Mining Strategy
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Mining Strategy
**DRAFT REGIONAL MINING STRATEGY**
EPA Region 10
December 4, 1997
BACKGROUND
Mining has played a significant role in the development of
this country. The industry has, and continues to be, an
important contributor to Regional economies in the Northwest
and Alaska. As hardrock mining continues to expand in Region
10 EPA must find ways to' work more effectively with other
mining stakeholders, including industry, to promote
environmental -protection goals. This strategy provides a
framework for that effort.
As an industrial sector, mining affects every major EPA
program. Tailings and waste rock disposal, wastewater
discharges, air emissions, storage of toxic reagents and even
disposal of PCB's can potentially affect surface and ground
water quality, drinking water supplies and air quality.
Mining can also cause losses of aquatic and terrestrial
habitat.
From a federal regulatory perspective, mining projects pose
unique challenges. They are technically complex and there is
no single environmental law that specifically addresses all
mining impacts. Instead, mining projects are addressed
through a fragmented set of federal authorities (administered
by a number of federal agencies), none of which were
developed with the specific intent of regulating mining.
While mining law reform has recently been on the
Congressional agenda, revisions to the 1872 Mining Law have
been focused primarily on updating "equity" issues rather
than environmental concerns. Furthermore, although Superfund
has been utilized to address environmental concerns at a
number of mining sites, Congress has basically exempted large
volume low toxicity mine waste from regulation under Subtitle
C of the federal solid waste law, the Resource Conservation
and Recovery Act (RCRA). For a variety of reasons, EPA has
declined promulgating solid waste regulations for mining
under RCRA subtitle D. This means that very complex solid
waste issues often must be handled either through other
federal authorities which were not developed to deal with
solid waste (e.g., the Clean Water Act) or under authorities
of state or local government.
States, Tribes, and local government have often been leaders
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in mining regulation. While no federal legislation
specifically addressing the environmental impacts of non-coal
mining exists, many States have passed their own statutory
programs. In addition, all States have general environmental
statutes that provide coverage to mining operations. Many
States have been delegated authority to implement federal
statutes such as the Resource Conservation and Recovery Act
(RCRA) and the Clean Water Act(CWA). The vital role of
States and Tribes in mining regulation cannot be overstated;
it is imperative that EPA understand these programs in order
to improve its own program implementation.
This complex regulatory landscape combined with the
recognition by EPA Headquarters that mining projects have in
some cases caused serious environmental degradation has led
to development of a National Hardrock Mining Framework (NMF) .
The draft NMF describes the environmental protection
challenges mining projects can present and emphasizes problem
solving by working with other stakeholders in an open,
cooperative manner whenever possible. The NMF discusses the
various regulatory and non-regulatory tools in the EPA
"toolkit" for addressing these problems. It also recognizes
the role of other federal agencies, Tribes, States, local
government, and industry in promoting environmentally sound
mine site management. Currently, recommendations for
improving these tools and the way EPA uses them are being
finalized for presentation to EPA senior managers.
One expectation of the NMF is that EPA Regions with
significant mining activity will tailor Framework
recommendations to their own regional issues and priorities.
Last year a Regional Mining Workgroup (RMW) was established
in Region 10, co-chaired by the Regional Mining Coordinator
and the Office of Water Mining Specialist. A Core Team of
the RMW has developed this draft Regional Mining Strategy
that will help set Region 10 priorities with respect to
mining issues over the next several years.
MINING IN REGION 10
Mining activity in Region 10 is extensive. This is reflected
in the fact that no less than 85 Region 10 employees are
involved with mining projects in some capacity. They work in
many different EPA programs, often on the same projects,
applying different tools and expertise to achieve
environmental protection goals. Following is a brief summary
of mining activities in the Region.
Alaska
Alaska is the fifth largest gold producing state in the
nation. Now that the Fort Knox project near Fairbanks has
begun production, the state's gold production will likely
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double. Exploration work in Alaska during 1996 was
considerable, perhaps the most extensive in nearly 100 years.
Several major new mines can be expected to enter the
permitting phase over the next couple of years, adding to the
considerable EPA workload in Alaska.
Currently operating mines include over 400 placer operations
as well as Red Dog, a world class lead/zinc mine,
Greens Creek (silver and zinc), and Usibelli coal.
Responding to permitting and compliance issues associated
with these
facilities, and those that will come on line in the next
decade, will require a significant resource commitment by EPA
since the Agency retains NPDES permitting responsibilities in
Alaska.
According to available estimates there are over 4,000
abandoned and inactive mines in the state, covering nearly
28,000 acres. Inventory and prioritization with respect to
environmental concerns are ongoing at several levels of
government.
Idaho
Idaho produced a record 300,023 ounces of gold in 1995, more
than double Alaska's production. Higher silver prices have
led to increased exploration activity, especially in the
Coeur d'Alene district. Several new or expanding gold mines
have recently entered, or are anticipated to enter, the
NEPA and permitting phase (Stibnite, Thunder Mountain,
Atlanta and Humbug). A large garnet mine in northern Idaho
(Garnet Creek) is also entering the NEPA and permitting
phase.
There are numerous mines currently operating in Idaho, over a
dozen of which are "major" NPDES dischargers. All but one
permit has expired. EPA is working with the Stibnite, Grouse
Creek, Thompson Creek and Kinross Delamar/Stone Cabin mines
on NPDES permitting and compliance issues. The Beartrack
mine began full scale operations in 1995.
According to the USDA Forest Service, there are over 5,000
inactive mines in Idaho covering over 27,500 acres. Two
inactive mines are currently Superfund sites (Bunker Hill and
Blackbird). Several others, while not on the National
Priorities List, are being addressed under Superfund
authorities. Inventory and prioritization are ongoing
efforts.
Oregon
• Oregon currently has the least mining activity of the four
Region 10 states. Significant metal deposits include the
Grassy Mountain gold deposit in southeastern Oregon and the
Bornite copper deposit northeast of Salem. Currently there
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is no ongoing permitting activity at either site, although an
EIS has been prepared for Bornite. No mining is anticipated
at these two site is the near future. Kinross and the state
of Oregon are currently in litigation regarding the Bornite
project.
Gravel/aggregate extraction from rivers, floodplains, and
upland sites is the largest type of mining in the state.
Demand for aggregate has outstripped production due to the
state's strong economy and strict land use laws. Gravel
mining can have serious effects on salmon/fish habitat. Gold
mining is currently limited to several placer mines in Baker,
Grant, Josephine and Lane counties.
There are an estimated 3,500 inactive and abandoned sites in
Oregon covering over 9,000 acres. The White King/Lucky Lass
uranium mine, an Oregon Department of Energy facility, is an
active Superfund site near Lakeview. EPA is currently
conducting an inactive mine inventory and assessment in the
Granite Creek watershed in the NE portion of the State.
Washington
Washington produced 107,000 ounces of gold in 1995, about one
third of Idaho's production. Nearly all of this was produced
from Echo Bay's Kettle River Lamefoot mine near Republic, the
only major gold mine operating in Washington. The Crown
Jewel Gold Mine project in Okanogan County is the only large
new mine currently proposed. It is in the EIS and permitting
phase. Exploration work continues in the Wenatchee gold
belt, in the Wind River deposit (Skamania County) and in
areas adjacent to the Pend Oreille Mine near Metaline Falls.
There is no current estimate available for inactive and
abandoned mines in Washington. The Cannon Mine in Wenatchee
closed in 1994 and Hecla Mining's Republic Unit closed in
early 1995. Closure of the Sherwood Mine has been cited as an
example of a successful reclamation effort. They are now in
the reclamation phase. In the N.E. portion of the state the
Midnite Mine and Dawn Mill are in the early stages of
reclamation planning. The Holden Mine near Lake Chelan is an
abandoned copper mine that is one of the state's and USFS'
top priority Superfund cleanup sites.
STRATEGY DEVELOPMENT
In recognition of the cross-media nature of mining
activities, and given the lack of any overarching federal law
that addresses the environmental impacts of mining
activities, Region 10 staff involved with mining formed a
Regional Mining Workgroup (RMW) in 1994. The main purpose
was to create a sector-based approach that would promote
better coordination among different media programs dealing
with the same or similar mining issues. In 1995, Region 10
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management selected a Regional Mining Coordinator (Nick Ceto)
and an Office of Water Mining Specialist (Bill Riley) who
worked with the RMW to form a Regional Mining 'Core' Team.
This team includes a representative from each major EPA
program that deals with mining.
Early on the Core Team began development of a Regional Mining
Strategy. The overall goal of the Strategy is to determine
where and how to invest the Region's limited resources that
are available to address mining issues so as to obtain the
highest possible return in terms of environmental protection
and restoration.
The Core Team met regularly for several months to develop a
draft Regional Mining Strategy using the following four step
process:
Step 1: MINING PROFILE - identify information needed to
understand problems and issues with mining and set priorities
for action.
The Core Team, along with other members of the RMW, and with
assistance from a summer intern, developed a Regional Mining
Profile to provide the "big picture" regarding mining
activity in Region 10. The Profile consists of fact sheets
for the major proposed, operating and inactive mining
facilities in each state. Staff supplemented this with
general information on mining that describes trends in the
industry for each state. These will be updated annually.
Staff also compiled a "who's who" directory of people from
various state and federal agencies involved with managing
mining activities. This includes an internal 'directory', of
EPA staff currently working as part of discrete teams on the
many mining projects in our Region. Lastly, Nick Ceto and
Bill Riley met with officials in each state to learn more
about each state's authorities and capabilities to deal with
current and future mining issues. The Profile includes a
compendium of selected state regulations that identify State
authorities and the nature of their specific mining programs.
Step 2: TOOL SHARPENING - identify deficiencies in the policy
area regarding tools/authorities for directing action.
The Core Team spent a considerable.amount of time reviewing
all of the 'tools' in the EPA mining toolkit. Team members
identified tools that are working well, those that need fine
tuning (or don't work at all) and areas where we need further
policy development to allow us to use the tool(s) more
effectively. The toolkit concept is also a fundamental
element of the National Hardrock Mining Framework. Tool
analysis focused on EPA responsibilities, however Region 10
recognizes that Agency programs must be considered in the
context of the critically important role played by other
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State, Federal, tribal and local environmental agencies.
Step 3: RESOURCE FOCUSING/PROGRAM IMPLEMENTATION -identify,
prioritize and implement actions that will address/resolve
problems identified to date.
Based on the information gathered in steps one and two, as
well as the collective experience and knowledge of the Core
Team, Region 10 staff developed a set of "strategic
principles" and associated tasks to put those principles into
action. These are presented in the following sections. They
include elements of the Region 10 Office of Water Mining Plan
which was developed earlier in the year by the Office of
Water Mining Team.
Step 4: MONITORING - establish tracking/monitoring systems to
determine whether the actions we have implemented are
achieving desired results.
A fundamental principle of any strategy should be a feedback
system to assess whether the strategy is working. The Core
Team agreed that every task should have an associated measure
of success so that continual progress can be made in an
iterative, adaptive manner (see Strategic Principle #10)
STRATEGIC PRINCIPLES
In order to design and implement an effective program to
fulfill agency responsibilities in managing the environmental
concerns posed by mine sites in Region 10, ten Strategic
Principals were identified to guide program improvements.
1) UNDERSTAND THE ENVIRONMENTAL IMPACTS OF MINING - Mining
has a significant impact on the environment in Region 10.
Impacts typically include large areas of land disturbance,
loss of habitat, changes in water quality and quantity, and a
variety of secondary and. tertiary impacts. It is essential to
clearly understand these impacts to develop an effective EPA
Region 10 Mining Strategy and to deal with environmental
concerns at individual sites where EPA has a regulatory
responsibility.
2) EARLY INVOLVEMENT in new mining operations is critical -
Region 10 needs to be actively involved in the earliest
stages of mine site evaluation and planning. As our
understanding of the impacts of mining improves it will be
critical to apply these lessons learned to new site
development. A pro-active approach to problem identification
and problem solving is far preferable to a reactive mode.
Predictive tools should be improved, and widely applied, to
maximize the value of early involvement.
3) DEVELOPING EFFECTIVE PARTNERSHIPS with other agencies,
states, and industry - EPA needs to be an effective partner
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with other stakeholders to maximize our contribution to
overall improvements in addressing environmental issues in
the mining sector. States and other federal agencies often
provide a leadership role in mine site management. By sharing
our experience and expertise, and learning from trie
experience of others, we will be able to leverage our limited
resources to achieve greater benefits. Effective, well
targeted outreach is a necessity.
4) FOCUS EFFORTS ON PRIORITY SITES/WATERSHEDS - EPA has
limited resources to devote to mining. Consequently,
resources must be devoted to the highest priority problems.
This is particularly important in dealing with inactive and
abandoned mines.
5) USE EXISTING TOOLS MORE EFFECTIVELY - There are many tools
available to address the environmental consequences of
mining. EPA, states, other federal agencies, local
government, and tribes all have programs, both regulatory and
non-regulatory, that apply to mine sites. A primary element
of this strategy is to understand the tools available to EPA
and others to address mining, and to use them more
effectively.
6) MAINTAIN/ENHANCE IN-HOUSE TECHNICAL EXPERTISE - Mine site
environmental issues are very complex. Many disciplines are
called upon to fully evaluate potential mine site impacts.
Experience has taught us that it is imperative that EPA have
competent in-house staff to evaluate mining projects. This
technical capability is essential to EPA program delivery and
increases our credibility with State and federal partners,
and the regulated community. By sharing our expertise we can
build the capacity of our partners. We can also enhance our
own expertise by working more closely with the regulated
community, and other mining stakeholders, to solve problems
of mutual interest.
7) MAINTAIN A PRIMARY POINT OF CONTACT ON MINING ISSUES -
Creation of the Regional Mining Coordinator and the Office of
Water Mining Specialist positions has been instrumental to
the progress made in working with mines in the Region over
the past year. It is also important to maintain a primary
contact for the States of Alaska and Idaho, the most active
mining states in the Region. These are also states where EPA
continues to implement the NPDES program. State contacts are
crucial to early and effective EPA involvement in site
scoping activities.
8) UTILIZE A TEAM APPROACH TO SITE MANAGEMENT - A
multi-disciplinary team is the most effective way to manage
both the Regional Mining Program, and EPA involvement at
individual sites.
9) PROMOTE SCIENTIFIC AND TECHNOLOGICAL IMPROVEMENTS -
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Improvements are needed in the analytical tools used to
predict and mitigate mine impacts. . A better understanding of
the nature of both existing and future impacts will assure
the best possible solutions. Promoting innovative, cost
effective technologies for mine site management is another
critical priority.
10) EVALUATE OUR PROGRESS AND MAKE IMPROVEMENTS - The Mining
Team is committed to continued improvements in program
delivery. Evaluating our effectiveness in contributing to
achievement of environmental goals will assist in determining
needed refinements.
STRATEGIC ACTIONS
The following action items are presented according to the
strategic principle they are designed to promote:
1. Understanding the Environmental Impacts of Mining
a. Use a CIS-based system to overlay mining sites/districts
with impaired waterbodies to identify potential mine related
impairments.
b. Continue investigations of alternative waste
management techniques, such as dry and submarine
tailings disposal.
c. Work with states/tribes and other partners to
identify mine site impacts.
2. Early Involvement
a. Continue active participation in the Idaho Joint
Review Process.
b. Assign teams to all major new mine projects where
EPA has regulatory responsibilities to improve the
effectiveness of EPA participation.
c. Emphasize pollution prevention by comprehensively
addressing environmental issues early in the EIS and
permitting process. This includes completing an EIS
Scoping Letter for Mine sites and developing mining
specific NPDES permit application requirements (to
address hydrologic modeling, treatability studies,
and acid rock drainage concerns).
3. Developing Effective Partnerships
a. Host a new/proposed mine permitting workshop for
Region 10 states and federal agencies.
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b. Distribute a list of mining expertise/experience
to Regional partners.
c. Develop and distribute a Region 10 Mining
Newsletter as a cooperative effort with partners,
including industry.
d. Host an EPA/Industry forum where mining executives
and EPA program managers can meet to discuss the
future of mining in Region 10 and identify areas of
common interest.
e. Evaluate options for recognizing environmentally
sound mining practices in Region 10; include
Northwest Mining Associaton (NWMA) in this effort.
f. Continue funding of, and participation in, the
Tri-State agreement, a cooperative effort with
Washington, Idaho, and Oregon to share information
and expertise on mining issues.
g. Provide technical assistance to state and federal
agencies in complex technical areas, such as
hydrology, waste characterization, and water quality
modeling.
h. Continue efforts to understand each state's mining
program and explore ways to complement rather than
duplicate state efforts.
4. Focus Efforts on Priority Sites/Watersheds
a. Host a Regional meeting on inactive and abandoned
mine sites to discuss inventories and priority
setting.
b. Continue to' use the Core Mining Team to set
priorities for evaluating newly proposed mining
projects.
5. Use Existing Resources More Effectively
a. Conduct in house cross-program training on mining
"tools".
b. Implement innovative "pilots" for existing
authorities (e.g., use of NPDES stormwater permits at
inactive mines).
c. Provide negotiation training to mining team
members.
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d. Develop a Multi-Media inspection checklist for
distribution to industry to assist mines in achieving
compliance goals.
e. Work with HQ and other Regions to resolve
implementation issues presented by the National
Toxics Rule.
f. Through the Eastside Forest Management Plan
process, EPA should help to develop standards for
mining on eastside forests that will provide adequate
protection for important aquatic and riparian
resources.
g. Work with mining stakeholders to understand
technical and administrative barriers to development
of centralized mine waste repositories in areas of
historic mining and propose options for overcoming
those obstacles.
6. Maintain/Enhance In-House Technical Expertise
a. Attend mining conferences, present papers on
mining and the environment.
b. Fund training for Region 10 staff on mine site
issues.
c. Host "brownbags" on mining issues; include
external partners.
d. Maintain a mining library within the Regional
Office.
e. Continue participation in National workgroups.
7. Maintain a Primary Point of Contact for Mining Issues
a. Continue to support Regional Mining Coordinator
and Office of Water Mining Specialist positions
(these
positions act as primary contacts for Washington and Oregon)
b. Continue to support Dave Tomten as 100 mining
contact, and formalize the Regional commitment to
this position.
c. Establish an AOO, and perhaps SE Alaska, mining
contact.
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8. Utilize a Team Approach to Site Management
a. A cross-program team will be designated for each
•priority site. The Core Team will determine Regional
priorities.
b. Continue to utilize the Core Mining Team and
Regional Mining Workgroup to consult on site specific
issues.
9. Promote Scientific and Technological Improvements
a. Develop siting guidelines and information
requirements for evaluating proposed sites.
b. Fund the Coeur d'Alene Basin innovative technology
demonstration project.
c. Work with the NWMA to identify innovative
approaches to mine site management and publicly
recognize the facility operators.
d. Encourage EPA technical experts to present
papers/poster sessions at appropriate conferences and
workshops.
10. Evaluate Our Progress and Make Improvements
a. Incorporate specific measures of success for each
action item in the Regional Mining Workplan when
developed (it will be based on this strategy) .
b. Conduct a qualitative evaluation of our mine
project reviews.
c. Evaluate progress in addressing inactive and
abandoned mines in priority watersheds annually.
d. Provide an annual progress report on implementing
the Regional Mining Strategy.
e. Seek feedback from our partners.
STATE-BY-STATE PRIORITIES
While the action items displayed above are pertinent to all
our states, there are certain priorities that warrant an
emphasis on a state-by-state basis.
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Alaska
The extensive exploration work underway is likely to create
an even larger EIS and permitting workload in the near
future. Given the numerous on-going EIS, permitting and
compliance issues that are already overtaxing staff
capabilities, this new workload suggests that Alaska be given
top priority for building partnerships and providing up-front
assistance, in the mine planning and evaluation process. The
following strategic actions would help prepare Region 10 for
the increased mining workload:
a. Assign a full-time mining specialist to the Alaska
Operations Office to serve as a front-line point of contact.
b. Develop an interagency team, composed of key
contacts from other federal and state agencies, that
would help coordinate Alaska mining issues
(particularly new mine NEPA and permitting) in a
fashion similar to the Idaho Joint Review Process.
c. Seek to invest EPA research or AC&C funds in
Alaska-specific mining issues (e.g., tailings
disposal in steep, wet climates or in permafrost
areas; reclamation of placer mines) .
With respect to inactive and abandoned mines (lAMs), a
meeting was held with the USFS, Alaska DOL, NFS, USGS, BLM,
and the Alaska Miners Association on November 5, 1996 to
discuss IAM inventories and begin developing a strategy for
future work. EPA will support this effort as an integral
part of the implementation of the Regional strategy in
Alaska.
Idaho
The state of Idaho has recently developed the Idaho Joint
Review Process (JRP) which promises to be an effective means
for interagency communication and coordination on mining. To
make the most of this opportunity the following actions are
recommended.
a. Maintain a full-time mining specialist in the
Idaho Operations Office to serve as a front-line
point of contact.
b. Through the JRP, determine what EPA resources are
most critical to properly evaluate mining projects
(proposed, existing and inactive).
lAMs will continue to be a priority in Idaho. EPA will
continue to work with state and federal agencies to identify
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priority sites and work with our partners to implement
cost-effective cleanups.
Oregon
Given the focus on gravel mining and salmon recovery issues
the following action is recommended.
a. Continue to work with the Oregon Division of Geology and
Mineral Industries through the Tri-State Agreement to develop
BMP' s for aggregate mining that could benefit salmon recovery
efforts.
Oregon does not have a comprehensive inventory of IAM sites,
although a number of agencies have done some limited site
assessment. EPA will work with the State and other federal
agencies to identify priority IAM sites and provide
appropriate support for cleanup initiatives. For example,
EPA is currently helping to identify potential lAMs requiring
cleanup in the Granite Creek watershed in NE Oregon, as well
as providing technical support to the USFS for specific IAM
projects.
Washington
The Crown Jewel proposal in Okanogan County continues to be a
controversial project. EPA should continue to support
evaluating the potential environmental impacts of the project
and to work cooperatively with the USFS, Ecology and other
entities through the permitting phase.
Currently the State of Washington considers the Holden Mine
Site near Lake Chelan to be the highest priority IAM. EPA is
providing technical support to the USFS in evaluating cleanup
options for this site. Region 10 will continue to provide
support for priority lAMs in Washington.
Canada
The boom in gold mining affects our neighbors to the north as
well. Unfortunately, a number of Canadian mining operations
could have potentially significant impacts on cross-boundary
waters, most of them affecting southeast Alaska (e.g.,
Tulsequah Chief). There is also the potential for American
.mines (e.g., the Crown Jewel project) to affect Canadian
waters. Therefore the following action is recommended.
a. EPA should maintain a regular dialogue with
Canadian officials, as well as state officials in
Alaska and Washington, to keep abreast of new mining
proposals and to assure that the potential impacts to
cross-boundary waters are properly addressed and
mitigated.
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CONCLUSION
The mining industry in the NW and Alaska devotes considerable
resources to identifying and managing environmental concerns
as an integral component of mine site development and
operation. Clearly mining practices have improved
considerably in the past decade. Nonetheless, modern mines
can still pose potential environmental threats in spite of
improved practices to mitigate environmental concerns.
Ongoing and potential environmental impacts posed by both
current and historic mining in the Region are significant,
particularly in Idaho and Alaska.
Region 10's Mining Strategy seeks to address the challenges
posed by historic, active, and proposed mines. The Strategic
Principles developed by the Mining Team will guide efforts to
design and implement a more effective mining program. The
specific initiatives to be undertaken were developed to
provide both short-term improvements, as well as long-term
refocusing of our mining program. Three critical themes
guide this effort: good science and engineering early in the
planning process is essential to managing environmental
concerns; priorities must be established (both programmatic
and geographic); and finally, we must work in partnership
with others to increase our effectiveness and support the
work of others.
[ Main Cleanup | Site List | Brownfields ]
[ Super-fund | CERCLIS Reports | FOIA | Records Center ]
Unit: Emergency Response/Site Cleanup Unit 1
Point of contact: Nick Ceto
E-Mail: ceto. nick @ epamail. epa. gov
Phone Number: (206) 553-1816
Last Updated: 12/24/97
The following is the Universal Resource Locator (URL) for this page:
http://epainotes1.rtpnc.epa.gov:7777/r10/cleanup.nsf/webpage/Mining+Strategy
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