copper  bearing material is piled  above grade  near
          the open pit.  Piles  are  initially leached with
          acid to start the  leaching process and then water
          is used to complete leaching.

     °     Leach liquor is  collected downgradient from the
          piles and  sent to  the precipitation plant for cop-
          per recovery.  The entire volume  of mine waste ma-
          terial  generated at Chino is subjected to leaching,

(2)   Presurvey waste characteristics are  typical of other
     leach dumps  material  sampled during  the Presurvey.

     0     Concentrations of  certain metals  in the pregnant
          leach liquor material were greater than 100 times
          the PDWS for these metals (three  pluses in Table
          9).  Samples of  the leached  rock  material also re-
          vealed  relatively  elevated levels for certain
          metals.

     0     Pregnant leach liquor had a  pH  between 2 and  3
          (two pluses in Table  9).

(3)   Environmental factors are  typical of other leach dumps
     in the Southwest copper mining district.

     0     Gently  rolling topography (elevation in area  of
          operation  ranges from 5,000  to  6,000 feet).   Semi-
          arid climate and sparse vegetation.

     0     The substrata underlying  the area consists of wea-
          thered  sandstone which is cemented, altered lime-
          stone,  shale, and  granite.

     0     Lamp Bright Creek, an ephemeral stream, is in
          close proximity  (less than one  mile) to the mine
          and the leach dump area  (one plus in Table 9).
          The intermit flow  of  this creek occurs most fre-
          quently between  July  and  October  which is  typical
          of most ephemeral  streams associated with  the
          Southwest  copper mining industry.

     0     Groundwater in the area varies  but generally  oc-
          curs at a  depth  of 150 to 200 feet  (a rating  of
          zero in Table 9).
                           54

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     (4)  Monitoring Considerations

          0    Seepage associated with the leach dump operation
               is collected by ten barrier or interceptor wells
               that are located downgradient from the leach dump
               area.  These barrier wells also serve as monitor-
               ing wells (two pluses in Table 9).
                                                    *
          °    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Florida and Idaho Phosphate Mine Waste Rock Dump Sites

     Approximately 395 million tons of phosphate waste rock is

generated annually in Florida and Idaho, accounting for about 18

percent of the total solid waste generated by non-coal mining

activities in this country.  The ore deposits and consequently

the waste rock management practices employed in Florida and Idaho

are distinctly different.  In Florida, two distinct management

practices are typically used.  In both methods, the mine waste

rock is initially backfilled into adjacent sites previously ex-

cavated.  Then the mine waste is either graded and revegetated

for ultimate uses such as grazing land, or it is employed to con-

struct the dikes of clay tailings ponds.

     In the mountainous terrain of the southeastern Idaho phos-

phate district, the shale material is initially segregated from

the cherty-limestone material.  These materials are then dumped

over mountain sides, in mountain valleys, or backfilled into pre-

viously excavated pits with shales placed over the cherty-lime-

stone material.  Reclamation of the mining areas is typically af-

fected by grading and revegetating the waste rock dumps.
                                55

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     Based on application of Step III Criteria to the four Flor-

ida and four Idaho waste rock dump Presurvey sites (Table 10),

three were selected for comprehensive monitoring:

     0    Fort Green Mine (No. 2)
     0    Lonesome Mine (No. 3)
     0    Wooley Valley Mine  (No. 8)


Fort Green Mine—

     The Fort Green Mine is owned by the Agrico Chemical Company

and is located about five miles south of Mulberry, Florida in the

central Florida phosphate mining district.  This site was selected

because:

      (1)  The waste management practice is typical of other Flor-
          ida phosphate waste rock dumps  (overburden).

          0    Waste rock (overburden) is placed in piles adjacent
               to cuts being mined and and later used to cap com-
               pleted clay tailings ponds, with subsequent reveg-
               etation.

      (2)  Presurvey waste characteristics are typical of other
          Florida waste rock dumps sampled during the Presurvey.

          0    Samples revealed radium 226 concentration greater
               than 4 but less than 10 pCi/g  (one plus in Table 10)

      (3)  Environmental factors are typical of other Florida
          phosphate waste rock dumps.

          0    Flat to gently rolling terrain  (elevation of 120-
               135 feet) in a subtropical climate.

          0    The substrata underlying the waste rock dumps con-
               sists of unconsolidated layers of clays and fine
               sand, underlain by limestone and dolomite forma-
               tions, regional in extent.

          0    The mine waste rock dumps are located in the
               drainage basin of Payne Creek  (total watershed is
               102 acres), Payne Creek is about 2,300 feet from
               the mine waste rock dump areas.   (A rating of one
               plus in Table 10).


                                56

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TABLE 10.  EVALUATION OF SPECIFIC FLORIDA AND IDAHO PHOSPHATE  WASTE  ROCK DUMP SITES
Site
No.
Florida
1
2
3
4
Idaho
5
6
7
8
Typicality of waste management practice
Waste characteristics
EP
toxlclty
+
0
0
0
4
4
4
+
Corrosfvlty
0
0
0
0
0
4
0
0
Radio-
activity
4
4
44
44
4
44
4
++
Cyanide
0
0
0
0
0
0
0
0
Environmental factors
Precipitation/
evapotrans-
plration ratio
4
•f
4
4
0
0
0
0
Proximity to
surface water
4
+
++
+
0
-f
+
4
Proximity to
groundwater
44
44
44
44
0
4
0
44
Monitoring considerations
Existing
monitoring
program
4
4
4
4
4
4
4
4
External
Influences

0
0
0

0
0
0

-------
          0     Surficial groundwater in the waste rock dumps area
               occurs at a depth of 20-50 feet (a rating of 2
               pluses in Table 10).  The Floridian aquifer occurs
               at a depth of 100-150 feet.

     (4)   Monitoring Considerations

          0     Tailings pond discharge is monitored to meet NPDES
               permit requirements  (one plus in Table 10).

          0     There are no apparent external influences which
               would significantly  interfere with a monitoring
               program.


 Lonesome Mine—

     The Lonesome Mine is owned by  the Brewster Phosphates; a

subsidiary of American Cyanamid, and is located about five miles

south of Bradley, Florida.  This site was selected because:

     (1)   The waste management practice is typical of other Flor-
          ida waste rock dumps.

          0     Waste rock (overburden) is placed in piles adjacent
               to cuts being mined  and later used to cap completed
               clay tailings ponds, with subsequent revegetation.

     (2)   Presurvey waste characteristics are typical of other
          Florida waste rock dumps  sampled during the Presurvey.

          0     Samples revealed radium 226 concentrations greater
               than 10 but less than 100 pCi/g.

     (3)   Environmental factors are typical of other Florida
          phosphate waste rock dumps.

          0     Flat to gently rolling terrain  (elevation of 120-
               135 feet) in a subtropical climate.

          0     The substrata underlying the waste rock dumps con-
               sists of layers of clays and fine sand, underlain
               by limestone and dolormite formations, regional in
               extent.

          0     The mine waste rock  dumps are located in the
               drainage basin of the south fork of the Alafia
               River  (two pluses in Table 10).
                               58

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          0    Surficial groundwater in the mine waste rock dump
               area occurs at a depth of 20-50 feet (2 pluses in
               Table 10).   The Floridian aquifer occurs at a
               depth of 100-150 feet.

     (4)  Monitoring Considerations

          0    Tailings pond discharge is monitored as part of
               NPDES requirements.


Wooley Valley Mine—

     The Wooley Valley Mine is owned by the Stauffer Chemical

Company and is located 15 miles northeast of Soda Springs, Idaho.

It was chosen because the waste characteristics and environmental

factors associated with its waste rock dumps are typical of the

other Idaho phosphate sites.

     (1)  The waste management practice is typical of other
          Southeastern Idaho phosphate mine waste rock dumps:

          0    Waste rock is segregated into cherts, limestones,
               and altered shales.  The cherts and limestones are
               deposited first and then the altered shales are
               placed over these materials, to provide a good
               growing medium for revegetation practices.

          0    Surface runoff from the disposal area is controlled
               by sediment retention basins located down gradient
               of the dumpsite.

     (2)  Presurvey waste characteristics are typical of other
          Idaho phosphate mine waste rock dumps sampled during
          the presurvey.

          0    EP acid extracts of mine waste rock samples re-
               vealed concentrations of certain metals which were
               greater than, the PDWS, but less than 10 times the
               PDWS  (one plus in Table 10).

          0    Activity levels for radium 226 were elevated  (two
               pluses in Table 10).

     (3)  Environmental factors are typical of the Eastern Idaho
          phosphate mining industry.
                                59

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          0    Mountainous topography (elevation between 6,300
               and 7,000 feet).  Average annual precipitation is
               19 inches and the potential evapotranspiration is
               approximately 23 inches.

          0    The substrata in the area of the mine waste dump
               consist of approximately 20-30 feet of unconsoli-
               dated sediment underlain by nearly vertical dip-
               ping beds of cherts, shales, and limestones.

          0    Drainage is to Angus Creek which eventually flows
               into Blackfoot River.  Angus Creek is about 1/4
               mile from the mine waste dumps.  (one plus in
               Table 10).

          0    Groundwater systems are alkaline with high buffer-
               ing capacities which is common to the area.
               Groundwater either flows vertically through the
               carbonate beds underlying the waste rock dump or
               horizontally through the unconsolidated surface
               sediments toward Angus Creek  (shallow -20-30 feet
               deep - two pluses in Table 10).

     (4)  Monitoring Considerations

          0    Surface water in the Southeastern Idaho phosphate
               mining district is routinely monitored by the U.S.
               Forest Service.  U.S. Geological Survey also is
               investigating radioactivity in surface waters and
               springs in the area  (one plus in Table 10).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Florida Phosphate Tailings Pond Sites

     The Florida phosphate mining and beneficiating industry gen-

erates approximately 70 million tons per year of clay tailings,

accounting for about 5 percent of the total non-coal mining in-

dustry solid wastes generated annually.   Phosphate clay tailings

are typically disposed of in unlined ponds or mined out cuts from

which water is completely recycled.  Florida clay tailings ponds

are typically constructed from mined out pits with dikes built up


                               60

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around them of mine waste rock or waste gypsum from adjacent fer-

tilizer plants.

     Based on application of the Step III Criteria to the four

Florida tailings pond Presurvey sites (Table 11),  two sites have

been selected for the comprehensive monitoring program:

     0    Fort Green Mine (No. 2)
     0    Suwannee River Mine (No. 4)


Fort Green Mine—

     The Fort Green Mine is owned by the Agrico Chemical Company

and is located about five miles south of Mulberry, Florida in the

central Florida phosphate mining district.  This site was selected

because:

     (1)   The waste management practice is typical of other Flor-
          ida phosphate tailings ponds.

          0    The clay tailings containing 40 percent solids are
               pumped to mined cuts averaging 550 acres.  Over-
               flow from gravity settling of clay solids is re-
               cycled to beneficiating process.  Overflow is
               discharged to surface waters.

          0    Reclamation involves placement of an overburden
               cap over the tailings, followed by revegetation.
               Reclaimed land is used for pasture, timber pro-
               duction, wildlife habitat, and recreation.

          0    Canals are employed to recycle water throughout
               operation.

     (2)   Presurvey waste characteristics are typical of other
          Florida phosphate tailings pond wastes sampled during
          the Presurvey.

          0    Some tailings liquid samples and/or extracts of
               tailings solids samples revealed concentrations of
               certain metals which were more than any specified
               in PDWS, but less than 10 times the PDWS  (one plus
               in Table 11).
                                61

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TABLE 11.  EVALUATION OF SPECIFIC FLORIDA PHOSPHATE TAILINGS POND SITES
Site
No.
1
2
3
4
Typicality of waste management practice
Waste characteristics
EP
toxicity
+
•f
++
++
Corrosivity
0
0
0
0
Radio-
activity
0
<•++
0
+
Cyanide
0
0
0
0
Environmental factors
Prrcipitation/
evanotrans-
piration ratio
+
+
+
t
Proximity to
surface water
+
+
+
+
Proximity to
groundwater
+ +
+-f
++
f 4
Monitoring considerations
Existing
monitoring
program
+
+
+
* *
External
influences
-
0
0
0

-------
          0    Elevated radium 226 levels (some liquid or solid
               tailings samples had radium 226 concentrations
               greater than 50 pCi/liter or 50 pCi/g respectively)
               (three pluses in Table 11).

     (3)   Environmental factors are typical of other Florida
          phosphate tailings ponds.

          0    Flat to gently rolling topography (elevation of
               120-135 feet) in a subtropical climate.

          0    The substrata underlying the tailings ponds con-
               sists of unconsolidated layers of clays and fine
               sand, underlain by massive limestone and dolomite
               formations,  regional in extent.

          0    The tailings ponds are located in the drainage
               basin of Payne Creek (total watershed is 102
               acres), Payne Creek is about 2,300 feet from the
               tailings pond (one plus in Table 11).

          0    Surficial groundwater in the tailings pond area
               occurs at a depth of 20-50 feet, depending primar-
               ily on rainfall (two pluses in Table 11).   The
               Floridian aquifer occurs at a depth of 100-150
               feet.

     (4)   Monitoring Considerations

          0    Tailings pond discharge is monitored to meet NPDES
               permit requirements (one plus in Table 11).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.
Suwannee River Mine--

     The Suwannee River Mine is owned by Occidental Chemicals,

Inc., and is located 10 miles north of White Springs, Florida.

This site was selected because:

     (1)  The waste management practice is typical of other Flor-
          ida phosphate tailings ponds.

          0    The clay tailings containing 40 percent solids are
               pumped to mined cuts averaging 550 acres.  Over-
               flow from gravity settling of clay solids is re-
               cycled to beneficiating process.  Overflow is
               discharged to surface waters.

                                63

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     0     Reclamation  involves  placement of an overburden
          cap  over  the tailings,  followed by revegetation.
          Reclaimed land  is  used  for pasture, timber pro-
          duction,  wildlife  habitat, and recreation.

     0     Canals  are employed to  recycle water throughout
          operation.

(2)   Presurvey waste characteristics are basically  typical
     of  other  Florida  phosphate tailings ponds sampled  dur-
     ing the Presurvey.

     0     Some tailings liquid  samples  and/or extracts  of
          tailings  solid  samples  revealed concentrations of
          certain metals  which  were more than 10  times  but
          less than 100 times the PDWS  (two pluses  in Table
          11).

     0     Elevated  radium 226 levels of some liquid or  solid
          samples had  radium 226  concentrations greater than
          4 but less than 10 pCi/liter  or 10 pCi/g, respec-
          tively  (one  plus in Table 11).

(3)   Environmental  factors are  basically typical  of other
     Florida phosphate tailings pond operations;  however,
     subtle differences exist at  this north-central Florida
     operation.   Selection of this site therefore will  re-
     veal the  impact from a  tailings pond in a slightly dif-
     ferent setting than  those  located  in Central Florida.

     0     Flat to gently  rolling  topography in a  subtropical
          climate.

     0     The  substrata underlying the  tailings pond con-
          sists of  layers of unconsolidated clays and fine
          sand, underlain by massive limestone and  dolomite
          formations,  regional  in extent.

     0     The  tailings pond  is  located  in the drainage  basin
          of the  Suwannee River.   Tributaries of  the Suwannee
          River (Swift, Hunter, and Roaring Creeks) are
          within  a  mile of the  tailings ponds.   (one plus  in
          Table 11).

     0     Surficial groundwater in the  tailings pond area
          varies  considerably with rainfall but always
          occurs  within a depth of 50 feet  (two pluses  in
          Table 11).   Floridian aquifer occurs at a depth  of
          about 50-60  feet.
                          64

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     (4)  Monitoring Considerations

          0    Existing monitoring wells and surface water moni-
               toring.  U.S.G.S., as subcontractor to EPA Region
               IV, will complete surface and groundwater monitor-
               ing programs around the tailings area by December
               1981 (two pluses in Table 11).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Wyoming Uranium Mine Waste Rock Dump Sites

     Over 240 million tons of uranium mine waste rock are gener-

ated annually in Wyoming, amounting to 11 percent of the total

waste generated by non-coal mining industries.  Mine waste rock

from the open pit mines is typically hauled by truck and either

backfilled into the mines or dumped in areas adjacent to the open

pits.  These mine waste dumps and backfilled areas are graded for

subsequent reclamation.

     Based on the application of the Step III Criteria to the

four Wyoming waste rock dump Presurvey sites  (Table 12), two

sites were selected for comprehensive monitoring:
     0    Bear Creek Mine (No. 16)
     0    Lucky Me Mine  (No. 19)
Bear Creek Mine—

     The Bear Creek Mine is owned by Bear Creek Uranium Company,

which is jointly owned by Rocky Mountain Energy Company and Mono

Power Company, which are wholly owned subsidiaries of Union Pa-

cific Corporation and Southern California Edison Company, respec-

tively.  Bear Creek is located about 35 miles northeast of Doug-

las, Wyoming.  This site was selected because:

                               65

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                      TABLE  12.   EVALUATION  OF  SPECIFIC  WYOMING URANIUM WASTE ROCK DUMP SITES
CTl
CT>




Site
No.
16
17
18
19
Typicality of waste management practice

Waste characteristics

EP
toxlclty
+
+
+
•f


Corroslvlty
0
0
++
+

Radio-
activity
+
0
0
+


Cyanide
0
0
0
0
Environmental factors
Precipitation/
evapotrans-
plratlon ratio
0
0
0
0

Proximity to
surface water
+
+
++
+

Proximity to
groundwater
0
0
0
0



Existing
monitoring
program
+
+
4-
+

External
Influences
0
0
0
0

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(1)   The waste management practice  is  typical of other Wyo-
     ming waste  rock  dumps.

     0    Waste  rock  dumps are  constructed  in areas near the
         open pit  to minimize  disposal costs.  Construction
         of  surface  dumps includes  topsoil removal and
         storage,  placement of wastes, and reclamation.

     0    Some procedures employed  at  Bear  Creek concerning
         reclamation activities  and general management of
         the dump  sites are somewhat  exemplary.   These pro-
         cedures include grading some areas of piles to a
         5:1 slope,  use of diversion  ditches and  retention
         ponds  to  control runoff,  and some use of vegetable
         fiber  matting to hold soil during revegetation.
         All sites employ these  types of activities  (grad-
         ing, runoff diversion,  revegetation) but not to
         the extent  that Bear  Creek employs them.

(2)   Presurvey waste  characteristics are typical of other
     mine waste  dumps sampled during the Presurvey.

     0    EP  acid extracts of some  waste rock samples re-
         vealed concentrations of  certain  metals  which were
         greater than specified  for these  metals  in the
         PDWS,  but less than ten times more  (one  plus in
         Table  12).

     0    The radium  226 values recorded for some  samples
         were greater than 4 pCi/g, but less than 10 pCi/g
          (one plus in Table 12).

(3)   Environmental  factors are  typical of other Wyoming
     uranium  operations.

     0    Topography  is rolling,  elevation  about 5,000 feet,
         and vegetation is sparse.  Climate is semi-arid
         with less than 12 inches  average  annual  precipi-
         tation.

     0    The substrata underlying  the area consists of
         claystone,  siltstone, and sandstone.

     0    The site  is located on  the divide of the Cheyenne
         River. Bear Creek is within approximately 1,000
         feet of the waste dumpsite (one plus in  Table  12).

     0    Top of the  water table  is between 200 and  250  feet
         deep  (a rating of zero  in Table 12).
                          67

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     (4)   Monitoring Considerations

          0    A fairly extensive monitoring program is maintained
               at Bear Creek.   The program includes a meteorology
               station, some overburden characterization,  air
               monitoring (including radon daughters sampling
               station), and surface and groundwater monitoring.
               Most monitoring is associated with the tailings
               pond.   (one plus in Table 12.)

          0    There are no apparent external incluences which
               would significantly interfere with a monitoring
               program.


Lucky Me Mine—

     The Lucky Me Mine is owned by the Pathfinder Mines Corpora-

tion, which is a wholly owned subsidiary of Utah International,

Inc., which is a wholly owned affiliate of General Electric Com-

pany.  The operation is located near Gas Hills, Wyoming which is

about 80 miles west of Casper.  This site was selected because:

     (1)   The waste management practice is typical of other Wyo-
          ming uranium waste rock dumps.

          0    Waste rock dumps are constructed in areas near the
               open pit.  Construction of the dumps includes top-
               soil removal, placement of wastes, and subsequent
               waste stabilization by reclamation.

          0    Reclamation involves slope reduction  (piles graded
               to either a 3:1 or 4:1 slope), placement of a
               runoff diversion system, and revegetation.

     (2)   Presurvey waste characteristics are typical of other
          waste rock material sampled during the Presurvey.

          0    EP acid extracts of some waste rock samples re-
               vealed concentrations of certain metals which were
               greater than specified for these metals in the
               PDWS, but less than 10 times more  (one plus in
               Table 12).

          0    The radium 226 values recorded for some waste rock
               samples were greater than 4 pCi/g, but less than
               10 pCi/g (one plus in Table 12).
                               68

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     (3)   Environmental factors are typical of other Wyoming
          uranium operations.

          0    The operation is located in the southeastern por-
               tion of the Wind River Basin.   Elevation in the
               vicinity of the mine ranges from 6,000 to 6,700
               feet.

          0    The climate is  semi-arid,  with mean annual precip-
               itation of less than 10 inches.  Most of the pre-
               cipitation occurs during April, May,  and June in
               the form of wet snow and rain.

          0    Topsoil in the  area ranges from 6 and 30 inches.
               The substrata underlying the site consists mostly
               of sandstone and shale.  The major bedrock units
               in the area are the Wind River and Cody shale for-
               mations.

          0    Numerous creeks and draws occur throughout the
               area of the Lucky Me operation.  Fraser Draw is
               the major drainage in the vicinity of the opera-
               tion.   Fraser Draw is a tributary of Muskrat Creek
               which is a tributary of the Wind River.  All the
               drainage in the area are dry except for periodic
               runoff from snowmelt and rain storms.  Fraser Draw
               is within one mile of the dumps (one plus in Table
               12).

          0    The water table in the area is estimated to be
               about 200 feet deep (a rating of zero in Table 12).

     (4)   Monitoring Considerations

          0    A fairly extensive monitoring program is maintained
               at Lucky Me.  Most of the monitoring is associated
               with the tailings pond but there are also some
               general area or site monitoring stations located
               around the vicinity of the operation  (one plus in
               Table 12).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


New Mexico and Wyoming Uranium Mine Water Pond Sites

     Although the precise quantity of waste associated with the

water pumped from uranium surface and underground mines in Wyoming


                                69

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and New Mexico is not known,  it is certainly relatively insignif-

icant compared to the volumes of other mine wastes generated.

Nearly all of the mine water produced is treated before discharge,

typically in a series (usually three) of 2 to 10-acre ponds by

alum flocculation of suspended solids and precipitation of radium

226 with barium chloride.

     Based on the application of Step III Criteria to the four

New Mexico and four Wyoming mine water pond Presurvey sites

(Table 13), three sites were selected for comprehensive monitoring:

     0    Churchrock No. 1 Mine (No. 13)
     0    Section 35 Mine  (No. 14)
     0    Shirley Basin Mine  (No.  18)


Churchrock No. 1 Mine—

     The Churchrock No. 1 Mine is owned by the Kerr-McGee Corpo-

ration and is located 25 miles northeast of Gallup, New Mexico.

This site was selected because:

     (1)  The waste management practice is typical of other New
          Mexico uranium mine water ponds:

          0    Liners are not used beneath the mine water ponds.

          0    Pond system has a discharge.

          0    Several mine water ponds are used in series for
               treatment.  Flocculants and barium chloride are
               reagents employed for treatment.

     (2)  Presurvey waste characteristics are typical of other
          New Mexico uranium mine water ponds sampled during the
          Presurvey.

          0    Liquid samples and/or EP acid extracts of settled
               solids from the mine water pond revealed that cer-
               tain metals were in concentrations between 10 and
               100 times the PDWS (two pluses in Table 13).
                               70

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TABLE 13.  EVALUATION OF SPECIFIC NEW MEXICO AND WYOMING URANIUM MINE
                          WATER POND SITES
Site
No.
New
Jtexlco
12
13
14
15
Wyoming
16
17
18
19
Typicality of waste management practice
Waste characteristics
EP
toxldty

44
+4
44
4

4
44
44
44
Corroslvlty

0
0
0
0

0
0
0
0
Radio-
activity

444
444
444
444

44
4
4
4
Cyanide

0
0
0
0

0
0
0
0
Environmental factors
Precipitation/
evapotrans-
plration ratio

- .
-
-
-

0
0
0
0
Proximity to
surface water

0
44
4
+

0
4
4
4
Proximity to
groundwater

4
4
44
44

0
4
0
0
Monitoring considerations
Existing
monitoring
program

4
4
4
4

4
4
4
4
External
Influences

-
-
-
-

0
-
0
-

-------
          0    Radium 226 concentration in some samples of mine
               water ponds were greater than 50 pCi/g or 50 pCi/1.
               (three pluses in Table 13).

     (3)  Environmental factors are typical of other New Mexico
          uranium mine sites.

          0    Mesa and valley topography with elevations approx-
               imately 6,700-7,000 feet in a setting with semi-
               arid climate.

          0    The substrata underlying the mine water pond con-
               sists of siliceous alluvial deposits with regional
               interbedded sandstones.  Shale beds exist but are
               not considered an aquaclude, due to fracturing.

          0    The Rio Puerco drains the mine site area and is
               less than 100 yards from the ponds  (two pluses in
               Table 13).

          0    Groundwater in the mine water pond area occurs at
               a depth of 80-100 feet (one plus in Table 13).

     (4)  Monitoring Considerations

          0    NRC requires the groundwater in the vicinity of
               the tailings pond be monitored (one plus in Table
               13).

          0    Run-off from mine waste rock and low-grade ore is
               routed to the mine water pond for treatment.  This
               combining of waste streams is not believed to sig-
               nificantly change the character of the mine water
               ponds, because of the arid climate  (i.e., minor
               volumes of run-off water as compared with the con-
               stant volume of mine water), (one minus in Table
               13).
Section 35 Mine--

     The Section 35 Mine is owned by the Kerr-McGee Corporation

and is located in Ambrosia Lake, 20 miles north of Grants, New

Mexico.  This site was selected because:

     (1)  The waste management practice is typical of other New
          Mexico uranium mine water ponds:

          0    Liners are not used beneath the mine water ponds.
                               72

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     0     Pond  system has  a  discharge.

     0     Several mine water ponds  are used  in  series  for
          treatment.   Flocculants and barium chloride  are
          employed  for treatment.

(2)   Presurvey  waste  characteristics are  typical of other
     New  Mexico uranium mine water  ponds  sampled during  the
     Presurvey.

     0     Liquid samples and/or  EP  acid extracts of settled
          solids from the  mine water pond revealed that  cer-
          tain  metals were in concentrations between 10  and
          100 times the PDWS (2  pluses in Table 13).

     0     Radium 226  concentrations in some  samples of mine
          water ponds were greater  than 50 pCi/g or pCi/1.
          (three pluses in Table 13).

(3)   Environmental  factors are typical of other New Mexico
     uranium mine sites.

     0     Mesa  and  valley  topography  (elevation approximate-
          ly 6,000  feet) in  setting with  semi-arid climate.

     0     The substrata underlying  the mine  water pond con-
          sists of  siliceous alluvial deposits  with inter-
          bedded dipping sandstones as bedrock.  Shale beds
          are present and  act as aquacludes. This strata  is
          regional  in extent.

     0     The San Mateo Creek drains the  mine site area  and
          is approximately 1 mile  (one plus  in  Table 13).

     0     Groundwater in the mine water pond area occurs at
          a depth of  30-50 feet  (two pluses  in  Table 13).

(4)   Monitoring Considerations

     0     NRC requires the groundwater in the vicinity of
          the tailings pond  be monitored  (one plus  in  Table
          13).

     0     There are no apparent  external  influences which
          would significantly interfere with a  monitoring
          program.
                          73

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Shirley Basin Mine—

     The Shirley Basin Mine is owned by the Pathfinder Mines Cor-

poration which is a wholly owned subsidiary of Utah International,

Inc., which is a wholly owned affiliate of General Electric.

This site was selected because:

     (1)  The waste management practice is typical of other uran-
          ium mine water ponds.

          0    Relatively small, unlined ponds with intermittent
               discharge.

          0    Flocculants and barium chloride are used to pre-
               cipitate radium.

     (2)  Presurvey waste characteristics are typical of other
          uranium mine water ponds sampled during the Presurvey.

          0    Liquid samples and/or EP acid extracts of settled
               solids from the mine water pond revealed that cer-
               tain metals were in concentrations between 10 and
               100 times the PDWS (two pluses in Table 13).

          °    Some liquid and solid samples had radium 226 val-
               ues greater than 4.0 but less than 10 pCi/liter or
               10 pCi/g, respectively.  These values are lower
               than those recorded for samples from New Mexico
               uranium mine water ponds, but they are typical of
               the values recorded for samples from other Wyoming
               mine water ponds (one plus in Table 13).

     (3)  Environmental factors are typical of other uranium
          operations..

          0    Topography is gently rolling, elevation about
               7,000 to 7,100 feet, and vegetation is sparse.
               Climate is generally semi-arid with an average
               annual precipitation of about 11 inches per year.

          0    The Shirley Basin is an extension of the Wind
               River Basin.  The predominant substrata underlying
               the operation is sandstone and some shale.

          0    Local surface drainage is low.  The area is drained
               by Spring Creek and the Little Medicine Bow River.
               Little Medicine Bow is less than 1 mile from mine
               water pond area  (one plus in Table 13).


                                74

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          0    Groundwater in the area occurs at a depth of 150
               to 200 feet (a rating of zero in Table 13).

     (4)  Monitoring Considerations

          0    There is very little monitoring directly associated
               with the mine water pond; however, general Multime-
               dia (air, groundwater, and surface water) monitor-
               ing is conducted on site and at several areas in
               close proximity to the site (one plus in Table 13).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Nevada and South Dakota Gold/Silver Tailings Pond Sites

     Gold/silver mines in South Dakota and Nevada generate over 5

million tons of tailings annually, accounting for less than one

percent of total solid wastes generated by non-coal mining indus-

tries.   The gold/silver mining industry is characterized by a few

large mines producing a large percentage of total U.S. production

through the cyanidation leaching process.

     Tailings from the cyanidation processes are typically sluiced

to unlined ponds.  State-of-the-art technology includes seepage

collection/recycle systems at the base of the tailings dams with

standby chlorination systems for cyanide destruction in the event

of failure or overload of the seepage recycle system.

     Based on application of the Step III criteria to the three

Nevada and one South Dakota tailings pond Presurvey sites  (Table

14), two sites were selected for comprehensive monitoring:

     0    Carlin Mine  (No. 52)
     0    Lead Mine  (No. 55)
                                75

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                    TABLE 14.  EVALUATION OF SPECIFIC NEVADA AND SOUTH DAKOTA GOLD/SILVER
                                             TAILINGS POND SITES
CT>
Site
No.
Nevada
52
53
54
South
Dakota
55
Typicality of waste management practice
Waste characteristics
EP
toxicity
+++
+++
4
+
Corrosivity
+
4
0
4
Radio-
activity
0
0
0
0
Cyanide
444
444
444
444
Environmental factors
Precipitation/
evapotrans-
pi rat ion ratio
0
Proximity to
surface water
4
0
0
+ 4
Proximity to
groundwater
0
0
+
+ *
Monitoring considerations
Existing
moni toring
program
4
0
0
++
External
influences
0

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Carlin Mine--

     The Carlin Mine is owned by Newmont Mining Corporation and

is located 20 miles north of Carlin,  Nevada.   This site was se-

lected because:

     (1)  The waste management practice is typical of other gold/
          silver tailings ponds for cyanidation wastes:

          0    Unlined pond with recycle of decant water to bene-
               ficiation process (no discharge).

          0    Tailings pond dam consists of an earthen dam.

          0    Seepage collection systems with pump-back capabil-
               ities are located below the pond.

     (2)  Presurvey waste capabilities are typical of other gold/
          silver tailings ponds for cyanidation leach process.

          0    Some liquid and/or EP acid extracts of settled
               solids revealed concentrations of certain metals
               which were greater than 100 times the PDWS (three
               pluses in Table 14).

          0    Liquid sample revealed slightly elevated levels  of
               corrosivity having a pH value between 10 and 11
               (one plus in Table 14).

          0    Significant quantities of cyanide is employed in
               the cyanidation leaching operations during bene-
               ficiation (three pluses in Table 14).

     (3)  Environmental factors are typical of other Nevada gold/
          silver tailings ponds for cyanidation leaching wastes:

          0    High relief to mountainous (elevation 6,000 to
               6,700 feet)  in semi-arid settings.

          0    The substrata underlying the tailings pond is sed-
               imentary in origin.   The majority of surface de-
               posits are siliceous interbedded sandstones,
               cherts, and shales.

          0    The mine site is located in the Sheep Creek drain-
               age basin, located approximately 1 mile to the
               north  (a rating of one plus in Table 14).
                               77

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          0    Groundwater in the area of the tailings pond
               occurs at a depth greater than 150 feet (a rating
               of zero in Table 14).

     (4)   Monitoring Considerations

          0    Water supply wells and some monitoring wells are
               located downgradient of the tailings pond (one
               plus in Table 14).

          0    The beneficiation mill and certain mine waste
               dumps are approximately 200 to 300 yards up-grad-
               ient of the tailings pond, but should not interfere
               with the location and interpretation of background
               data.
Lead Mine--

     The Lead Operation is owned and operated by the Homestake

Mining Company and is located in Lead,  South Dakota.  Although

this mine is the only significant gold mine in South Dakota, it

was chosen because:

      (1)  It is the largest gold mine in the world, representing
          21 percent of total U.S. gold/silver production from
          principal mines.

      (2)  The waste management practice is typical of tailings
          disposal at other gold/silver mines using cyanidation
          recovery process.

          0    Unlined pond with recycle of decant water to bene-
               ficiation process  (no discharge).

          0    Tailings pond dam consists of an earthen dam.

          0    Seepage collection and pump back facilities are
               located below the pond.

      (3)  Presurvey waste characteristics are typical of other
          gold/silver cyanidation tailings ponds sampled during
          the Presurvey:

          0    Some liquids and/or EP acid extracts of settled
               solids revealed concentrations of certain metals
               which were greater than specified for these metals
               in the PDWS but less than 10 times the PDWS  (one
               plus in Table 14).


                                78

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          0    Significant quantities of cyanide is employed in
               the cyanidation leaching operations during bene-
               ficiation (three pluses in Table 14).

          0    Some solid samples revealed potential acidity
               values in the 500 to 5,000 yg 003 per gram of sam-
               ple range (one plus in Table 14).

     (4)  It represents a different environmental setting than
          that of Nevada operations:

          0    Hilly topography, elevation about 5,500 feet, with
               a precipitation to evapotranspiration ratio of
               0.75 to 1.0.

          0    It is located in the Grizzly Creek drainage basin
               which drains to Strawberry Creek, surface waters
               are within a mile of the practice (one plus in
               Table 14).

          0    Groundwater in the area below the tailings pond is
               expected to be within 50 feet of the surface (two
               pluses in Table 14).

     (5)  Monitoring Considerations

          0    The tailings pond has many groundwater wells and
               surface water sampling stations.  Ground and sur-
               face waters are routinely analyzed from these sam-
               pling points (two pluses in Table 14).

          0    The age of the tailings pond is only 3 years, but
               because of the relatively shallow groundwater
               table the age of this waste management practice
               should be sufficient to allow detection of leach-
               ate if it is present (one minus in Table 14).


Missouri and Tennessee Lead/Zinc Tailings Pond Sites

     Approximately 13 million tons of tailings are generated an-

nually at underground lead and zinc mines in Missouri and Tennes-

see, accounting for less than one percent of the total non-coal

mining industry solid wastes.  Typically, tailings are disposed

of in on-site ponds, with dams constructed of earthen materials,

mine waste rock, and/or coarse tailings.


                                79

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     Based on the application of Step III Criteria to the one

Tennessee and two Missouri lead/zinc Presurvey sites (Table 15),

two sites were selected for comprehensive monitoring:
     0    Young Mine (No.  40)
     0    Viburnum Mine (No. 46)
Young Mine—

     The Young Mine is owned by ASARCO Incorporated and is lo-

cated about 30 miles east of Knoxville, Tennessee,  near Mascot.

The Young Mine and beneficiating plant are representative of

other operations in the eastern Tennessee zinc mining district.

The specific reasons for selecting the Young tailings pond for

comprehensive monitoring are as follows:

     (1)  The beneficiating process and the tailings waste man-
          agement practice are typical of other eastern Tennessee
          operations:

          0    Beneficiating process consists of conventional
               crushing, heavy media separation, grinding, flota-
               tion, and limestone (agricultural lime) byproduct
               recovery.  The tails,  which consists of the slimes
               that remain after limestone recovery, are dis-
               charged to a 50 acre tailings pond.

          0    Tailings pond is unlined and tailings water is re-
               cycled.  Periodic discharging does occur during
               periods of heavy rainfall.  Discharge is through a
               small decant pond.

     (2)  Only one eastern Tennessee mining operation was sampled
          during the Presurvey and therefore a comparison of the
          characteristics of tailings from different sites in
          this district cannot be made.  Information obtained
          through telephone contacts indicate that characteris-
          tics of tailings from different operations in this dis-
          trict are not expected to vary significantly.  Also,
          the waste characteristics data recorded for the Young
          Mine are consistent with the results obtained for other
          (e.g., Missouri and New York) lead/zinc mines sampled
          during the Presurvey.
                               80

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            TABLE 15.  EVALUATION OF SPECIFIC MISSOURI AND TENNESSEE LEAD/ZINC TAILINGS POND SITES
Site
No.
Tennessee
40
Missouri
45
46
Typicality of waste management practice
Waste characteristics
EP
toxlclty
4+
+
44
Corroslvlty
0
0
0
Radio-
activity
0
0
0
Cyanide
0
t
4
Environmental factors
Precipitation/
evapotrans-
plration ratio
4+
4
4
Proximity to
surface water
4
4
+
Proximity to
groundwater
4
4+
•t-f
Monitoring considerations
Existing
monitoring
program
4
4
4
External
Influences
0
00

-------
          0    Some liquid and/or EP acid extracts of settled
               solids revealed concentrations of certain metals
               which were greater than 10 but less than 100 times
               the PDWS (two pluses in Table 15).

     (3)   Environmental factors are typical of other Eastern Ten-
          nessee zinc mines.

          0    Gently rolling topography (elevation 800 to 1,200
               feet) with seasonal climate (precipitation exceeds
               evaporation)  which is typical of the setting for
               most lead/zinc mining operations in the eastern
               United States and Missouri.

          0    The substrata of the Eastern Tennessee zinc mining
               district is karstic (an irregular limestone region
               with .numerous sinks, underground streams, and cav-
               erns).  The depth to groundwater varies consider-
               ably  (50 to over 150 feet)(one plus in Table 15).

          0    Several small streams are located in close prox-
               imity to the tailings pond.   Beaver Creek, the
               largest stream in the immediate area, is about 1/2
               mile west of the tailings pond  (one plus in Table
               15).

     (4)   Monitoring Considerations

          0    Several wells located on private property near the
               Young operation are periodically monitored.  Bear
               Creek is monitored at least once a year at points
               upgradient and downgradient of the Young site  (one
               plus in Table 15).

          0    There are no apparent external influences which
               would significantly interfere with a monitoring
               program.


Viburnum Mine—

     The Viburnum Mine is owned and operated by St. Joe Minerals

Corporation and is located 1.5 miles southeast of Viburnum, Mis-

souri.   This site was selected because:

     (1)   The waste management practice is typical of other Mis-
          souri lead tailings ponds:

          0    Unlined pond with recycle of tailings water to
               beneficiation process  (no discharge).

                                82

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     0     Tailings  pond was  constructed  by  damming  a  valley.
          Tailings  pond dam  construction consist  of a small
          earthen starter  dam and  coarse tailings.

(2)   Presurvey  waste  characteristics  are typical  of other
     lead/zinc  tailings ponds sampled during  the  Presurvey:

     0     Some  liquid and/or EP  acid  extracts of  settled
          solids  or dike material  revealed  concentrations  of
          certain metals which were greater than  10 but less
          than  100  times the PDWS  (two pluses in  Table 15).

     0     Cyanide is  employed in the  sulfide  flotation pro-
          cess  (one plus in  Table  15).

(3)   Environmental  factors are typical of other Missouri
     lead  mine  operations.

     0     Hilly topography (elevations between 1,000  and
          1,300 feet)  in a high  precipitation - low evapo-
          transpiration setting  which is typical  of the en-
          tire  New  Lead Belt mining operations in southeas-
          tern  Missouri.

     0     The substrata underlying the tailings pond  con-
          sists mainly of  massive  carbonate formulations,
          regional  in extent.

     0     The pond  is located fairly  close  (-1/2  mile) from
          Indian  Creek,  a  continuous  flowing  drainage for
          the area  (one plus in  Table 15).

     0     Groundwater in the vicinity of the  pond is  less
          than  50 feet deep,  which is typical of  valleys in
          the New Missouri Lead  Belt.   (two pluses  in Table
          15).

(4)   Monitoring Considerations

     0     Mining  effects on  the  environment within  the New
          Missouri  Lead Belt has been studies by  the  Univer-
          sity  of Missouri (one  plus  in  Table 15).

     0     The tailings pond  is only 4 years old;  however,
          since there groundwater  is  relatively shallow, it
          is believed that the age of this  waste  management
          practice  will be sufficient to detect leach.ate
          within  the  groundwater system  (one  minus  in Table
          15).
                          83

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Molybdenum Tailings Pond Sites

     The three primary molybdenum mines,  two in Colorado and one

in New Mexico, generate about 30 million tons of tailings annual-

ly, and account for about 2 percent of the solid waste generated

by non-coal mining industries.  Tailings from the beneficiation

plants at these sites are all slurried to unlined impoundments.

State-of-the-art tailings disposal technology includes seepage

collection/recycle systems at the base of the dams which are con-

structed of coarse tailings.  The two Colorado sites account for

the majority of the molybdenum tailings produced, in addition fu-

ture expansion of this industry segment is likely to include ad-

ditional mine development in Colorado.

     Based on application of the Step III criteria to the two

Colorado tailings pond Presurvey sites (Table 16), one tailings

pond site was selected for comprehensive monitoring:

     0    Henderson Mine  (No. 50)


Henderson Mine--

     The Henderson Mine is owned and operated by the Climax Mo-

lybdenum Company, a subsidiary of AMAX, Inc.  The mine is located

on the eastern side of the Continental Divide near Empire, Colo-

rado, while the mill is on the western side of the Divide about

15 miles away.  The tailings pond at this site was selected

because:

     (1)  The waste management practice is typical of other pri-
          mary molybdenum mines:

          0    Unlined pond with recycle of decant water and col-
               lected seepage to the beneficiation process.

                                84

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                            TABLE 16.   EVALUATION OF SPECIFIC MOLYBDENUM TAILINGS POND SITES
Site
No.
49
50
Typicality of waste management practice
Waste characteristics
EP
toxldty
*
+
Corroslvlty
+•+
4-f
Radio-
activity
0
0
Cyanide
+
+
Environmental factors
Precipitation/
evapotrans-
plratlon ratio
+
4
Proximity to
surface water
•f
+
Proximity to
groundwater
++
+
Monitoring considerations
Existing
monitoring
program
*
4-
External
Influences
0
00
en

-------
     0     Tailings  dike  construction  consists of  an earthen
          toe  dam,  with  successive  lifts of coarse tailings.

(2)   Presurvey waste  characteristics  are. typical  of other
     molybdenum tailings ponds  sampled during the Presurvey:

     0     Some liquid and/or  EP acid  extracts of  settled
          solids from the tailings  pond or dike material re-
          vealed that certain metals  were in concentrations
          greater than,  but less than 10 times the PDWS  (one
          plus in Table  16).

     0     Samples of  material in the  tailings pond revealed
          levels of potential acidity in the same range as
          found in  the other  major  operations  (two pluses in
          Table 16).

     0     Cyanide is  employed in the  flotation process  (one
          plus in Table  16).

(3)   Environmental  factors are  typical of those at tailings
     ponds at  the other  primary molybdenum mines.

     0     Mountainous topography in Alpine/sub-Alpine set-
          ting similar to the other major operation in
          Colorado.

     0     The  substrata  underlying  the tailings pond area is
          highly siliceous material,  consisting of clays,
          sands, and  gravel overlying bedrock.

     0     It is located  in the  Ute  Creek watershed, with
          drainage  north-east to the  nearby Williams Fork
          River, approximately  0.5  mile from the  Williams
          Fork River  (one plus  in Table 16).

     0     Although  no specific  data was available on depth
          of groundwater in the immediate area the available
          information suggests  that groundwater depth is not
          greater than 150 feet, similar conditions exist at
          the  other operation (one  plus in Table  16).

(4)   Monitoring Considerations

     0     There are no groundwater  monitoring wells in  the
          area of the tailings  pond,  as is true of the  other
          Colorado  operation.  There  are some surface water
          monitoring  programs at the  tailings pond sites
          (one plus in Table  16).

     0     There are no apparent external influences which
          would significantly interfere with a monitoring
          program.
                          86

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     Table 17 presents a summary of the specific sites selected



for each industry segment waste management practice to be studied,
                               87

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TABLE 17.  MINE SITES SELECTED FOR COMPREHENSIVE MONITORING
    Southwest copper tailings ponds
         Pima (No. 28) - Arizona
         San Manuel (No. 30) - Arizona
         Sieritta (No. 31) - Arizona
         Morenci (No.  32) - Arizona

    Southwest copper leach dumps
         Chino (No. 33) - New Mexico

    Florida and Idaho phosphate mine waste rock dumps
         Fort Green (No. 2) - Florida
         Lonesome (No. 3) - Florida
         Wooley Valley (No. 8) - Idaho

    Florida phosphate tailings ponds
         Fort Green (No. 2)
         Suwannee River (No. 4)

    Wyoming uranium mine waste rock dumps
         Bear Creek (No. 16)
         Lucky Me (No. 19)

    Wyoming and New Mexico uranium mine water ponds
         Churchrock No. 1  (No. 13) - New Mexico
         Section 35 (No. 14) - New Mexico
         Shirley Basin (No. 18) - Wyoming

    Nevada and South Dakota gold/silver tailings ponds
         Carlin (No. 52) - Nevada
         Lead (No. 55) - South Dakota

    Missouri and Tennessee lead/zinc tailings ponds
         Young (No. 40) - Tennessee
         Viburnum (No. 46) - Missouri

    Molybdenum tailings pond
         Henderson (No. 50) - Colorado
                             88

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            FUTURE PLANS FOR COMPREHENSIVE MONITORING






     At this time the EPA is planning to monitor all of the rec-



ommended sites.  However, some sites may be dropped from the mon-



itoring program if sufficicent funds are not available.  Other



sites may be dropped if information is uncovered during the ini-



tial site visit that would make the site undesirable for addi-



tional study.



     Figure 8 presents the schedule for the major task involved



in conducting the comprehensive monitoring phase of the study.



Eash of the major tasks is discussed below.






COMPANY CONTACTS



     A period of approximately one month will be required for



PEDCo to establish the proper contacts with the mining companies



selected for comprehensive monitoring.  A schedule will be estab-



lished for the initial site visits.  Potential problem areas such



as the procedures to be followed for site access, safety require-



ments, etc., will be discussed.






INITIAL SITE VISITS



     Site visits of two to four days' duration will be made to



insure that the actual site characteristics will facilitate a



monitoring program and to collect all background information nec-




essary for developing monitoring plans.  Several teams, consisting




                                89

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VD
O


Mining company contacts
Initial site visits
Development of compre-
hensive monitoring
research plan
Industry review and
comment
Comprehensive moni-
toring program
Final report
1981
M
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1982
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                               Figure  8.   Schedule for Comprehensive Monitoring Program.

-------
of personnel from PEDCo, their subcontractors,  and EPA will



conduct these visits.






COMPREHENSIVE MONITORING RESEARCH PLAN



     At the completion of the initial site visits, PEDCo will



prepare a comprehensive monitoring research plan for each indi-



vidual site.  This plan will describe in detail the types of sam-



ples to be collected, the parameters to be monitored, the samp-



ling frequency, the length of the monitoring program, and other



site specific details.  The comprehensive monitoring research



plan will be reviewed by the individual mining  company before



implementation.



     A number of parameters will be monitored.   These include the



following:



     0    Solid Waste.  Representative mining solid waste samples



          will be collected and analyzed.  The  samples may be



          grab samples, composite samples, and  or samples ob-



          tained from borings.  In addition to  the normal ana-



          lytical work, RCRA Extraction Procedure tests will be



          conducted on some of the samples.



     0    Groundwater.  It is believed that this aspect of the



          study is extremely important.  In order to adequately



          study the groundwater hydrology and quality, a series



          of wells will be drilled.  The exact number, depth, and



          orientation of these wells will be determined after the



          preliminary site visits have been made.  When necessary



          to define groundwater movement, pump, draindown, and





                               91

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          other tests will be conducted.  All drilling will be



          subcontracted.




     0    Surface Water.   The surface water flow around a dispos-



          al practice will be thoroughly studied.  Both quantity



          and quality of the surface waters will be evaluated.



          Since the flush-off of pollutants during a storm event



          may be a time of significant pollution contribution,



          sampling during storm events will be conducted.  Data




          will be collected using weirs and Parshall flumes and



          continuous recorders and samplers.



     0    Air Monitoring.  Air samples will be collected from se-



          lected disposal sites to measure fugitive or other air



          emissions such as radon gas.  Due to funding limitations,



          the extent of this phase of the study may be limited.



     0    Meteorological.  Where on-site data is not available, a



          weather station will be installed at each site.  Records



          of precipitation, evaporation, relative humidity, tem-



          perature, and wind direction and magnitude will be ob-



          tained.





COMPREHENSIVE MONITORING



     The comprehensive monitoring will be initiated on a staggered



basis to allow for efficient utilization of equipment and program



personnel.  Regional climatic conditions will play a major role



in developing the monitoring schedule.  It is estimated that each



site will be monitored for a period of two to six months.  PEDCo



personnel will not be on site the entire time.  It may only be




                               92

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necessary to collect samples weekly or even monthly.   At the con-



clusion of the data collection phase of the study,  all weirs,



flume, meteorological equipment, etc., will be removed and all



wells capped or sealed.






FINAL REPORT



     At the conclusion of the comprehensive monitoring phase of



the study, PEDCo will prepare a detailed final report describing



all the results of the mining solid waste study.  EPA will use



this data, as well as the results from other studies  as part of a



final report to Congress fulfilling the Agency's mandate under



RCRA and the 1980 Amendments.
                               93

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                Attachment A


       MINE SITES SELECTED FOR COMPREHENSIVE MONITORING
Southwest copper tailings ponds
     Pima (No.  28) - Arizona
     San Manuel  (No. 30) - Arizona
     Sieritta (No. 31)  - Arizona
     Morenci  (No.  32) - Arizona

Southwest copper leach  dumps
     Chino (No.  33) - New Mexico

Florida and Idaho  phosphate mine waste rock dumps
     Fort Green (No. 2) - Florida
     Lonesome (No. 3) - Florida
     Wooley Valley (No. 8) - Idaho

Florida phosphate  tailings ponds
     Fort Green (No. 2)
    -Stwa-nnee-R-i-ver-'(No-r~4-} -A-v^y 0-«-

Wyoming uranium mine waste rock dumps
     Bear Creek (No. 16)
     Lucky Me (No. 19')

Wyoming and New Mexico uranium mine water ponds
     Churchrock No. 1  (No. 13) - New Mexico
     Section 35 (No. 14) - New Mexico
     Shirley Basin (No. 18) - Wyoming

Nevada and South Dakota gold/silver tailings ponds
     Carlin (No. 52) -  Nevada.
     Lead (No.  55) - South Dakota

Missouri and Tennessee lead/zinc tailings ponds
     Young (No. 40) -  Tennessee
     Viburnum (No. 46) - Missouri

Molybdenum tailings pond
     Henderson  (No. 50) - Colorado

-------
  DATE.
                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        FBB24I9S1
                                                                REGION 1>;

                                                                HoiW'81
.SUBJECT: Mine Solid Waste Study ~ Two Reports for Review
                       .  o
                      A\A'
       Yvonne M. Garbe
  FROM-. Office of Solid
       Hazardous & Industrial Waste Division

    TO: EPA Regional Offices  I - X

            Our Office of Solid Waste and the Office of Research and
       Development have been conducting a joint investigation of the
       mining industry as mandated under Section 8002(f) of RCRA, 1976
       and more recently, under Section 8002(p) of the 1980 RCRA Amendments.

            We have just completed the first phase of a major $3.1 million
       technical contract to PEDCo Environmental, Inc. to study the phos-
       phate, uranium, iron, copper, lead, zinc, molybdenum, gold and silver
       mining industries.  The "tirst half of the study included sampling
       and analyses of solid wastes collected from 65 various mine sites
       within these industry segments.

            The sampling and analytical procedures along with the test
       results are presented in the accompanying Phase I - Presurv.ey .draft
       report.  Copies of the report have been distributed for review and
       comment to the participating industry sites as well as to various
       Federal Agencies and  program offices concerned with mining.   If
       you wish to submit comments, we would appreciate receiving them no
       later than March 15,  1980 to allow ample time for incorporation
       into the final report.

            A second draft report, Mining Industry Solid Waste Interim  »,
      • Report, is also enclosed for your review.  The report explains the
       method EPA employed to select 20 candidate sites (see attachment A)
       for more comprehensive study during the second phase of the contract.
       Those sites were selected from the original list of 65 visited
       during the Presurvey  (Phase I).  Under Phase  II,
       streams and associated management practices will
       monitored for their effects on the environment.
       likely that our present budget will not allow us
       sites, we will visit  each initially with the  intention
       the number to 12-15 final sites at a later date.
                                                         specific waste-
                                                         be  comprehensively
                                                         Although it  is
                                                         to  monitor all  20
                                                              of reducing
            A general  Phase  II  schedule beginning with  the  initial  site
       visits and  an outline of  the  comprehensive monitoring  program  are
       discussed  in this report  (see pages  89  -  93).  Your  comments on
       this draft  report are invited as well.  •

            We have been and will  continue  to  work  closely  with  the Regional
       Offices throughout  this  study.  We will notify the appropriate staff
       within each Region  well  in  advance of all site visits.  Meanwhile,
       if you have questions regarding the  reports  or the study,  or if you
       are aware  of any  information  that would enhance,  deter or  otherwise
       affect this study,  please contact me at your earliest  convenience.
       Your cooperation with both  our contractors and our.headquarters and
       research offices has  be.en greatly appreciated.
        Attachments
: PA Form 1320-6 (Rev. 3-76)
                    (3)

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