DAMAGE CASES AND ENVIRONMENTAL RELEASES FROM
MINES AND MINERAL PROCESSING SITES
1997
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street. SW
Washington, DC 20460

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Table of Contents
INTRODUCTION
Discussion and Summary of Environmental Releases and DamagesPage 1
Methodology for Developing Environmental Release CasesPage 19
ARIZONA
ASARCO Silver Bell Mine:
"Waste and Process Water Discharges ContaminateThree Washes and Ground Water"Page 24
Cyprus Bagdad Mine:
"Acidic, Copper-Bearing Solution Seeps to Boulder Creek"Page 27
Cyprus Twin Buttes Mine:
"Tank Leaks Acidic Metal Solution Resultingin Possible Soil and Ground Water Contamination'Page 29
Magma Copper Mine:
"Broken Pipeline Seam Causes Discharge to Pinal Creek"Page 31
Magma Copper Mine:
"Multiple Discharges of Polluted Effluents Releasedto Pinto Creek and Its TributariesTage 33
Magma Copper Mine:
"Multiple Overflows Result in Major Fish Kill in Pinto Creek"Page 36
Magma Copper Mine:"Repeated Release of Tailings to Pinto CreekTage 39
Phelps Dodge Morenci Mine:"Contaminated Storm Water Seeps to Ground Waterand Surface
Water"Page 43
Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath anUnlined Impoundment is Discovered"Page 45
Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath anUnlined Impoundment is Discovered"Page 48
ASARCO Ray Complex:
"Airborne Fugitive Dust and Tailings Resultfrom Improper Management and Maintenance"Page 51
ASARCO Ray Complex:
"Emissions from Multiple Sources Resultin Opacity Violations and Impacts on Community"Page 53
ASARCO Ray Complex:
"Mine Discharges Degrade Ground Waterand Surface Water"Page 56
ASARCO Ray Complex:
"Breaches in Tailings Impoundment ContainmentDike Contaminates Eleven Miles of River
Sediment"Page 61 ASARCO Ray Complex:"Discharges from Mine Threaten Water Qualityin a Sensitive
Stream"Page 64ASARCO Ray Complex:"Leachate Solution Overflows Collection Damsto Mineral Creek
and Elder Gulch"Page 67
Phelps Dodge New Cornelia Branch Facility:
"Soil Contamination Results from Improper Disposalof Scrap Metals"Page 73

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BHP Copper, Inc. San Manuel Facility:
"Heavy Metals Contaminate Soil at Five Locations"Page 75
Cyprus Copperstone Gold Corporation:
"Disposal of Non-Mine Related Waste Materialsin Mine Tailings PilesnPage 77
Cyprus Sierrita Corporation:
"Leaks and Seepage Affect Ground Waterand Two Nearby Washes"Page 79FL0RIDA
Associated Minerals (USA), lnc.:"Turbid Discharge Enters Nearby Creek"Page 83
Bartow Phosphate Complex:
"Ground Water Contaminated at CF ComplexTage 85
Florida Solite Company:"Contaminated Discharge EPage 87
Fort Meade Mine:
"Phosphate Pipeline Spills to Peace River Tributary"Page 89
Highland Mine:
"Contaminated Storm Water Enters Tiger Branch CreekTage 91
Highland Mine:
"Release of Turbid Wastewater Resultsin Siltation and Fish Kill"Page 93
Hopewell Phosphate Mine:
"Mine Water Spill Damages Wetlands and Alafia River"Page 96
IMC Fertilizer, Inc.:
"Gypsum Stack Contaminates Surface Water.Ground Water, and SoilTage 98
MMM Nichols Phosphate Mine:
"Unauthorized Mine Water Discharges Affect Alafia River"Page 101
Mulberry Phosphates Plant:
"Fluoride Contamination at Edge of Authorized Zone of Discharge"Page 103
New Wales Chemical Complex:
"Sinkhole Forms Beneath Phosphogypsum Stack"Page 105
Payne Creek Phosphate Mine:
"Settling Pond Break Releases Wastewaterto Local Streams"Page 109
Potash Corporation of Saskatchewan:
"Hazardous Waste Releases Result in Soil Contamination"Page 112
Potash Corporation of Saskatchewan:
"Mining Effluent Degrades Nearby Stream"Page 114
Premier Services Corporation:
"Ionic Imbalance in Discharge Causes Toxicity"Page 116
Riverview Chemical Complex:
"Acidic Discharge Kills Fish and Crabs"Page 118

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i			Page 4
					 ¦'¦¦¦¦				^rMmrr. 		¦¦	. 			 »						 — ¦ 					 ¦ 		¦•¦•¦	—-¦ 				¦. .._L.JJJJ.yf...
MARYLAND
Bethlehem Steel Corporation Sparrows Point Facility:
"Elevated Chlorine Levels in Discharge to Nearby Water Bodies"Page 120
Chemetals lnc.:Toxic Effluents Released from Permitted Outfall to Arundel CoveTage 123
SCM Chemicals Hawkins Point Plant:nBatch Attack Lagoon Contaminates Groundwater"Page 126
SCM Chemicals Hawkins Point Plant:
"Chlorine Released to Air During Process Malfunction"Page 128
SCM Chemicals Hawkins Point Plant:
"Multiple Discharges of Highly Acidic Wastewaterinto the Patapsco River"Page 130
SCM Chemicals Hawkins Point Plant:
"Multiple Releases of Titanium Tetrachloride to Air"Page 133
SCM Chemicals St. Helena Plant:
"Ammonia-Contaminated Effluent Causes Toxicity"Page 135
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Cadmium-Contaminated Effluent into Colgate Creek"Page 137
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Zinc-Contaminated Effluentinto Colgate Creek"Page 139
SCM Chemicals St. Helena Plant:
"Multiple Turbid Discharges Enter Colgate CreekTage 141
NEVADA
USMX, Inc., Alligator Ridge Mine:
"Spills of Process Solutions to Soil Surfaces'Page 143
The Aurora Partnership Auora Gold Project:
"Notice of Violation and Multiple SpillsTage 145
Placer Dome U.S. Inc.'s Bald Mountain Mine:
"Spills of Process Solution to Soil Surfaces" and "Leak in Primary Line'Page 148
Battle Mountain Gold Company
Battle Mountain Mining OperationsPage 152
Kinross Mining Company, Candelaria Mine:
"Process Releases to Soil Surfaces'Page 154
Coeur Rochester, Inc. Mine:
"Process Releases to Soil Surfaces'Page 156
Cortez Gold Mines:
"Process Releases to Surrounding Soils'Page 158
Hycroft Resources and Development, Inc., Crofoot Project:
"Spills of Process Solutions"Page 161
Independence Mining Company Inc., Jerritt Canyon Gold ProjectPage 163

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Kennametal Inc., Falcon Nevada:
"Spill of Process Solution to Soil Surface'Page 166
Santa Fe Pacific Gold Corporation's Lone Tree Mine:
"Process Solution Releases'Page 168
Western States Minerals Corporation, Northumberland Project
"Initiated Clean-Up Efforts'Page 170
BHP Copper, Magma Nevada Mining Company:
"Process Releases to Surface Waters and Soils'Page 173
Round Mountain Gold Corporation, Smoky Valley Common Operation:
"Process Releases to Soil Surfaces"Page 176
Nevada Gold Mining, Inc, Sleeper Project:
"Spills of Process Solution to Soil Surfaces'Page 178
Wind Mountain Mining's Wind Mountain Project:
"Spills of Process Solution to Soil Surfaces'Page 180
NEW MEXICO
Phelps Dodge's Chino Branch:
"Multiple Tailings SpillsTage 182
Cobre Mining Co.'s Continental Mine:
"Multiple Tailings Spills and Seeps'Page 184
Ortiz Project IV:
"Remediation of Groundwater Contamination and Acid Rock Drainage'Page 186
Molycorp's Questa Mine:°Multiple Tailings SpillsPage 188
PENNSYLVANIA
Reading Alloys, Inc.:
"Contaminated Storm Water Released to Ground Water"Page 190
Reading Alloys, Inc.:
"90,000 to 100,000 Gallons of Process WaterContaminates Soil"Page 192
Shenango, Inc. Coke and Iron:
"Multiple Oil Releases Contaminate Soil and Surface Water"Page 194
Zinc Corporation of America Monaca Latex Facility:
"Effluent Limits Exceeded"Page 198
TENNESSEE
Chemetals, Inc. Manganese Dioxide Plant:
"High Manganese-Content Wastewater Spillsinto the Tennessee River"Page 201
Cyprus Foote Mineral Company Butyllithium Plant:"High Turbidity WastewaterPage 203
DuPont New Johnsonville Titanium Plant:
"Landfill Contaminates Ground Water"Page 205

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Page 6
DuPont New Johnsonville Titanium Plant:
"Low pH Wastewater Discharges to River"Page 207
ICI Specialists Phosphorus Plant:
"Sodium Hydrosulfide Spill Causes Second Fish KillTage 209
Savage Zinc, Inc. Clarksville Plant:
"Heavy Metals-Contaminated WastewaterEnters Cumberland River"Page 211
W.R. Grace & Co.:
"Thorium Discharges to CreeknPage 213
TEXAS
American Minerals, Inc.:
"Fugitive Dust Is a Likely Source ofHeavy Metal Soil Contamination"Page 215
Anzon Incorporated:
"Antimony Contaminates Soil and Ground WaterTage 216ASARCO El Paso Plant:"Contaminated
Ground WaterPage 219
ASARCO El Paso Plant:
"Improper Management of Hazardous Waste Resultsin Soil Contamination"Page 221
ASARCO El Paso Plant:
"Spills and Improper Waste Management Resultsin Heavy Metals Soil Contamination"Page 223
Dal-Tile/Dal-Minerals:
"Lead-Contaminated Sludge Dumpedat Seven Texas Sites Contaminates SoilsTage 226

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Page 7
Discussion and Summary of Environmental Releases and Damages
In its continuing efforts of collecting information on the mining and mineral processing industry,
EPA obtain detailed information to develop approximately 62 summaries illustrating recent mining and
mineral processing damage cases in a variety of mineral commodity sectors and states. While these
cases should not be viewed as the results of an exhaustive survey or as a statistically representative
body of knowledge, EPA does believe they demonstrate that releases of constituents to the environment
with consequent environmental damages have been and are occurring from many different types of
mineral production sites and activities across the U.S.
Table 1 provides summary information on the cases of documented damages and contaminant
releases described in this report. Additional detail on the specific facility can be found in the body of the
report. In the accompanying tables, the cases are organized according to the primary mineral
commodity sectors involved. In addition, the table describes the general source of constituent releases,
and provide supporting information on the nature and severity of any resulting environmental damages.
Review of this information provides several general findings, as discussed below.
In addition to the damage cases presented in this report, the following discussion also takes into
consideration data collected from prior EPA efforts. EPA has conducted several studies identifying
human health and environmental damages caused by mining and mineral processing waste
management activities:
*	Report to Congress on Special Wastes from Mineral Processing, July 1990, U.S. Environmental
Protection Agency.
*	Mining Waste Release and Environmental Effects Summaries, Draft, March 1994, U.S. Environmental
Protection Agency.
*	Mining Sites on the National Priorities List NPL Summary Report, U.S. Environmental Protection
Agency, June 21,1991.
*	Human Health and Environmental Damages from Mining and Mineral Processing Wastes, Technical Background
Document Supporting the Supplemental Proposed Rule Applying Phase IV Land Disposal Restrictions to Newly
Identified Mineral Processing Wastes, U.S. Environmental Protection Agency, December 1995.
Mining Sites on the NPL, U.S. Environmental Protection Agency, August 1995.
Mining Sites on the NPL, U.S. Environmental Protection Agency, 1997
This latest information collection effort documents 95 release incidents that have occurred since
1990 at facilities within eight states. Some of the facilities had more than one release. These facilities
operate in 19 distinct mineral commodity sectors (e.g., copper, lead, etc). These incidents involve
management of secondary and waste materials in addition to spills or other releases of feedstocks,
in-process materials, intermediates, or products. A number of the release incidents involve a
combination of materials. Affected media include ground water, surface water, and soils, with the most
common impacts comprising elevated concentrations of heavy metals, increased acidity, and in a few
cases, biotic impacts such as fish kills.
The releases documented in this report have arisen from both extraction/beneficiation operations,
and mineral processing operations. In a few cases, the releases occurred from integrated facilities that
engage in both beneficiation and mineral processing. Of the 49 release incidents occurring from
extraction/beneficiation operations, most involved inadequate containment of tailings, clay ponds, waste
rock, process water, process solution (e.g., cyanide), wastewater, acid mine drainage, and stormwater.
Many of the releases occurred through spills resulting from equipment failure, and operator error while
others resulted from unusually heavy rains and, consequently, the generation of high stormwater
volumes. In a number of other cases, however, use of unlined storage units resulted in seepage of

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Page 8 j
contaminated waters and down gradient ground water and surface water impacts. In addition, EPA found
several instances of releases of hazardous substances to the environment from the loss of beneficiation
feedstocks or in-process materials through failure of containment tanks or storage units or through failure
of transport devices such as pipelines.
The typical management practice used for storage or disposal of mineral processing secondary
materials and wastes was found to have created or exacerbated ground water contamination in the
immediate area. In some cases, a combination of feedstock, in-process materials, secondary materials,
and wastes contributed to ground water, surface water, or soil contamination. Finally, in a limited
number of cases, contamination occurred through episodic or continuing mismanagement of hazardous
and other solid wastes (e.g., commercial chemical spills).
This report refers to the terms "extraction/beneficiation" and "mineral processing" based upon
applicable EPA definitions found at 54 FR 36618-36620 (September 1,1989). In some cases, both
activities occur at the same site or in contiguous operations that share the same facilities. For these
cases, it is sometimes difficult to discern where beneficiation ends and mineral processing begins.
References to the terms extraction/beneficiation and mineral processing are not intended to be
regulatory determinations or final decisions of the status of these materials; rather, EPA did a subjective
evaluation based upon available information. The information on damages cases where beneficiation
operations occur are intended to support the discussions regarding Bevill wastes (see Risks Posed by
Mining and Mineral Processing Wastes, EPA, 1997). Some of the site listed as beneficiation may have,
in fact, mineral processing operations, especially gold mining sites that have furnaces that produce gold
dore. However, the damage incidents from gold sites are focused primarily on beneficiation and
non-exempt commercial chemicals.
In Table 1, the columns under the heading of source of release are divided in three categories (1)
feedstock, in process materials, or product; (2) waste streams; and (3) secondary materials. These
categorizations are not intended to be regulatory determinations or final decisions of the status of these
materials; rather, EPA did a subjective evaluation based upon available information. The detailed
summary of each of these incidents should be examined, as well as the correspond references, to
understand the context for which these materials are categorized.
For purposes of this table only, and in the context of providing a technical basis for solicitation of
public input on issues presented in the January 25,1996 and April 15,1997 proposals, the Agency has
made the following categorizations: a feedstock or in-process material or is an input or ingredient used
in the production of a product, as part of normal operations. A waste stream is typically discarded and
unlikely to be recycled or reclaimed (some exceptions may exist). A secondary material is derived from
a mineral processing operation and may be wholly or partially recovered not only for minerals but for acid
values, heat or cooling properties, make-up water, or other purposes. In many cases, process
wastewater is stored in impoundments and either discharged or a portion may be used as process water.
Also, solids are often found in process wastewaters and in the surface impoundments due to settling.
This effort also documented 42 releases from mineral processing operations. Many of the incidents
involved process and wastewater systems, equipment and/or operator failure, and releases from tanks,
piles, and surface impoundments. In many of these cases, the secondary material is typically recycled in
part or in whole for mineral value, acid value or water. In addition to the cases presented in this report,
EPA reviewed environmental data collected at the Kennecott Copper facility in Utah. Because the site
was proposed to be placed on the National Priorities List and is currently undertaking remedial actions
under an agreement with EPA, a significant amount of information regarding contamination from
secondary materials is available. For example, secondary materials from electrolytic refining, smelter
and furnace flue dusts, acid plant blowdown, and process water all stored in surface impoundments or
piles have contributed to groundwater contaminationl. EPA has developed an extensive administrative
record indicating that the source of groundwater contamination may not be from the massive tailings
ponds, which are waste from beneficiation activities, but rather the contamination may originate from
mineral processing land-based units from the electrolytic refinery and smelter.
In some cases, the value of product-like materials is questionable, and further, land placement of

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products, byproducts, in-process materials, and intermediates can result in environmental problems. For
example, some secondary material is sold as a byproduct for other uses. In Louisiana-Pacific v Asarco.
24 F.3d 1565 a smelter sold copper slag, a hazardous byproduct of the smelting process, to logging
companies for use as gravel ballast in their logyards. The placement of the slag on the ground resulted
in environmental damage. The Court held that the slag was a "byproduct with nominal commercial
value, "which the smelter wanted to get rid or whether it could sell the slag or not. kL at 1575. In other
cases, in-process, intermediates, and commercial products stored in land based units have contributed to
environmental problems. For example, copper concentrate was disposed of in a surface impoundment
at the Kennecott smelter; lead concentrate was found disposed of at a site in Missouri (see Case Files,
Kennecott and Burlington Northern, respectively). Flue dusts, a secondary mineral processing material
commonly recycled, have been found to be a source of contamination not only at Kennecott, an
operating smelter, but also at historic mineral processing NPL sites such as Bunker Hill and the
Anaconda Smelter. It is not known why some flue dusts and spilled metal concentrates are fully recycled
at some facilities but not at others.

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Page 101
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Page 11
Copper
A8ARC0, Ins. Ray Complex
AZ
X

Copper leechate
solution
Coppsr sludg
Copper
ASARCO, Inc. Ray Complex
AZ
X

Pregnant leach
solution
Mill tailings a
storm water
Copper
A8ARCO, Inc. Ray Complex
AZ
X

Copper sulfate
solution process
water

Copper
BHP Copper, Inc. San Manual
Facility
AZ
X
X

Unknown
Copper
Cyprus Bagdad Mine
AZ
X

Pregnant leach
solution

Precious metals
Cyprus Coppsretons Gold
Corporation
AZ
X
X
Empty sodium
cyanide drums
Waste oil end
tires
llmsnite
'Associated Minerals (USA),
Ins.
FL
X


Tailings and
reclamation 8
Lightweight
clay aggregate
Florida Sollts Company
FL

X


Magnesium
hydroxide
Premier Services Corporation
FL

X

Process
wastewater
Phosphate
IMC-Agrico Hopewell
Phosphats Mine
FL
X


Clays and effl
Phosphate
Cargill Fertilizer, Inc. Forts
Meade Mine
FL
X

Phosphats rock
slurry

Phosphate
Mobil Mining and Minerals
Company Nichols Phosphats
Mins
FL
X


Tailings and
effluent
Phosphate
IMC-Agrico Co. Payne Creek
Phosphate Mine
FL
X


Clays and effl
Phosphate
Occidental Chemical
Corporation, Swift Creek
Chemical Complex and Mine,
Suwannee River Chemical
Complex and Mins
FL

X
8ulfuric acid and
molten sulfur
Contaminated
refractory
Phosphats
Occidental Chemical
Corporation, Swift Creek
Chemical Complex and Mins,
Suwanras River Chemical
Complex and Mins
FL

X

Process and
non-process
wastewater
Phosphoric acid
CF Industries, Inc. Bartow
Phosphate Complex
FL

X

Process
wastewater
Phosphoric acid
Mulberry Phosphates, Inc.
Mulberry Phosphates Plant
FL

X

Process
wastewater
Phosphoric acid
IMC-Agrico New Wales
Chemical Plant
FL

X

Process
wastewater
Phosphoric acid
IMC Fertilizer. Ins.
NoralynJPhosphsria Mins P-Z1
Gypsum Disposal Area
FL

X

Process
wastewater
Phosphorio acid
Cargill Fertilizer, Inc.
Riverview Chemical Complex
FL

X

Process
wastewater

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Titanium/Titani
um dioxide
E. 1. DuPont de Nemours and
Co Jne. Highland Mins
FL
X


Storm water
Titanium/Titani
um dioxide
E. 1. DuPont de Nemours and
Co, Ins. Highland Mine
FL
X


Process
wastewater a
storm water
Cadmium
SCM Chemicsle St. Helena
Plent
MD

X

Process
wastewater
Cadmium
SCM Chemicals St. Helena
Plant
MD

X
Raw materials and
cadmium liquor
Process
wastewater
Cadmium
8CIH Chemicals St Helena
Plant
MD

X

Procsss
wastewater
Manganese
Chemetale ,1ns.
MD

X

Process
wastewater,
scrubber wat
cadmium, and
hlowdown
8ilica
8CNI Chemicals Corporation
St Helena Plant
MD

X
Sodium eillcata
Process
wastewater
Steel
Bethlehem 8teel Corporation
Sparrows Point Faoility
MD

X
Chlorinated process
water
Chlorinated p
wastewater
Titanium/Titani
um dioxide
SCM Chemical8 Corporation
Hawkins Point Plant
MD

X

Sulfate proce
wastes and p
wastewater
Titanium/Titani
um dioxide
SCM Chemicals Corporation
Hawkins Point Plant
MD

X
Chlorine gas

Titanium/Titani
um dioxide
SCM Chemicals Corporation
Hawkins Point Plant
MD

X
Acidified sulfate
process feedstock
Process
wastewater
Titanium/Titani
um dioxide
SCM Chemicals Corporation
Hawkins Point Plant
MD

X
Titanium
tetrachloride

Gold
Alligator Ridge Mine
NV
X

Cyanide containing
process solution
Muratie sold

Gold
Aurora Gold Project
NV
X

Cyanide containing
process solution

Gold
Bald Mountain Mins
NV
X

Cyanide containing
process solution

Gold
Barrick Goldstrike and Meikle
Mins
NV
X

Cyanide
Ammonie vepor
Mercury

Gold/ Copper
Battle Mountain Mine
NV
X

Barron leachate

Gold/Silver
Candelaria Mine
NV
X

Cyanide containing
process solution


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Gold/Silver
Coeur Rochester
NV
X

Ore
Cyanide containing
process solution

Gold
Cortez Gold Mine
NV
X

Cyanide contain-ing
process solution

GoldfSilvsr
Cm foot Projaot
NV
X

Cyanide contain-ing
process solution

Gold
Jerritt Canyon
NV
X

Barren process
solution
Teilings slurr
Tungsten
Kenna metal. Inc.
NV

X
Sulfuric acid

Gold
Lone Tree Mine
NV
X

Cysnide contain-ing
process solution
Tailings slurr
Gold
Northumberland Project
NV
X

Cysnide contain-ing
process solution

Copper/ Gold
Magma Nevada Mining Co.
NV
X

Cyanide contain-ing
process solution
Flotation slur
Gold
Smoky Valley Common
Operation
NV
X

Cyanlds contain-ing
process solution

Gold
8leeper Project
NV
X

Cyanide contein-ing
process solution

Silver/Gold
Wind Mountain Project
NV
X

Cyanide containing
process solution

Copperf
Nlolyb-denum
Phelps Dodge Chi no Branch
NM
X
X
8psnt electrolyte
Tailings slurr
Copper
Continetal Mine
NM
X


Tailings slurr
Acid rackdra
Gold
Ortiz Projaot IV
NM
X


8pent ore lea
Acid rock dra
Molyb-demon
Questa Mine
NM
X


Tailings slurr
Beryllium
NGK Metals Corporation
PA

X

Spent sulfur!
Ferrous metals
Shenango, Inc. Coke and Iron
PA

X
Oil

Ferrous metals
Reading Alloys, Inc.
PA

X

Slag
Ferrous metals
Reading Alloys, Inc.
PA

X
Proceea meter

Tin
LTV Steel Company Aliquippa
Tin Mill
PA

X

Process
wastewater
Zino
Zino Corporation of America
PA

X

Process
wastewater
Cadmium
Savege Zino, Ins. Harksvillo
Plant
TN

X

Process
wastewater

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" •"^ 	 	 					
Page 14
Manganese
Chametal8, Inc. Manganese
Dioxide Plant
TN

X

Process resid
process wast
Phosphate
ICI Specialists Phosphorus
Plant
TN

X
8odlum
hydro sulfide

Thorium
W. R. Grace and Co.
TN

X

Wastewater,
wastewater e
end storm wa
Titanium/Titani
um dioxide
E. 1. DuPont de Nemours and
Company, Ino. Titanium Plant
TN

X

Process
wastewater
Titanium/Titani
um dioxide
E. 1. DuPont de Nemours and
Company, Inc. Titanium Plant
TN

X

Process
wastewater
Antimony
Anzon Incorporated
TX

X
Various raw and
in-process materials
Process
wastewater
Copper
ASARCO El Paso Plant
TX

X
Copper concentrate
Air pollution
residues, trsa
and untreated
wastewater
Copper
ASARCO El Paso Plant
TX

X

Contaminated
blasting msdi
Copper
ASARCO B Paso Plant
TX

X
Copper concentrate

Gam-quality
minerele
American Minerals, Ino.
TX
X

Product and gangus
fines

Talc
Dal-TileJDal-Minerals
TX
X


8ludgefromt
manufacturin

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Methodology for Developing Environmental Release Cases
In preparing these cases, EPA sought to collect information on environmental releases and
damages resulting from the extraction, beneficiation, and processing of ores and minerals occurring
since 1990. The Agency has previously collected environmental release information at mining and
mineral processing sites. The results of that evaluation have been placed in the RCRA docket
supporting prior rulemaking activities addressing mineral processing wastes. In identifying new data,
EPA conducted research, including file searches, across a wide range of mineral commodity sectors and
throughout the United States. Further, the Agency looked not only at releases resulting from waste
management, but also included in the scope of its investigation material processing, storage, and
handling operations (e.g., releases of mineral processing feedstocks, and from storage and handling of
characteristic by-products and sludges, and spent materials).
EPA conducted three steps to assemble this document:
1.	Identifying mining and mineral processing sites with potential releases and/or damages;
2.	Contacting selected Regional EPA and state agency representatives to identify specific
sites for review and to establish the existence of documentation of releases and/or
damages; and
3.	Conducting detailed searches of relevant inspection, enforcement, permitting, and other
files for mining and mineral processing facilities in selected states.
Each of these steps is discussed in more detail below. While EPA solicited assistance from Regional
staff to identify potential sites and state contacts, file searches were not conducted in all Regions.
Identifying Mining and Mineral Processing Sites
EPA relied on information used in the preparation of these documents to develop a preliminary list
of potential sites in Arizona, Florida, Maryland, Missouri, Nevada, New Jersey, New Mexico, Ohio,
Pennsylvania, Tennessee, and Texas. As a result, the Agency initially identified a large number of
potential mining and mineral processing sites within the specified states for review. These sites were
categorized by state and commodity sector to facilitate a focused identification of sites that would most
likely provide tangible, documented evidence of environmental releases. The results of this search do
not represent an exhaustive search of all releases from mines and mineral processing facilities in these
states. Rather, EPA used best efforts given the time and resources available. Further, in the states that
were examined a comprehensive examination of all information was not performed. In some cases only
selected state regional offices were contacted due to limited resources.
Contacting EPA Regional and State Representatives
Initially, EPA contacted Regional offices and state environmental protection agencies in eight states
to obtain information on potential mining and mineral processing sites with associated releases and/or
damages occurring since 1990. The states listed below were selected to ensure diversity in the mining
and mineral processing sectors examined as well as geographic breadth:
•	Arizona
•	Florida
•	Missouri
•	Nevada

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Page 16
		 — 		¦" " ¦"		"""¦¦¦ "¦ ——-tmcumoMt. —				
New Mexico
• Ohio
Pennsylvania
Texas

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Page 17

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	1
In each state, the Agency contacted a variety of representatives in different offices. Further, the
Agency contacted representatives in the EPA Regional offices in which the selected states were located.
The table below identifies the various agencies contacted initially as part of the scoping effort for this
research.
Ohio contacts did not provide sufficient information to develop damage case summaries. State
representatives indicated that the complaints documented in their files related more to water quantity
issues rather than the release of contaminants into the environment. Based on this information, EPA did
not conduct a file search in the State of Ohio. Subsequently, EPA determined that three additional states
should be contacted to ensure adequate representation of the industry. These additional states were
Maryland, New Jersey, and Tennessee.
StatefRegion
Agencies Contacted
Arizona
• Department of Environmental Quality
-	Remedial Project Section
-	Water Enforcement
-	Permitting/Surface Water
-	Hazardous Waste
-	Ground Water Permitting
-	Mine Permitting
-	Pollution Prevention Unit
-	Superfund
Florida
• Department of Environmental Protection
-	Phosphogypsum Management Program
-	Industrial Wastewater Division
-	Emergency Response Division
-	Air Quality Program
-	Hazardous Waste Division
-	Northeast District Office
-	Northwest District Office
Maryland
• Department of Environmental Protection
-	Waste Management Division
-	Water Management Division
-	Air Management Division
Missouri
• Division of Environmental Quality
- Director's Office
Nevada
• Division of Environmental Protection
-AirQuality Bureau
-	Mining Regulation and Reclamation Bureau
-	Corrective Actions Bureau
-	Solid Waste Bureau
New Jersey
• Department of Environmental Protection
-	Hazardous and Solid Waste Division
-	Legal Affairs Office
New Mexico
• Environment Department
-	Groundwater Protection and Remediation Bureau
-	Ground Water Section
-	Superfund Oversight Section
-	Surface Water Quality Bureau
-	Nonpoint Source Section
-	Point Source Regulation Section
-	Air Quality Bureau
Ohio
•	Department of Natural Resources
-	Division of Mines and Reclamation
•	Ohio Environmental Protection Agency
-	Solid and Infectious Waste Division
-	Emergency Remedial Response Enforcement, Technical Assistance
-	Emergency Remedial Response Division

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Pennsylvania
• Department of Environmental Protection
-	Pittsburgh Regional Office
-	Harrisburg Regional Office
-	Bureau of Land Recycling and Waste Management
Tennessee
• Department of Environment and Conservation
-	Solid and Hazardous Waste Management Division
-	Water Pollution Control Division
-	Surface Mining Division
Texas
• Texas Natural Resources Conservation Commission
-	Enforcement Division
-	Region 6 Compliance
-	Wastewater Program
-	Region 15 Compliance
EPA Region 3
•	Superfund Programs Branch
•	RCRA Programs Branch
EPA Region 4
•	Waste Management Division
•	Waste Programs Branch
•	South Superfund Remedial Branch
•	North Superfund Remedial Branch
EPA Region 5
•	Waste Management Division
•	RCRA Enforcement Branch
EPA Region 6
•	Superfund Division
•	Water Quality Protection Division
EPA Region 7
•	Air, RCRA and Toxics Divisioni
•	Superfund Division
•	Environmental Services Division
EPA Region 9
•	Air and Toxics Division
•	Hazardous Waste Management Division
Conducting Detailed File Searches
Based on the results of telephone contacts with state representatives, EPA conducted detailed
searches of state files in Arizona, Florida, Missouri, Nevada, New Mexico, Pennsylvania, Tennessee,
and Texas. File searches were conducted for all states from November 1996 to January 1997. A file
search was not conducted in New Jersey or Missouri.
For the States of Florida and Pennsylvania, environmental and human health information is
maintained within regional offices. Because of the small number of sites located within each region, EPA
selected only those regions with the most sites and the greatest potential for documentation of
environmental releases and/or damages. In all states in which file searches were conducted, relevant
documents were obtained indicating environmental releases and/or damages resulting from waste and
material management practices at mining and mineral processing facilities.
Further, EPA limited its search only to environmental releases that have occurred in these selected
states since 1990. The Agency chose this time cutoff because it represents a reasonable reflection of
modem practices and is indicative of normal operating procedures under modem regualtory scrutiny.
Indeed, while many mining and mineral processing practices have not changed significantly since
inception, the subjection of many of these waste to Subtitle C regulations has been relatively recent
given the promulgation of the 1988-91 Bevill rules.
The degree to which the results of EPA's file searches provide a complete assessment of
environmental releases and damages resulting from mining and mineral processing sites is limited by
several factors:
Results of inspections, sampling events, responses to complaints, and environmental
studies for releases occurring in the recent past may not be reflected in state files, due to

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Page 20;
the significant time necessary to update and maintain complete files.
EPA was directed, in most cases, to state file rooms to search files. In past experience
conducting such reviews, active files are often not contained in file rooms, but are rather
held by the responsible staff person. Further, active files may be held as enforcement
confidential and not available for review outside the regulatory agency.
Although EPA did attempt to identify individuals who may have relevant files in their
possession, it is probable that files on some releases from mining and mineral
processing sites were not available for review by EPA during the file searches. In
particular, the Director of the Texas Natural Resource Conservation Commission's
(TNRCC) Enforcement Division declined to provide information or other support to
develop damage cases beyond allowing research of the central files that are available to
the general public. In addition, the director declined to allow TNRCC enforcement staff
to be contacted for questions on behalf of EPA.
Prior to 1990, many facilities and specific waste streams associated with mining and
mineral processing operations were not subject to the rigorous controls of RCRA Subtitle
C. Although some are now explicitly regulated under Subtitle C, there may be
remaining uncertainty as to the statutory and regulatory authority of state agencies over
these facilities and wastes. Even where the state's authority is clear, the relatively
recent (post-1990) changes in the RCRA status of mineral industry wastes may have, in
the short term, oustripped the ability of some state agencies to effectively regulate them.
As a result, some facilities may not, as yet, have been fully subjected to the
requirements of RCRA Subtitle C (e.g., permitting, monitoring, and
recordkeeping/reporting).
While some releases are documented as having been identified during inspections by
state agencies, a number of these incidents were described as having been reported to
the regulatory agency by the facility owner or operator.
For many of the releases described in this report, the fact that a waste or material was
released does not necessarily mean that there was significant damage to human health
or the environment. Nor does it make an assessment or determination as to the
adequacy of the response on behalf on the respective regulatory agencies.

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ASARCO Silver Bell Mine:
"Waste and Process Water Discharges Contaminate
Three Washes and Ground Water"
Wasto and Material Management Practices: The Silver Bell Mine occupied 20,000 acres in 1993, including an
abandoned mine site known as the BS&K mine, which was an underground lead-zinc mine that operated
for most of the 1950s. Open pit mining operations at Silver Bell stopped in 1982, but were resumed two
years later, only to stop again in 1994. Active open pit mining, milling, and leaching operations were
scheduled to resume in 1995, pending finalization of all required permits. No information existed in the
available files concerning whether open pit activities have actually resumed. Leaching operations at
Silver Bell have been continuous since 1960. The files available for review covered the mine's activities
through 1993. At that time, the mine had neither an NPDES permit nor an Arizona Aquifer Protection
Permit (APP). No information was available concerning the issuance of either of these permits to the
Silver Bell Mine.
The topography and drainage of the mine site, which is situated to the west and south of the Silver
Bell Mountains, is complex. The mine is segregated into four primary areas, including the El Tiro and
Oxide open pits, the leach dumps and overburden piles, the abandoned mill site, and the tailings
impoundments. The El Tiro Pit, the BS&K abandoned mine, and the leach dumps are located near the
headwaters of three ephemeral washes, the El Tiro, Mammoth, and Silver Bell. The Oxide Pit drains to
several unnamed washes and to the Cocio Wash, which also drains the mill site and the tailings
impoundments. Both open pits intersect an aquifer located within the Silver Bell Mountains, which is
100 to 150 feet below ground. ASARCO uses the water that collects in the pits as make-up water for the
leaching operations.
During site inspections of the mine conducted in January and March 1993, the Arizona Department
of Environmental Quality (ADEQ) observed water flowing in three unnamed washes below Silver Bell
Mine. One stream flowed into Mammoth Wash, while the other two flowed into El Tiro Wash. The water
in two of the streams was found to flow directly under one of the waste rock dumps, while the third
stream originated at the base of an active leach dump near the El Tiro Pit.
Type of Impact/Madia Affected: During the site inspection, ADEQ documented with a series of photographs
the water flowing in these washes immediately downstream of ASARCO's facilities. The photographs
and diagrams show where the samples were collected in March. ASARCO also collected samples at the
same and other points, but the Tiles contained no documentation of the sample results.
Samples taken from the two streams flowing under the waste rock dump showed violations of
standards for total selenium, with one stream also violating standards for dissolved copper. The water in
one of these streams was intermittently flowing in the subsurface in parts of the stream bed and
resurfacing in other parts.
The third stream, which flows from the leach dump, showed a broader range of exceedances. In
addition, concentrations of dissolved copper in this stream were several orders of magnitude greater than
the concentrations in the other streams. Analyses showed violations of standards for four parameters,
including pH, total zinc, total cadmium, and dissolved copper. The exceedances of surface water quality
standards documented in the stream flowing to El Tiro Wash, which began flowing 420 feet below the
PLS pond, are listed below. The applicable standard for dissolved copper in this stream is 0.69 mg/l,
which was established by Arizona to protect aquatic life and wildlife based on an ephemeral stream with
a hardness of 3,500 mg/l.

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Cadmium, total 1.4mg/l
Copper, dissolved120.0 mg/l
pH (minimum) 3.41
Zinc, total 78.0 mg.l	
Regulatory Action/Response: On May 17,1993, U.S. EPA Region 9 NPDES Compliance Section sent a letter
to ASARCO in Tucson notifying them of "observed evidence of past unauthorized discharges of process
water from the Silver Bell Mine." In an attached inspection report, EPA made several recommendations.
These included that ASARCO take measures to immediately cease all surface and subsurface
discharges to the three ephemeral streams, and that ASARCO should conduct a survey of the entire
mine to identify all other potential sources of unauthorized discharges and take measures to cease or
prevent those discharges. EPA asked ASARCO to respond to these recommendations within three
weeks. There was no follow-up information in the files concerning any response from ASARCO or any
further developments.
The principal permit required by Arizona for new facilities, such as ASARCO's planned third open
pit, is an Aquifer Protection Permit (APP). This permit program was designed by Arizona in part to
identify and remediate environmental concerns that could adversely affect ground water in the vicinity of
mines, such as those at the Silver Bell Mine. The types of violations and the concerns described above
could be dealt with as part of an APP application by Silver Bell and ADEQ's review of that application.
Part of the APP permitting process involves State permit writers working with facility owners/operators to
correct historical degradation of ground water quality. Periodic site inspections including compliance
monitoring occur at permitted facilities to ensure that each facility is maintained and operated to restore
and maintain ground water quality. As of June 1993, ASARCO had reportedly begun the process of
obtaining from ADEQ an APP for its proposed North Silver Bell Pit, the new open pit and its associated
dump sites. In November 1996, at the time State files were reviewed, there was no information present
in the files concerning the status of the permit or Silver Bell's APP application.
References:
Arizona Department of Environmental Quality. Draft Internal Memorandum from Hyde, P. March 10,1993.
U.S. Environmental Protection Agency. Latter from Greenberg,K. to Malay, P. J* ASARCO Inc. May 17,1993.
U.S. Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. August 19,1992.
U.S. Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. March 19,1993.

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Cyprus Bagdad Mine:
"Acidic, Copper-Bearing Solution Seeps to Boulder Creek"
Waste and Material Management Practices: Cyprus Bagdad Copper Corporation (Cyprus) operates a large
open pit copper mine approximately 40 miles west of Prescott, Arizona. In 1995, the mine produced 208
million pounds of copper and 10 million pounds of molybdenum. The mine crushes high grade ore and
uses a froth flotation process to concentrate copper and molybdenum values. The concentration process
results in large quantities of water-laden tailings which Cyprus discards into tailings ponds. Cyprus
leaches the lower grade ores with a sulfuric acid mixture. The leachate is collected in basins. The
facility uses solvent extraction and electrowinning to extract copper from the pregnant leachate solution.
Cyprus channels the process water to holding facilities for reuse.
Cyprus has several NPDES permits for discharging into three streams that are tributaries to the Big
Sandy River. The most important of these discharges goes into Boulder Creek or its tributaries,
including Copper Creek. Outfall 001 is a spillway located at the top of the dam that holds the Copper
Creek Flood Control Basin. It is the sole point from which Cyprus is authorized to discharge from its
Copper Creek Leaching System into Copper Creek. Discharges from Outfall 001 are authorized only
when there has been a storm event in which a 3-inch rainfall in the vicinity of the Copper Creek
watershed has occurred during a 24-hour period. In May 1991, seepage of pregnant leach solution from
the Copper Creek Leaching System was discovered in a receiving pool in Boulder Creek.
Type of Impact/Media Affected: Studies indicated that instead of being contained by the Copper Creek Flood
Basin, the heavily contaminated solution seeped under the dam. The concentration of total copper in
samples collected in the pool in Boulder Creek were as high as 76.4 mg/l. Out of 18 samples collected
from the pool during the month that the seepage was discovered, every sample exceeded background
levels by more than 0.5 mg/l of total copper, the State's Agricultural Livestock Watering Standard for
total recoverable copper. No information was available in the files reviewed that clearly documented the
source of the infiltration; however, several documents referred to "repairs" to various HDPE liners. It was
not clear from information in the files precisely which units were lined, when they were lined, or the
capacity or dimensions of the units.
Regulatory ActionJResponse: On March 29,1993, U.S. EPA issued a Finding of Violation and Order against
Cyprus. That order was not present in the State files made available for review, but it was referred to by
other documents in the files. On September 13,1996, in the U.S. District Court for the District of
Arizona, the U.S. Department of Justice (DOJ) brought civil action against Cyprus for discharging
contaminated water in violation of the Clean Water Act (CWA) and Arizona law. The civil action cited
discharges from tailings ponds, pipelines, leach dumps, other facilities, and a sewage treatment plant.
The largest discharges cited, however, came from the mine's Copper Creek Leaching Basin. In a
Consent Decree, Cyprus agreed to pay a civil penalty totaling $760,000. Of that amount, $475,000 was
to be paid to U.S. EPA and $285,000 was to be paid to the Arizona Department of Environmental Quality
(ADEQ). ADEQ received $285,000 from Cyprus on September 25,1996. As of November 1996, ADEQ
had ended all enforcement activities against Cyprus. Although there were no other terms specified in the
Consent Decree, there may have been additional terms or recommendations included in the Notice of
Violation and Order. Several remedial actions, which are summarized below, along with the resultant
change in ground water quality were undertaken by Cyprus following the discovery of the seep.
Based on the relatively small amount of follow-up information available in State files, the facility
had generally achieved compliance by January 1991. That informal determination was made by ADEQ
personnel based on a comprehensive water quality monitoring program to determine the net contribution
of copper to Boulder Creek from the Copper Creek Leach Basin. During a water quality sampling period
that extended from shortly after the seepage was discovered in May 1991 through September 1993,
concentrations of copper above background levels dropped dramatically. In May of 1991, Cyprus
repaired the HDPE liner in the PLS channel. The following September, the mine repaired the soil liners

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in the Copper Creek Leach Basin. Cyprus also completed construction of a cutoff wall in Copper Creek
in November 1992.
Of 143 samples of water collected from January 1992 until October 1993, all of which were
collected from sumps installed in the alluvial gravels of Boulder Creek downgradient from the facility, not
one sample showed any elevation above background concentrations of copper. The cutoff wall was
credited with reducing total copper concentrations in shallow ground water 400 feet downgradient of the
wall from 7.2 mg/l before the wall was constructed to 0.8 mg/l afterwards. ADEQ personnel concluded in
an internal 1995 memorandum that the overall effectiveness of the remedial measures undertaken by
Cyprus was amply demonstrated by the consistently low concentrations of copper measured in sumps
downgradient of the wall and the consistently within-standard copper values achieved in the receiving
pool. At the time of the file review in November 1996, the available water quality enforcement files did
not contain any more information regarding how Cyprus is managing its PLS pond and other structures.
References:
Arizona Department of Environmental Quality. Internal Memorandum from Black. J. to File. November 5,1996.
Arizona Department of Environmental Quality. Interoffice Memorandum from Hyde, P. to R. Best, Re: Effectiveness of the
Cyprus Bagdad Cutoff Wall in Copper Creek. January 23, 1995.
Arizona Republic, "Cyprus to pay big penalty." September 17,1996.
U.S. Department of Justice. Civil Action in the U.S. District Court for the District of Arizona, USA and State of Arizona versus
Cyprus Bagdad Mining Corporation. September 11,1996.
U.S. Environmental Protection Agency Region 9. Environmental News [Newsletter]. September 16,1996.
U.S. Environmental Protection Agency. Findings of Violation and Order. March 29,1993 (not in files reviewed).

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Cyprus Twin Buttes Mine:
"Tank Leaks Acidic Metal Solution Resulting
in Possible Soil and Ground Water Contamination"
Wasto and Material Management Practices: Although the majority of past operations at the Cyprus Twin Buttes
Mine in Pima County have been discontinued, Cyprus still operates an electrowinning (EW) facility that is
used in the production of copper from ore mined at the Cyprus Sierrita Mine. Cyprus also operates a
thickener associated with the EW plant, acid tanks, several septic systems, two reservoirs for temporary
storage of pumped ground water, storm water run-off catchments, and a heavy equipment shop. The
dates on which the EW plant or other facilities began operation were not specified in the available files.
Operation of the mine's solvent extraction plant were discontinued in 1993. During the previous year, the
tailings processing and agitated vat leaching were discontinued. On March 28,1995, Arizona
Department of Environmental Quality (ADEQ) staff conducted a site inspection of the Cyprus Twin
Buttes Mine operations in Pima County. This inspection showed that the EW plant operations were likely
to be adversely affecting ground water quality.
Type of Impact/Media Affected: During the site inspection, ADEQ documented with photographs the severely
corroded concrete floor in the basement of the EW tank house that provided secondary containment for
the tank house. On a subsequent visit in January 1996, the corroded concrete remained unchanged and
unlined. Leakage from the tanks above the floor had caused fluid to pool extensively on the floor. This
situation also was documented with a series of detailed photographs showing the state of the corroded
concrete floor and the liquid from the tanks above the unlined floor that was pooling on the floor. Based
on the condition of the floor, ADEQ concluded that there was no way to prevent the pooling fluid from
infiltrating the underlying soil and ground water because the crumbling and corroded concrete floor was
not capable of providing an effective barrier between the soil and the pooling fluid.
Following meetings with ADEQ staff, in June 1995, Cyprus proposed to document that past releases
from the EW plant have not contributed to or caused an exceedance of aquifer water quality standards.
Further status reports or findings were not present in the files available in ADEQ offices. Based on
informal conversations with the ADEQ site inspector, the facility has not yet reported the results of any
ground water monitoring.
Regoletory Action/Response: ADEQ staff met with Cyprus staff following the site inspections. Cyprus
subsequently installed an HDPE liner on the floor of the EW tank house in order to provide secondary
containment for any of the highly corrosive and metal-containing solutions that leak to the floor of the
tank house. The presence of this new liner was documented with photographs. No additional
information was found in the files regarding further ADEQ or Cyprus responses to this situation.
References:
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and photographs.
April 28,1995.
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and photographs.
January 8,1996.
Cyprus Sierrita Corporation. Letter from Com, KEnvironmental Affairs Supervisor to Olsen, 6, ADEQ/APP Project Officer.
March 28,1996.
Olsen, Greg, ADEQ/APP Mining Unit Project Officer. Personal Communication, November 18,1996.

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Magma Copper Mine:
"Broken Pipeline Seam Causes Discharge to Pinal Creek"
Waste and Material Management Practices: The BHP Copper Mine is an 8,000-acre open pit copper mine
located eight miles west of Miami, Arizona. The mine is part of Arizona's Globe-Miami mining district
which has been mined for copper, silver, and gold since 1874. The mine is located in a mountainous
area between two creeks, Pinto Creek and Pinal Creek. BHP Copper recently purchased the mine from
Magma Copper Co. (Magma). Because the environmental release described in this summary occurred
during Magma's ownership of the mine, this summary focuses on Magma's operations.
Magma mined low-grade copper and molybdenum ore at a combined rate of approximately 87,600
to 160,000 tons per day. Both millable and leach-grade ore were mined, with the millable ore crushed
and concentrated in on-site facilities. Copper and molybdenum concentrates were shipped to off-site
facilities at Magma's San Manuel facility, located 40 miles northeast of Tucson, for smelting and refining.
Magma deposited low-grade ore in the dump leaching area referred to as Gold Gulch. Raffinate
solutions consisting of weak sulfuric acid were sprayed over the low-grade ore. Magma collected the
pregnant leach solution (PLS) in a double-lined facility with leak detection. The solution was pumped to
the SX/EW plant where it was processed using an organic solvent and electrowinning process. Magma
shipped the resulting .cathode copper off-site for further refining. During an inspection conducted on
March 24,1994, U.S. EPA Region 9 personnel noticed water flowing towards Pinal Creek in Tinhorn
Wash at a rate of about 100 gallons per minute. There were no authorized discharge points upstream of
the area where the discharge was observed.
Type of Impact/Media AffecteA The purpose of the EPA site inspection was to monitor compliance with a
NPDES permit (AZ0020419) and a Finding of Violation and Order issued in January 1992. During the
inspection, the effluent was determined to be coming from a broken seal in a pipeline carrying
non-process water from the Burch Pump Station. Magma indicated that the pipeline had not been used
for approximately three months prior to the discharge. On the day of the discharge, the pipeline was
being used in connection with the testing of a new well pump. The pipeline's failure resulted in the loss
of about 108,000 gallons of water over a period of 83 minutes to a tributary of Pinal Creek. Chemical
analyses of the water showed arsenic, chromium, copper, mercury, lead, and zinc. The copper
concentration was 1.02 mg/l, almost seven times higher than the Arizona Surface Water Quality
Standard of 0.150 mg/l.
Regulatory Action/Response: In April 1994, U.S. EPA sent a compliance monitoring inspection report to
Magma's Pinto Valley Division which contained several recommendations. EPA recommended
inspection of the pipeline, replacement of defective portions, and installation of automatic shutdown
controls to minimize any future discharges. EPA also requested that Magma respond to the
recommendations. Magma had previously indicated in writing that the pipeline would be thoroughly
inspected before the next maintenance check or use. No additional information was present in the files.
References:
Arizona Department of Environmental Quality. Latter from Browne, K± todawson, /?„ U.S. Environmental Protection
Agency Region 9 andR. Fray. Magma Copper. November 2,1994.
Notice of Preliminary Decision to issue an Individual Aquifer Protection Permit. ADEQ. June 17,1996.
U.S. Environmental Protection Agency. Letter from Greenberg, K. to Browne, K1„ Magma Copper. April 25,1994.
U.S. Environmental Protection Agency Region 9. NPDES Compliance Monitoring Report. April 19,1994.

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Page 27 j
Magma Copper Mine:
"Multiple Discharges of Polluted Effluents Released
to Pinto Creek and Its Tributaries"
Wasta and Material Management Practices: BHP Copper purchased this facility from Magma Copper Company
(Magma). Magma mined low-grade copper and molybdenum ore at this facility at a combined rate of
87,600 to 160,000 tons per day. Both millable and leach-grade ore was mined. Millable ore was crushed
and concentrated in on-site facilities. Copper and molybdenum concentrates were shipped to off-site
facilities for smelting and refining. Low-grade ore was deposited in the dump leaching area referred to as
Gold Gulch. Raffinate solutions consisting of weak sulfuric acid were sprayed over the low-grade ore.
Magma collected the pregnant leach solution (PLS) in a double-lined facility with leak detection. The
solution was pumped to the SX/EW plant where it was processed using an organic solvent and an
electrowinning process. The facility shipped the resulting cathode copper off-site for further refining.
Gold Gulch Dam No. 2, located in Gold Gulch, a tributary of Pinto Creek, is a clay core/rock fill dam
that impounds surface precipitation and process solutions that overflow from Gold Gulch Dam No. 1,
which is approximately one mile upstream of Gold Gulch Dam No. 2. The dam is 410 feet long and has
a seepage collection caisson equipped with pumps located at its toe. The seepage is pumped from the
caisson to the impoundment behind Gold Gulch Dam. No. 2. Water contained there is pumped to the
mill for use in process operations. There was no mention in the available files concerning the presence
of a liner to reduce infiltration to ground water. Based on EPA's review of discharge monitoring reports
between January 1990 and September 1991, Magma reportedly discharged effluent to Pinto Creek or its
tributaries in excess of allowable effluent limitations on numerous occasions, and/or did not collect and
analyze samples, in violation of permit conditions.
Type of Impact/Media Affected: EPA found that these types of violations occurred at least once in each of at
least nine months during this period, including releases in August and December 1990, and in January,
February, March, May, July, August, and September 1991. Each of these discharges is likely to have
transported contaminants to Pinto Creek or its tributaries.
In August and September 1991, a ditch in the vicinity of a tailings pond, the Miller Springs ditch,
became plugged, causing the ditch to overflow several times. Each of the discharges entered Pinto
Creek. During the first episode, a total of approximately 3,000 gallons of effluent containing total
suspended solids and copper of unknown concentrations was discharged from the ditch. A similar
discharge of 24,000 gallons occurred on September 5,1991. An estimated 39,000 gallons of effluent in
exceedance of Arizona Surface Water Quality Standards and Aquifer Water Quality Standards for
copper, zinc, and lead were discharged from the ditch on September 23,1991.
EPA also conducted a site inspection on January 16,1991, during which an EPA inspector
observed several unauthorized discharges of effluent in various areas of the facility. One discharge
surfaced in the Gold Gulch alluvium about 50 yards below the Gold Gulch No. 2 Dam, flowing towards
Pinto Creek. The effluent surfaced from the mine's Gold Gulch No. 2 reservoir, which contained water
and copper dump leach solution that overflowed from the Gold Gulch No. 1 Dam. Ground water samples
in 1988 from nearby wells showed concentrations of fluoride and mercury in exceedance of State water
quality standards. In addition, water collected from the caisson sump at the Gold Gulch No. 2 Dam in
1992 showed a dissolved copper concentration of 0.175 mg/l, as compared to the Arizona Surface Water
Quality Standard of 0.150 mg/l. Dissolved copper concentrations from a 1992 sample collected in the
impoundment behind the dam at Gold Gulch No. 2 were 3.7 mg/l.
The EPA inspector also observed two other discharges. Concentrations of copper in both samples
exceeded Arizona Surface Water Quality Standards and Aquifer Water Quality Standards. One
discharge was an effluent surfacing below the toe of Tailings Dam No. 3 and flowing towards Pinto
Creek. Magma collected a sample of that seepage. The sample contained 0.42 mg/l of total copper.

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Another discharge observed was a mixture of storm water run-off and industrial water that surfaced
below the Miller Springs Catchment Dam and flowed towards Pinto Creek. A sample of that discharge
solution was found to contain 0.0023 mg/l of total copper.
The EPA inspector also observed evidence of a recent discharge from a permitted discharge point
in the form of damp soil and water near a discharge pipe at the base of a contingency pond located
below Tailings Dam No. 2. Magma had not monitored the discharge on the first day as required by
permit conditions. Magma also failed to monitor intermittent discharges on at least two other days in
January from another discharge point.
Regulatory ActionfResponm: On November 27,1991, U.S. EPA Region 9 issued a Findings of Violation and
Order based on authority granted under the Clean Water Act (CWA). In the Order, EPA directed Magma
to complete the following actions:
•	Comply with all NPDES permit conditions;
•	cease all unauthorized discharges of pollutants into Pinto Creek immediately;
Submit, by January 29,1992, a preliminary engineering plan outlining steps and a schedule for
modifications necessary to ensure consistent compliance with effluent limits and prevent
unauthorized discharges;
Begin construction of any needed modifications by March 1,1992;
Complete all needed modifications by July 15,1992;
Submit quarterly reports summarizing progress;
Monitor and limit all discharges so as not to cause violations of Arizona Water Quality Standards;
Report any noncompliance with this Order; and
Submit, by February 15,1992, a detailed report including a compilation of all water quality and
sediment data collected by Magma on Pinto Creek and its tributaries since March 15,1987, a
comparison of the results to applicable water quality standards, and descriptions of any observed
fish kills and degradation of the flora and fauna of Pinto Creek since March 15,1987.
Although the Order explicitly did not preclude further administrative, civil, or criminal action to seek
penalties, fines, or other appropriate relief under the CWA, there was no follow-up information in the files
as to whether any additional action had been taken or whether all conditions stipulated in the Order had
been met by Magma. Magma did commission a hydrogeologic investigation in the vicinity of the
unauthorized discharge downstream of Gold Gulch Dam No. 2. The investigator was unable to find the
seep observed during the site visit on January 16,1991, or to sample the water quality of that seep, or
determine its source. Another seep approximately one-quarter mile downstream was observed during
the hydrogeologic investigation. Magma's analysis of the water quality of the downstream seep failed to
show any exceedances of water quality standards. Magma's hydrogeological consultants recommended
relocating the NPDES discharge point, modifying the permit for continual discharge, and setting effluent
standards for the discharge. No information was available in the files concerning any changes in permit
conditions.
References:
Arizona Department of Environmental Quality. Notice of Preliminary Decision to Issue an Individual Aquifer Protection
Permit. June 17,1996.
Hargis and Associates, Inc. Hydrogeologic Investigation, Gold Gulch Dam No. 2. April 15,1992.

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. .V—.V. . .				 			 -WW"-.-.-						 	 				¦ 	 			 						"¦ .W. .w. .^w^ . . ^. r. . . .,r. . . .
U.S. Environmental Protection Agency. Findings of Violation and Order. November 27,1991.
Page 29

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Magma Copper Mine:
"Multiple Overflows Result in Major Fish Kill in Pinto Creek"
Waste and Material Management Practices: BHP Copper now operates this 8,000-acre open pit copper mine,
which is eight miles west of Miami, Arizona. The mine site is located in a mountainous area between two
creeks, Pinto Creek and Pinal Creek. Pinto Creek, which receives discharges from the mine, is one of
Arizona's few perennial streams and is one of the State's major recreational areas. The creek flows into
Roosevelt Lake, which supplies drinking water for the Phoenix area.
BHP Copper recently purchased the mine from Magma Copper Company (Magma). The mine is
part of Arizona's Globe-Miami mining district, which has been mined for copper, silver, and gold since
1874. Because the environmental releases described in this summary occurred during Magma's
ownership of the mine, this summary focuses on Magma's operations. In the almost four years since the
releases occurred, significant engineering and operational changes have been put in place at the mine to
help ensure that no repeat incidents of the magnitude of the 1993 releases occur.
Magma mined low-grade copper and molybdenum ore at the mine at a combined rate of
approximately 87,600 to 160,000 tons per day. Both millable and leach-grade ore were mined, with the
millable ore crushed and concentrated in on-site facilities. Copper and molybdenum concentrates were
shipped to off-site facilities at Magma's San Manuel facility, located 40 miles northeast of Tucson, for
smelting and refining. Magma deposited low-grade ore in the dump leaching area referred to as Gold
Gulch. Raffinate solutions consisting of weak sulfuric acid were sprayed over the low-grade ore. Magma
collected the pregnant leach solution (PLS) in a double-lined facility with leak detection. The solution
was pumped to the SX/EW plant where it was processed using an organic solvent and electrowinning
process. Magma shipped the resulting cathode copper off-site for further refining.
During January 1993, exceptionally heavy rainfall combined with precipitation in December 1992
that was 250 percent above the monthly norm overwhelmed the mine's water management capabilities.
The area received over 19 inches of rainfall in December and January, or nearly 90 percent of its annual
rainfall over a seven week period. During the rainfall event, a reservoir overflowed the tailings pile, tore
out a levee, and carried tailings to Pinto Creek. In addition, a retention pond that held storm water and
mineral wastes from the mine's acidic leaching process discharged material into the creek after its dam
was breached.
Type of Impact/Media Affected: Critical water containment structures in place at the mine in 1992 were
reportedly designed to hold a 100-year, 24-hour storm event. Nonetheless, the mine discharged
hundreds of tons of tailings and millions of gallons of contaminated water into Pinto Creek. In spite of
the dilution that occurred following mixing with the water in the creek, water quality sampling by Magma
during January and February 1993 indicated 286 exceedances of daily and monthly water quality
parameters. The total number of exceedances reported by Magma are summarized below for 10
parameters:
Cadmium, dissolved 15
Cadmium, total 4
Copper, dissolved 50
Copper, total 71
Lead, total 22
Mercury, total 21
pH (minimum) 21
Total suspended solids 21
Zinc, dissolved 39
Zinc, total 22	

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lUlUiUUlUIWlXBtM
Page 31
Fish surveys collected before and after the discharges showed a marked decline in populations of the
desert sucker (Pantosteus clarki) following the discharges. Though abundant in 1992, a summer survey in
1993 found only one adult in Pinto Creek. Several months later, a small number of young were found.
Regulatory Action/Response: Immediately following the spill, Magma voluntarily undertook widespread
cleanup efforts. The breach in the levee was filled with hundreds of tons of rock and dirt. Water used in
the mining process is no longer stored on top of the tailings levee that breached. A series of catchment
areas were constructed below the leach-water pond that overflowed. Magma reportedly may spend up to
$15 million in cleanup costs and facility upgrades following the spill.
On November 8,1994, the U.S. Department of Justice (DOJ) issued a Consent Decree signed by
DO J, the State of Arizona, and Magma Copper Co. The decree was negotiated during a series of
meetings that occurred in 1993 and 1994. The decree contained a number of penalties, tasks, and
reporting requirements. Magma agreed to pay $5,000 to the U.S. Forest Service (USFS) for a fisheries
study in Pinto Creek and/or reintroduction of native fish, $20,000 to the Amett Creek Native Fish
Reestablishment Project, and $25,000 to construct a fence along Pinto Creek to restrict livestock
movement into the Creek. Magma also agreed to pay a $625,000 civil penalty, with $385,000 going to
the U.S. and $240,000 going to the State of Arizona. Magma agreed, by December 31,1998, to collect,
contain, and store water for process use, and to minimize discharges of pollutants by ensuring that any
discharges are from approved outfalls and are in compliance with the NPDES permit. Magma also
agreed to submit three plans for the Pinto Valley Operations; a Compliance Plan; an Engineering Plan;
and a Best Management Practices (BMP) Plan. The former would include, at a minimum, compliance
measures for the Gold Gulch area, the Miller Springs area, and the No. 3 Tailings Impoundment area of
the Pinto Valley Mine. Magma also voluntarily agreed to perform a Supplemental Environmental Project
(SEP) for its Old Dominion inactive mine site. The goal of the SEP is to mitigate the contribution of
contaminants from that inactive mine into the Pinal Creek drainage.
References:
Arizona Department of Environmental Quality. Interoffice Memorandum from Swanson,E. toMunson,B. February
24,1993.
Arizona Department of Environmental Quality. Notice of Preliminary Decision to Issue an Individual Aquifer Protection
Permit. June 17,1996.
Arizona Game and Fish Department. Letter from Riley, L. to Clawson, Rv U.S. Environmental Protection Agency Region 9.
September 23,1993.
Golfen, B. "Magma doing monumental, expensive cleanup of Pinto Creek." The Arizona Republic. February
7,1993.
Magma Copper. Letter from Browne, Kl. to Clawson, /?, U.S. Environmental Protection Agency Region 9. April 8, 1993.
Magma Copper. Letter from Browne, Kl. to Clawson, R, U.S. Environmental Protection Agency Region 9endR. Frey, ADEQ.
November 2,1994.
Magma Copper Co. Pinto Valley Operations. Report No. 4 NPDES Upset Condition Starting January 8,1993. April
1993.

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fcV 7 '.'.V.V.V.V.'.V.V.V.V,
Page 32!
tWyWMghV'iM^n'vf'
U.S. Department of Justice. Consent Decree among the United States, the State of Athene, and Magma Copper Co.
November8,1994.

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Magma Copper Mine:
"Repeated Release of Tailings to Pinto Creek"
Waste and Material Management Practices: The BHP Copper Mine is an 8,000-acre open pit mine
approximately 60 miles east of Phoenix in Arizona's Globe-Miami mining district. Mining for copper,
silver, and gold has occurred in the district since 1874. This mine is located in a mountainous area
between two creeks, Pinto Creek and Pinal Creek.
BHP Copper Co. recently purchased the mine from Magma Copper Company (Magma). Because
the environmental releases described in this summaiy occurred during 1991 while Magma owned the
mine, this summary focuses on Magma's operations.
Magma mined molybdenum ore and both millable and leach-grade copper ore at this facility.
Millable ore was crushed and concentrated in on-site facilities. Copper and molybdenum concentrates
were shipped to off-site facilities for smelting and refining. Low-grade ore was deposited in the dump
leaching area referred to as Gold Gulch. Raffinate solutions consisting of weak sulfuric acid were
sprayed over the low-grade ore. Magma collected the pregnant leach solution (PLS) in a double-lined
facility with leak detection. The solution was pumped to the SX/EW plant where it was processed using
an organic solvent and an electrowinning process. The facility shipped the resulting cathode copper
off-site for further refining. On several occasions in 1991, the mine released various quantities of tailings
to the stream beds near the mine.
On January 4,1991, the face of Tailings Dam No. 3 failed, allowing 150 to 250 tons of tailings to
enter Pinto Creek. The tailings discharge was accompanied by approximately two million gallons of
water which were released over a period of 16 hours.
Type of Impact/Media Affected: The tailings releases contaminated receiving surface waters with at least five
heavy metals in exceedance of Arizona's surface and ground water quality standards. Both shoreline
and bottom deposits of tailings were observed in the creek. The following analytical results were
reported for seven parameters from a sample collected at the time of the release:
Cadmium 0.036 mg/l
Copper, total 35.1 mg/l
pH 3.6 SU
Lead, total 1.52 mg/l
Mercury, total 0.0017 mg/l
Zinc, dissolved 5.78 mg/l

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>¦ .w. —		 —		—- -
Page 34
Beginning on March 1,1991, another large quantity of tailings was released from the same pile.
This release occurred from an over-saturation of the tailings face benches due to heavy precipitation. An
estimated 3.4 million gallons of water also were discharged. Based on a sample collected on March 1,
values for three parameters exceeded Arizona Surface Water Quality Standards and Aquifer Water
Quality Standards, as indicated below:
Copper, total 10.8 mg/l
pH 5.7 SU
Lead, totalO.296 mg/l
The following analytical results, which also exceeded standards, were reported for seven
parameters from a sample collected on March 2:
Cadmium 0.025 mg/l
Copper, dissolved 9.13 mg/l
Copper, total 9.13 mg/l
pH 5.9 SU
Lead, totalO.2140 mg/l
Mercury, total0.0018 mg/l
Zinc, dissolved 3.58 mg/l
Regulatory Action/Response: On November 27,1991, U.S. EPA Region 9 issued a Findings of Violation and
Order based on authority granted under the Clean Water Act (CWA). In the Order, EPA directed Magma
to undertake the following actions:
Cease all unauthorized discharges of pollutants into Pinto Creek immediately;
Submit, by January 29,1992, a preliminary engineering plan outlining steps and a
schedule for modifications necessary to prevent unauthorized discharges;
Begin construction of any needed modifications by March 1,1992;
Complete all needed modifications by July 15,1992;
Submit quarterly reports summarizing the progress;
Report any noncompliance with this Order; and
Submit, by February 15,1992, a detailed report including a compilation of all water
quality and sediment data collected by Magma on Pinto Creek and its tributaries since
March 15,1987, a comparison of the results to applicable water quality standards, and
descriptions of any observed fish kills and degradation of the flora and fauna of Pinto
Creek since March 15,1987.
Although the Order explicitly did not preclude further administrative, civil, or criminal action to seek
penalties, fines, or other appropriate relief under the CWA, there was no follow-up information in the files
as to whether any additional action had been taken or whether all conditions stipulated in the Order had
been met by Magma. The files did contain at least one report of an EPA site inspection conducted to
monitor compliance with the Finding of Violation and Order issued in January 1992. This report noted

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"	.--..W- — ¦^¦¦¦¦-¦¦¦-^.S^-^-.S^.W-..W-.W-.W- ...... ¦- — ¦¦¦¦¦					" —				.....			. .
Page 35
that Magma had been in compliance with its NPDES permit and the Finding of Violation and Order.
However, during an inspection on March 16,1993, an unauthorized discharge from a broken seam in a
pipeline was noted. (Information on this discharge is contained in Magma Copper Mine: "Broken
Pipeline Seam Causes Discharge to Pinal Creek.")
References:
Arizona Department of Environmental Quality. Notice of Preliminary Decision to Issue an Individual Aquifer Protection
Permit. June 17,1996.
Arizona Department of Environmental Quality, Office of Water Quality. Internal Memorandum. July 30,1992.
U.S. Environmental Protection Agency. Findings of Violation and Order. January 24,1992.

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Arizona
Phelps Dodge Morenci Mine:
"Contaminated Storm Water Seeps to Ground Water
and Surface Water"
Waste and Material Management Practices: Previous ore extraction activities at the Morenci Mine have
produced several inactive waste rock dumps that consist of what is referred to by Phelps Dodge Morenci
Inc.(PDMI) as development rock. The rock dump, known as the Producer Pile, is located in Gold Gulch,
an intermittent stream bed. The pile has been at its current location since 1986. The pile roughly bisects
the watershed of the gulch, with approximately 40 percent of the watershed's total run-off falling below
the pile and the remainder of the run-off coming from or flowing through the pile. PDMI has constructed
berms near the crest of the pile to contain potential run-off.
In order to contain all run-off from a 100-year, 24-hour storm event, PDMI constructed a 20-foot tall
concrete dam approximately 200 feet from the toe of the stockpile. The dam created an unlined surface
impoundment with a natural creek bed and has a storage capacity of approximately 4.7 acre-feet. The
estimated 6.7 acre-feet of run-off from the portion of the watershed above the pile is delayed as it
infiltrates through the pile. Studies have shown that precipitation on a large portion of the pile itself does
not contribute to the run-off to the dam. Any run-off from the pile travels approximately 200 feet
overland to the dam. All run-off from the portion of the watershed below the pile but above the dam
flows directly to the dam. Automatic controls are designed to keep the volume of the pond at 0.5
acre-feet and at a depth of 10 feet to minimize hydraulic head. The dam effectively prevents any storm
water from discharging off-site. The depth to ground water below the dam is reported to be 5 to 10 feet.
All water collected at the impoundment that does not infiltrate the ground is pumped through an
HDPE pipeline to the top of the Lone Star Stockpile. The pumped water then filters through the
stockpile, after which it flows overland to the upgradient edge of the Southwest Stockpile. It infiltrates
through the Southwest Stockpile and is collected at the Stargo Sump. This pregnant leachate solution is
then pumped several miles on top of tailings through a pipeline overlying the Gila Conglomerate to the
mine's SX/EW facility for extraction and electrowinning.
The Producer Pile dam and resulting impoundment were constructed to protect surface water from
storm water run-off from the pile. The Arizona Department of Environmental Quality (ADEQ) has made
visual observations and collected data indicating that infiltration from the pile and the impoundment may
be adversely affecting the quality of both ground water and surface water.
Type of Impact/Media Affected: Ground water issues from several intermittent springs along the gulch,
including several seeps located downstream from the dam that issue from fracture zones and faults at
flow rates of one gallon per minute (gpm). Approximately 2,500 feet downstream from the dam, ADEQ
personnel observed and documented with photographs a several-hundred-foot-long surface seep with a
distinct blue-green color indicative of a copper-bearing precipitate. Neither ADEQ nor PDMI collected
samples of the precipitate. Although not yet demonstrated, the observed contamination of the surface
seep is considered by ADEQ to be reasonably attributable to the Gold Gulch impoundment. There is
currently only limited documentation regarding the quality of the ground water down gradient of the
impoundment in the Gold Gulch watershed. There are no monitoring wells upgradient of the rock dump.
In April 1996, however, ADEQ collected water quality data from a monitoring well that is downgradient of
the waste rock dump and impoundment located in Gold Gulch, but in another drainage. Although the

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. 	 	 	 			 .

Page 37
standard for antimony is 0.006 mg/l, the reported concentration in the collected sample from the nearby
well was 0.0092 mg/l. All other parameters evaluated by ADEQ for samples from this well were below
applicable standards. Without additional wells being constructed, it is not possible to attribute the
observed ground water quality directly to the Gold Gulch impoundment.
PDMI has evaluated an alternative control option for this impoundment that would entail lining the
pond behind the dam with a 60-mil HDPE liner. PDMI has concluded that the dam's design and the
operational discharge controls and site characteristics provide "significant resistance to infiltration and
constitute Best Available Demonstrated Control Technology."
Regulatory Action/Response: Arizona is managing these ground and surface water quality concerns through
its new Aquifer Protection Permit (APP) program. The State designed the APP process to implement a
cooperative approach to identifying, preventing, and remediating potential environmental concerns that
could adversely affect ground water in the vicinity of specific types of facilities, including mines, industrial
plants, and municipal wastewater facilities. The permitting process involves State permit writers working
with facility owners/operators to prepare detailed State-issued permits specifying facility design
requirements, monitoring requirements, self-reporting requirements, additional steps to correct historical
degradation of ground water quality, and possible re-evaluation of permit conditions to address any
environmental or facility/operational changes. Compliance monitoring and periodic site inspections
occur at permitted facilities to ensure that each facility is maintained and operated to restore and
maintain ground water quality. The APP application for this facility is currently undergoing technical
review by ADEQ.
References:
Arizona Department of Environmental Quality. Facility Site Inspection Report, including notes and photographs.
March 10,1995.
Olsen, Greg, ADEQ/APP Mining Unit Project Officer. Personal Communication. November 18,1996.
Phelps Dodge Morenci Inc. and Dames and Moore. Aquifer Protection Permit Application. March 28,1996.

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Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath an
Unlined Impoundment is Discovered"
Waste and Material Management Practices: Phelps Dodge Morenci Inc. (PDMI) operates an open pit copper
mine in southeastern Arizona. PDMI constructed an impoundment in the Rocky Gulch drainage well
above the confluence of the gulch with the river following the discovery of contaminated water flowing
from Rocky Gulch to the San Francisco River. The Rocky Gulch Dam is a storm water collection system
located approximately 200 feet downgradient of the toe of the Rocky Gulch Stockpile. The Rocky Gulch
Stockpile is a development rock stockpile containing low-grade development rock that was closed prior
to 1986. The dam system consists of a 25-foot high roller-compacted concrete dam and spillway, an
unlined impoundment, and a pump bay. The impoundment has a maximum storage capacity of
approximately 34 acre-feet at the spillway crest elevation. The pump bay consists of a pit, approximately
40 feet by 40 feet by 10 feet deep, excavated into the foundation rock. The pump bay is equipped with
two 3,000 gallon-per-minute rated pumps and is located approximately 150 feet upstream of the dam.
The pump bay collects seepage flow from the excavated impoundment area to keep the impoundment
empty during normal operating conditions. It also pumps storm water collected in the impoundment to
the top of the Placer Stockpile. The impoundment has a slight slope that promotes drainage to the pump
bay. The pumps are set to maintain the fluid level in the bay at less than 3 feet. Overflow from the
pump bay into the impoundment occurs only during storm events that exceed the capacity of the pumps
in the pump bay. The dam, with the pumps operating, is designed to contain run-off from a 100-year,
24-hour storm event.
The dam captures spring water that seeps from the toe of the stockpile and storm water run-off from
areas unimpacted by mining activities upgradient and downgradient of the stockpile. Most of the
precipitation that falls onto the stockpile is retained within the stockpile. The storm water run-off from
areas upgradient of the stockpile is delayed as it infiltrates through the stockpile and exits at the toe. The
potential discharge from the impoundment is natural spring water and storm water run-off that percolate
through the development rock stockpile. PDMI claims that most of the upgradient run-off does not report
to the toe of the stockpile. The primary source of discharge is the unlined pump bay. The impoundment
is reportedly empty except when storm water flow exceeds the capacity of the pumps. Thus, it is not a
source of surface water or ground water discharge under normal conditions.
On April 25,1996, Arizona Department of Environmental Quality (ADEQ) staff collected samples
from the point-of-compliance monitor well for Rocky Gulch Dam. The samples collected from the well
violated Maximum Contaminant Levels (MCLs) for seven parameters.
Type of Impact/Media Affected: The water quality standard violations documented by ADEQ on April 25,
1996, are displayed below.
Parameter
Maximum Observed
Concentration (mg/1)
Applicable Standard (mg/l)
Beryllium
0.0166
0.004
Cadmium
0.0202
0.005
Fluoride
8.55
4.0
Iron
42
0.3
pH (standard units)
4.37
6.5-9
Sulfate
706
500(proposed)
Total dissolved solids
1270
500

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Because the contamination was discovered in 1996, the size of the contaminated plume of ground
water beneath Rocky Gulch is not yet known. There are no drinking water wells within one mile of the
impoundment. However, the municipal supply of the town of Clifton is downgradient of the
impoundment. Clifton maintains two public water wells in the alluvium of the San Francisco River near
the river's confluence with Rocky Gulch. The wells provide an alternative water supply for the town's
approximately 3,000 residents. To date, no contamination of the ground water supplied by these two
intakes has been documented. The distance from the dam to the wells was not documented in the
available files.
Regnlatory Action/Response: The regulatory mechanism in place in Arizona to deal with ground water quality
issues at mines is the State's Aquifer Protection Permit (APP) program. The program's application
development and review process was designed to achieve a cooperative approach to identifying,
preventing, and remediating potential environmental concerns that could adversely affect water quality in
the vicinity of mines as well as other types of facilities, including industrial plants and municipal
wastewater facilities. The APP permitting process involves permit writers working with facility owners
and operators to prepare detailed state-issued permits specifying facility design requirements, monitoring
requirements, self-reporting requirements, additional steps to correct historical degradation of ground
water quality, and possible re-evaluation of permit conditions to address any environmental or
facility/operational changes.
ADEQ received PDMI's APP application for the Morenci Mine on March 28,1996. ADEQ worked
with PDMI to ensure that a complete application, including all hydrogeology, well construction, and
engineering requirements, were submitted. At the time of the file review, ADEQ's APP section was
performing an in-depth technical review of PDMI's application prior to issuing a permit. To ensure that
the mine's facilities are maintained and operated to restore and maintain ground water quality,
compliance monitoring and periodic site inspections will occur once all the mine's facilities are permitted.
There was no indication in the files concerning the issuance date of PDMI's permit or what conditions the
permit would stipulate.
Based on PDMI's APP application, several alternatives that could affect the discharge of
contaminants to ground water at Rocky Gulch have been considered by PDMI. Although PDMI claimed
that the impoundment's existing discharge control technologies minimize loading to the aquifer, ADEQ
subsequently discovered violations of water quality standards in samples collected from the monitoring
well for the impoundment. Based on the application, PDMI considered lining the Rocky Gulch Dam
impoundment and the pump bay with 60-mil HDPE liners. PDMI concluded that lining the pump bay
would not be effective because seepage flow to the pump bay would "float" the liner. PDMI did
acknowledge in its APP application that lining the impoundment would constitute prescriptive Best
Available Discharge Control Technology (BADCT). They had calculated that a liner would reduce the
equivalent daily discharge rate from the impoundment by approximately 477 gallons per day, or 97
percent. At the time the application was submitted, however, PDMI claimed that lining the impoundment
was not warranted. PDMI's argument against installing the lining was based, in part, on the high
associated cost which PDMI estimated to be approximately $665,000. There was no indication in the
available files concerning how ADEQ and PDMI ultimately will resolve the aquifer degradation situation
that has been discovered, or whether PDMI still maintains that the lining is unwarranted. At the time of
the file search, the source of the contamination of the ground water had not been definitively
documented.
References:
Arizona Department of Environmental Quality. Notice of Violation. October 24,1994.
Arizona Department of Environmental Quality. Inter-Office Memorandum Re: Phelps Dodge Discharge of August 1Z 1996.
August 14,1996.
Arizona Department of Environmental Quality. Notice of Violation. November 1,1996.

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Arizona Department of Environmental Quality. Letter from Finton, Pv toBeardsley, W. February 2,1996
Arizona Department of Environmental Quality. Letter from Hyde, Pw toMohr, /?„ Phelps Dodge Morenci. March 11,
1994.
Arizona Department of Environmental Quality. Letter from Hyde, P* to Pope, £, USGS. March 16,1994.
Phelps Dodge Morenci. Letter from Mohr, /?, to Strauss, A* U.S. Environmental Protection Agency, Region 9. August 16,
1996.
Phelps Dodge Morenci Inc. Aquifer Protection Permit Application. March 28, 1996.

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Page 41
Arizona
Phelps Dodge Morenci Inc.:
"Contaminated Ground Water Beneath an
Unlined Impoundment is Discovered"
Waste and Material Management Practices: Phelps Dodge Morenci Inc. (PDMI) operates an open pit copper
mine in southeastern Arizona. PDMI constructed an impoundment in the Rocky Gulch drainage well
above the confluence of the gulch with the river following the discovery of contaminated water flowing
from Rocky Gulch to the San Francisco River. The Rocky Gulch Dam is a storm water collection system
located approximately 200 feet downgradient of the toe of the Rocky Gulch Stockpile. The Rocky Gulch
Stockpile is a development rock stockpile containing low-grade development rock that was closed prior
to 1986. The dam system consists of a 25-foot high roller-compacted concrete dam and spillway, an
unlined impoundment, and a pump bay. The impoundment has a maximum storage capacity of
approximately 34 acre-feet at the spillway crest elevation. The pump bay consists of a pit, approximately
40 feet by 40 feet by 10 feet deep, excavated into the foundation rock. The pump bay is equipped with
two 3,000 gallon-per-minute rated pumps and is located approximately 150 feet upstream of the dam.
The pump bay collects seepage flow from the excavated impoundment area to keep the impoundment
empty during normal operating conditions. It also pumps storm water collected in the impoundment to
the top of the Placer Stockpile. The impoundment has a slight slope that promotes drainage to the pump
bay. The pumps are set to maintain the fluid level in the bay at less than 3 feet. Overflow from the
pump bay into the impoundment occurs only during storm events that exceed the capacity of the pumps
in the pump bay. The dam, with the pumps operating, is designed to contain run-off from a 100-year,
24-hour storm event.
The dam captures spring water that seeps from the toe of the stockpile and storm water run-off from
areas unimpacted by mining activities upgradient and downgradient of the stockpile. Most of the
precipitation that falls onto the stockpile is retained within the stockpile. The storm water run-off from
areas upgradient of the stockpile is delayed as it infiltrates through the stockpile and exits at the toe. The
potential discharge from the impoundment is natural spring water and storm water run-off that percolate
through the development rock stockpile. PDMI claims that most of the upgradient run-off does not report
to the toe of the stockpile. The primary source of discharge is the unlined pump bay. The impoundment
is reportedly empty except when storm water flow exceeds the capacity of the pumps. Thus, it is not a
source of surface water or ground water discharge under normal conditions.
On April 25,1996, Arizona Department of Environmental Quality (ADEQ) staff collected samples
from the point-of-compliance monitor well for Rocky Gulch Dam. The samples collected from the well
violated Maximum Contaminant Levels (MCLs) for seven parameters.
Type of Impact/Media Affected: The water quality standard violations documented by ADEQ on April 25,
1996, are displayed below.
Parameter
Maximum Observed
Concentration (mg/l)
Applicable Standard (mg/l)
Beryllium
0.0166
0.004
Cadmium
0.0202
0.005
Fluoride
8.55
4.0

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.v.'.v
Page 42 j
		f •
Iron
42
0.3
pH (standard units)
4.37
6.5-9
Sulfate
706
500 (proposed)
Total dissolved solids
1270
500
Because the contamination was discovered in 1996, the size of the contaminated plume of ground
water beneath Rocky Gulch is not yet known. There are no drinking water wells within one mile of the
impoundment. However, the municipal supply of the town of Clifton is downgradient of the
impoundment. Clifton maintains two public water wells in the alluvium of the San Francisco River near
the river's confluence with Rocky Gulch. The wells provide an alternative water supply for the town's
approximately 3,000 residents. To date, no contamination of the ground water supplied by these two
intakes has been documented. The distance from the dam to the wells was not documented in the
available files.
Regulatory ActionfResponse: The regulatory mechanism in place in Arizona to deal with ground water quality
issues at mines is the State's Aquifer Protection Permit (APP) program. The program's application
development and review process was designed to achieve a cooperative approach to identifying,
preventing, and remediating potential environmental concerns that could adversely affect water quality in
the vicinity of mines as well as other types of facilities, including industrial plants and municipal
wastewater facilities. The APP permitting process involves permit writers working with facility owners
and operators to prepare detailed state-issued permits specifying facility design requirements, monitoring
requirements, self-reporting requirements, additional steps to correct historical degradation of ground
water quality, and possible re-evaluation of permit conditions to address any environmental or
facility/operational changes.
ADEQ received PDMI's APP application for the Morenci Mine on March 28,1996. ADEQ worked
with PDMI to ensure that a complete application, including all hydrogeology, well construction, and
engineering requirements, were submitted. At the time of the file review, ADEQ's APP section was
performing an in-depth technical review of PDMI's application prior to issuing a permit. To ensure that
the mine's facilities are maintained and operated to restore and maintain ground water quality,
compliance monitoring and periodic site inspections will occur once all the mine's facilities are permitted.
There was no indication in the files concerning the issuance date of PDMI's permit or what conditions the
permit would stipulate.
Based on PDMI's APP application, several alternatives that could affect the discharge of
contaminants to ground water at Rocky Gulch have been considered by PDMI. Although PDMI claimed
that the impoundment's existing discharge control technologies minimize loading to the aquifer, ADEQ
subsequently discovered violations of water quality standards in samples collected from the monitoring
well for the impoundment. Based on the application, PDMI considered lining the Rocky Gulch Dam
impoundment and the pump bay with 60-mil HDPE liners. PDMI concluded that lining the pump bay
would not be effective because seepage flow to the pump bay would "float" the liner. PDMI did
acknowledge in its APP application that lining the impoundment would constitute prescriptive Best
Available Discharge Control Technology (BADCT). They had calculated that a liner would reduce the
equivalent daily discharge rate from the impoundment by approximately 477 gallons per day, or 97
percent. At the time the application was submitted, however, PDMI claimed that lining the impoundment
was not warranted. PDMI's argument against installing the lining was based, in part, on the high
associated cost which PDMI estimated to be approximately $665,000. There was no indication in the
available files concerning how ADEQ and PDMI ultimately will resolve the aquifer degradation situation
that has been discovered, or whether PDMI still maintains that the lining is unwarranted. At the time of
the file search, the source of the contamination of the ground water had not been definitively
documented.
References:

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Arizona Department of Environmental Quality. Notice of Violation. October 24,1994.
Arizona Department of Environmental Quality. Inter-Office Memorandum Re: Phelps Dodge Discharge of August 12,1996.
August 14,1996.
Arizona Department of Environmental Quality. Notice of Violation. November 1,1996.
Arizona Department of Environmental Quality. Letter from Finton, £, toBeardsley, W. February 2,1996
Arizona Department of Environmental Quality. Letter from Hyde, £, toMohr, /?„ Phelps Dodge Morenci. March 11,
1994.
Arizona Department of Environmental Quality. Letter from Hyde, Pv to Pope, £, USSS. March 16,1994.
Phelps Dodge Morenci. Letter from Mohr, R, to Strauss, A, U.S. Environmental Protection Agency, Region 9. August 16,
1996.
Phelps Dodge Morenci Inc. Aquifer Protection Permit Application. March 28,1996.

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Arizona
ASARCO Ray Complex:
"Airborne Fugitive Dust and Tailings Result
from Improper Management and Maintenance"
Waste and Material Management Practicee: The ASARCO Incorporated Ray Complex, located in Arizona's
Pinal County, comprises one of the largest mineral extraction and processing operations in Arizona. The
complex is two separate sites, with Arizona Highway 177 passing through or running adjacent to both
sites. ASARCO's open pit copper mine, known as the Ray Mine, is located at the northernmost of the two
sites. This unit of ASARCO's complex is called the Ray Unit at which most of the operations are carried
out. The concentrator at the Ray Unit processes most of the lower grade ore mined at the Ray Unit. The
resulting tailings and wastewater are transported to the Elder Gulch tailings impoundment. The ore
processed by the Ray concentrator plus some of the higher grade ore from the mine is shipped by rail to
ASARCO's other site in the county, near the town of Hayden. The Ray concentrator processes
approximately 32,000 tons of ore daily, while the concentrator in Hayden processes 15,000 tons a day.
The Ray concentrator produces 180 tons of copper concentrate per day, and the Hayden concentrator
produces 80 tons to copper concentrate per day. ASARCO's smelter also is located at the Hayden site.
On May 8,1991, Arizona Department of Environmental Quality (ADEQ) staff conducted an
inspection of ASARCO's Ray Unit. Inspectors noted that several areas were not being maintained in
accordance with conditions stipulated in ASARCO's permit.
On December 5,1995, Arizona Department of Environmental Quality (ADEQ) staff conducted an
inspection of the concentrator at the Ray Complex. The inspectors observed fugitive emissions at the
facility while ore schists were being unloaded. The dump hopper spray system was not being operated.
Type of Impact/Media Affected: Air Permit No. 036293 requires ASARCO to maintain and control emissions
from tailings piles, ponds, and associated roadways. In order to control fugitive emissions, roadways are
required to be capped using decomposed granite, and the mine must use a water truck to achieve a 90
percent dust control efficiency. Similarly, tailings pond surfaces must be wet down or encrusted to
control emissions. During the inspection, May 8,1991, ADEQ inspectors noted numerous strips of
drifting tailings on roadways on the property. In addition, many of the roadways were not encrusted,
some were missing permit-required decomposed granite caps, and powdery dust up to three inches thick
covered portions of many of the roadways. The talcum-powder-like dust on some of the roadways was
easily entrained by any passing vehicles.
During any operations likely to result in significant amounts of airborne dust, Arizona's
Administrative Code requires that reasonable precautions be taken to prevent excessive amounts of
particulate matter from becoming airborne, such as using spray bars, wetting agents or dust
suppressants, covering loads, and using hoods. In addition, Arizona's air pollution control operating
permit for the ASARCO Ray Complex's Hayden concentrator requires the reduction of fugitive emissions
from the crushing plant by operating a spray system. The system is required to spray no less that 1.4
gallons per minute from each of at least four spray heads located at each side of the dump hopper. The
heavy dust plumes on December 5,1995, were not monitored because of the short duration of the
emissions.
Regulatory Aetion/Reeponee: On May 23,1991, ADEQ issued a Notice of Violation (NOV) to ASARCO for the
failure of the facility's operators to observe the permit requirements and the State Implementation Plan at
the Ray Unit.

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ADEQ's Air Quality Division issued a NOV on December 11,1995, to the ASARCO Ray Complex
as a result of the violations observed during the December 5,1995 inspection. The NOVs corrective
action provisions required the Ray Complex always to operate the Rail Road Dump Hopper when
conducting materials unloading operations. ADEQ also required a written summary or compliance plan
to assure proper operation of the spray system to reduce fugitive dust emissions. ADEQ did not levy a
civil penalty against the facility as part of the NOV, but cautioned that achieving compliance does not
preclude ADEQ from imposing a fine. Further, ADEQ stated that an unilateral enforcement action would
result if compliance was not achieved. Such an action may impose a civil penalty for each violation for
the entire non-compliance period. No additional information pertinent to this violation was present in the
available state files.
References:
Arizona Department of Environmental Quality. Latter from Jasper, toB. Ma/one, ASARCO Ray Unit. March 25,
1991.
Arizona Department of Environmental Quality. Letter from Olson, S, to IV. Gambell, ASARCO Ray Technical Services.
December 11,1995.

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Page 46
ASARCO Ray Complex:
"Emissions from Multiple Sources Result
in Opacity Violations and Impacts on Community"
Waste and Material Management Practices: The ASARCO Incorporated Ray Complex, located in Arizona's
Pinal County, comprises one of the largest mineral extraction and processing operations in Arizona. The
complex is two separate sites, with Arizona Highway 177 passing through or running adjacent to both
sites. ASARCO's open pit copper mine, known as the Ray Mine, is located at the northernmost of the two
sites. This unit of ASARCO's complex is called the Ray Unit at which most of the operations are carried
out. The concentrator at the Ray Unit processes most of the lower grade ore mined at the Ray Unit. The
resulting tailings and wastewater are transported to the Elder Gulch tailings impoundment. The ore
processed by the Ray concentrator plus some of the higher grade ore from the mine is shipped by rail to
ASARCO's other site in the county, near the town of Hayden. The Ray concentrator processes
approximately 32,000 tons of ore daily, while the concentrator in Hayden processes 15,000 tons a day.
The Ray concentrator produces 180 tons of copper concentrate per day, and the Hayden concentrator
produces 80 tons of copper concentrate per day. ASARCO's smelter also is located at the Hayden site.
On March 19,1991, Arizona Department of Environmental Quality (ADEQ) staff conducted an
inspection of mineral tailings piles at the Ray Complex. The inspectors observed major fugitive
emissions coming from the tailings piles.
ASARCO continuously monitors emissions from both the reverberator and roaster (R&R) flue and
the acid stack. Opacity is monitored from both plants, with sulfur dioxide (S02) emissions also being
monitored at the acid plant. During the first and second quarters of 1991, ASARCO reported opacity and
S02 violations. In 1991 and 1992, ADEQ found opacity violations of the main smelter stack in Hayden.
Type of Impact/Media Affected: Arizona's Administrative Codes require mine operators to control emissions
from mineral tailings piles. During the inspection, a six-minute average opacity of 78 percent was noted,
violating the Arizona Administrative Code.
Arizona's Administrative Code requires the control of stack emissions. Air pollution equipment,
process equipment, and processes must be maintained and operated at all times to minimize emissions.
Arizona requires that opacity levels of ASARCO's R&R flue and the acid plant S02 stack not exceed 20
percent. ASARCO submits quarterly excess emissions reports to ADEQ on these two sources.
ASARCO's smelter also is required to meet an opacity limit of 20 percent. ASARCO reported that in the
first quarter of 1991 the R&R flue operated in excess of the 20 percent opacity standard 30 percent of the
time. In the second quarter, the flue exceeded the opacity standard 40 percent of the time. For the acid
plant, opacity standards were exceeded eight percent of the time in the first quarter and two percent of
the time in the second quarter. The six-hour average S02 standard of 650 ppm was self-reported by
ASARCO as having been violated eight percent of the time in the first quarter and two percent of the
time in the second quarter.
On several occasions in late 1991 and early 1992, ADEQ staff observed and monitored emissions
from the main smelter stack of ASARCO's operations in Hayden. On September 25,1991, ADEQ
observed an average opacity reading of 52 percent for the stack. On October 9,1991, the observed
opacity reading of the stack was 41 percent. On January 17,1992, the average observed reading was
44 percent. On January 30 and February 28, the average observed readings of the stack were 59
percent. Each of these readings was more than double the allowable opacity limit.
Regulatory Action/Response: On March 25,1991, ADEQ issued a Notice of Violation (NOV) to ASARCO.
The NOV cited the March 19 incident as well as the mine's long history of violations and the associated
severity and impact on the community. On the basis of the mine's history of emissions from the tailings
piles, ASARCO's lack of commitment to control tailings pile emissions and the historical impact on the

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community, ADEQ levied the maximum possible statutory civil penalty allowed, $10,000. There was no
information present in state files reviewed that discussed the severity or impact of ASARCO's emissions
either from this incident or historically.
Sighting apparent design deficiencies or operational and maintenance problems associated with the
reverberator and roaster and acid plants, ADEQ issued a NOV to ASARCO on August 26,1991, for
violating Arizona Administrate Codes. ASARCO was not subjected to a civil penalty for these violations;
however, ADEQ required a compliance activity plan with interim and final compliance dates stipulated.
This NOV requested ASARCO to comply voluntarily.
On October 4, and October 20,1991, and again on January 29,1992, ADEQ issued NOVs
concerning the excess emissions from the main smelter. ADEQ required ASARCO to state the
circumstances relating to the violation and provide detailed plans of how ASARCO would achieve prompt
and continuous compliance. This NOV also was a request for ASARCO to comply voluntarily. At the
time of the file review, documentation describing ASARCO's responses to these NOVs, if any, was
missing from the files available. Follow-up telephone calls may help determine the nature of ASARCO's
responses and whether any additional enforcement actions were taken by the state.
References:
Arizona Department of Environmental Quality.	Letter from Jasper, Wv to B. Ma/one, ASARCO Ray Unit. March 25,
1991.
Arizona Department of Environmental Quality.	Letter from Jasper, to B. Malone, ASARCO Ray Unit. August 26,
1991.
Arizona Department of Environmental Quality.	Letter from Jasper, IK, to B. Malone, ASARCO Ray Unit. October 4,
1991.
Arizona Department of Environmental Quality.	Letter from Jasper, MC to B. Malone, ASARCO Ray Unit. August 26,
1991.
Arizona Department of Environmental Quality.	Letter from Kempson, /?, to B. Malone, ASARCO Ray Unit. October
20.1991.
Arizona Department of Environmental Quality.	Letter from Kempson, Z?„ to B. Malone, ASARCO Ray Unit. January
29.1992.
Arizona Department of Environmental Quality.	Letter from Kempson, to B. Malone, ASARCO Ray Unit. February
11,1992.
Arizona Department of Environmental Quality.	Letter from Kempson, 0H to B. Malone, ASARCO Ray Unit. March 9,

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...........	- 		¦ ^. ¦ f				¦¦¦¦			e. . .w.-. ,r,rr. -----	—
Page 48
1992.

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Arizona
ASARCO Ray Complex:
"Mine Discharges Degrade Ground Water
and Surface Water"
Waste and Material Management Practices: ASARCO Incorporated extracts approximately 300,000 tons of ore
per day as part of an open pit copper mine operation in south central Arizona's Pinal County. This mine,
known as the Ray Mine, consists of four pits; the Pearl Handle, Amanda, Calumet, and West pits, with
the Pearl Handle being the largest. The site is drained by Mineral Creek and its principal tributary, Elder
Gulch. The creek is a perennial stream most years, but is occasionally dry. The creek joins the Gila
River south of the Ray Unit.
ASARCO collects pregnant leach solution (PLS) in ponds located in the washes below the leach
dumps. The electrowinned leach solution produces 90 tons of copper cathode per day. The ore
processed at the Ray concentrator, plus some of the raw higher grade ore, is shipped by rail car to
ASARCO's Hayden site, where ASARCO's smelter and another concentrator are located. The Ray
concentrator crushes and processes approximately 32,000 tons of sulfide ore daily, producing 180 tons
of copper concentrate per day. ASARCO transports the tailings from the concentrator to the Elder Gulch
tailings impoundment. The tailings derived from crushing, milling, and floatation are deposited at a rate
of 30,000 to 36,000 dry tons per day. They are transported to the impoundment as a slurry and are
deposited through a single discharge point located on the rockfill dam crest and from several other points
on the perimeter of the impoundment.
The floor of the electrowinning plant was lined with HDPE plastic in 1995. Old and leaking concrete
cells were replaced with polyfcrete cells. The electrowinning dam, which ASARCO planned to enlarge,
may contain storm water and overflow from various tanks in addition to PLS. The mine's routine
operations are chronically affecting the quality of both surface and ground waters in the mine's vicinity.
In April 1995, EPA reported that six ground water wells situated downgradient of the electrowinning plant
and the electrowinning dam were continuously pumping PLS. EPA concluded that it is likely that
contaminants are escaping from the Ray Unit and entering Mineral Creek via ground water.
Type of Impact/Media Affected: In July 1996, the Arizona Department of Environmental Quality (ADEQ)
reported that approximately one-half mile of the Mineral Creek stream bed below the Ray Mine was
visibly affected by mining activities. The cobble and gravel substrate in this stretch of the stream bed
was coated with a blue-green layer of copper oxides. These toxic materials are believed to be the result
of precipitation of the dissolved copper with increasing alkalinity. According to ADEQ, visible
environmental damage to Mineral Creek constitutes a violation of narrative surface water quality
standards.
Water quality degradation also is detectable in the chemical make-up of Mineral Creek as a result
of violations of numeric surface water quality standards, as documented by ADEQ in April 1996. ADEQ
termed the violations a dramatic degradation of water quality by mining activities. The surface water
quality standards violated based on samples collected in April 1996 in Mineral Creek immediately
downstream of ASARCO's Ray Unit are summarized below.
Parameter
Maximum Observed
Applicable Standard (mgfl)

Concentration (mgfl)


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Beryllium
0.011;;
O.OOOil
Cadmium
O.O6H1
0.05
Copper, total
6.54
0.5
Some of the violations of aquifer water quality standards that ADEQ documented based on samples
collected from three ground water monitoring wells are summarized below.
Parameter
Maximum Observed
Concentration (mg/l)
Applicable Standard (tngfl)
Arsenic
0.104
0.05
Beryllium
0.110
0.004
Cadmium
0.482
0.005
pH (standard units)
5.99
6.5 -S
As a result of these documented violations, ADEQ has inferred numerous subsurface discharges at
various points with respect to the mining facilities.
Regulatory ActionfResponse: EPA's NPDES permit for ASARCO's Ray Unit expired on August 3, 1993.
Although no new permit was present in the available files, the files did contain correspondence
concerning the development of draft conditions for the permit's reissuance. EPA planned to include
provisions for annual biological sampling of Mineral Creek downstream of the site. The results of that
sampling were to be compared to an appropriate reference site to provide an indication of the degree to
which ASARCO's pollution control measures were improving receiving water quality over the effective
life of the permit. This provision was written into the draft report as a result of the U.S. Fish and Wildlife
service (FWS) having consulted formally with EPA concerning the effect of mine discharges on
Endangered Species Act (ESA) listed species. In tandem with the Arizona Department of Game and
Fish, FWS had notified EPA that Mineral Creek below the Ray Mine was severely depleted of fish and
aquatic insect populations as compared with an upstream station, and that downstream riparian habitat
values were low. EPA intended to work closely with both ASARCO and FWS to develop a practical
approach to reissuing the permit. Prior to issuing the permit, EPA recommended the following
compliance measures:
All necessary efforts should be taken by ASARCO to determine the sources of copper
solutions that are entering Mineral Creek and to stop those discharges;
To stop unauthorized discharges of pollutants to Mineral Creek from transite pipelines;
transite pipelines carrying solutions in the vicinity and over Mineral Creek should be
located and replaced with HDPE piping;
An interim containment structure should be constructed at the base of the 4G Rock
Deposition Area to prevent storm water run-off from reaching Mineral Creek;
A pump should be installed in the monitor well located in the flood plain of Mineral Creek
downgradient of the 4D Rock Deposition Area (Adit seep) to intercept pollutants flowing
toward Mineral Creek. Additional hydrologic studies should be conducted in the 4D Rock
Deposition Area to determine if low pH, high copper solutions are entering Mineral
Creek;
Water quality monitoring of Mineral Creek above and below the electrowinning plant for
the presence of copper should be performed to determine the effectiveness of the six
cut-off wells. If the cut-off wells are ineffective, additional hydrogeological and or

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Page 51
engineering studies will be necessary;
Water quality monitoring of Mineral Creek above and below the Big Dome Pond for the
presence of copper should be conducted to determine the effectiveness of the four
slotted caisson pumping systems. If the caissons are ineffective, additional
hydrogeological and or engineering studies will be necessary; and
Cemented gravels located in the bed of Mineral Creek should be collected and tested to
determine the solubility of copper in the gravels to Mineral Creek water. If these gravels
are found to be contributing copper to Mineral Creek, then they should be removed.
In addition to the NPDES permit covering direct discharges to Mineral Creek, the Ray Unit was
required to secure a permit for discharges that could affect ground water quality. ADEQ issued an
Aquifer Protection Permit (APP) to ASARCO on September 25,1991. Arizona's APP is the principal
permit required by Arizona for operations such as this copper mine. The APP program was designed to
deal with ground water quality concerns by identifying and remediating those that could adversely affect
ground water quality in the vicinities of permitted mines. The permitting process involves correcting the
known historical degradation of ground water quality. The permit included the Elder Gulch impoundment
and required ground water monitoring, as well as design and operational requirements for the site. The
permit requirements included a response protocol in the event of the exceedance of permit-established
Alert Levels (AL) for ground water quality. The permit required ASARCO to meet the following
objectives:
Evaluate the source, extent, and magnitude of contamination causing AL exceedances
and the potential for an Aquifer Quality Limit (AQL) violation;
Evaluate any possible malfunction of impoundment design, pollution control devices, or
other equipment processes that may have caused or contributed to AL exceedances;
and
Provide recommendations for corrective action, additional monitoring, and
point-of-compliance (POC) wells, and operations records and data.
Several AL exceedances for multiple constituents have been observed. In 1995, ASARCO's
consultant responding to the AL exceedances observed in wells in the vicinity of the tailings
impoundment concluded that the water levels and chemical quality of ground water from wells in the
vicinity of the Elder Gulch impoundment were influenced by seepage from the impoundment. They
determined that the primary cause of the seepage was pressurization of the base of the tailings by direct
flow of tailings pond water into the impoundment's drain system. That flow increased the hydraulic
gradients of seepage outside the impoundment. Recommendations for corrective measures included the
following:
Slime seal the backs of ponds by dredging slimes. Extending the sealing over the entire
floor of the ponds and increasing the minimum thickness of the slime sealing may be
necessary in order to adequately reduce drain flow;
Reduce the size of the ponds to as small as practicable;
Extend the peripheral spigotting system for the full length of the dam perimeter to
provide longer drying periods between deposition cycles to achieve beach desiccation
and minimize infiltration;
Draw down the main tailings pond by reducing make-up water flow into the system;
Install three porous tip piezometers at each of two locations along the tailings beach for
confirmation of depressurization of the base of the tailings;

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r
Page 52
Measure the tailings pond water surface area, drain discharge, water reclaim volumes,
and tailings slurry inflow volumes and percent solids on a monthly basis, and reevaluate
the water budget; and
Measure water levels in existing wells at a frequency of at least every six weeks.
Work on many of these corrective measures was underway in mid-1995. ASARCO's consultant
concluded that completion of these corrective measures will reduce the probability of AQLs being
exceeded.
ASARCO notified ADEQ's APP Section of AL exceedances in four wells in April and July 1996, as
required by the facility's APP. The constituents were potassium, sodium, sulfate, and total dissolved
solids. ASARCO contends that these AL exceedances were forecast in the consultant's 1995 report.
They requested that the operational measures be given a chance to work prior to additional changes
being implemented. ASARCO also is concerned as to the progress that ADEQ was making on
calculating ALs. No information was identified in the state files available for review that addressed the
establishment of ALs for the Ray Unit or that identified the costs of the corrective measures
recommended by ASARCO's consultant. In addition, no information was available concerning
assessments of the effectiveness of any of the corrective measures that ASARCO has taken to date.
References:
AGRA Earth & Environmental, Inc. Elder Gulch Tailings Impoundment Alert Level Response. June 26,1995.
Arizona Department of Game and Fish. Investigation of Fisheries Resources and Habitat of Mineral Creek Arizona.
September 30,1993.
Arizona Department of Game and Fish. Mineral Creek/Ray Mine Fisheries and Habitat Survey Arizona. September 30,
1993.
ASARCO Ray Complex Technical Services. Letter from Gambell, Hlv to J. Bruneau, APP Section, ADEQ. April 10,
1996.
ASARCO Ray Complex Technical Services. Letter from Gambell, IU„ to R. Azizi, APP Section, ADEQ. July 26, 1996.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1,1994.
U.S. Environmental Protection Agency. Letter from Greenberg, K, to T. Scartaccini, ASARCO Ray Complex. April 14,
1995.
U.S. Environmental Protection Agency. Letter from Lendy, J, to T. Scartaccini, ASARCO Ray Complex. February 12,
1996

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Page 54
ASARCO Ray Complex:
"Breaches in Tailings Impoundment Containment
Dike Contaminates Eleven Miles of River Sediment"
Waste and Material Management Practices: ASARCO Incorporated's Ray Complex is located in south central
Arizona's Pinal County. ASARCO mines approximately 300,000 tons of ore per day at the Ray Mine,
located at the northernmost site. Approximately 15,000 tons of ore is sent from the Ray Unit via railcar
to the ASARCO Complex's other site, which is located in Hayden. Hayden also is the site of ASARCO's
smelter. A concentrator at the Hayden site produces 80 tons of concentrate copper per day. ASARCO's
Hayden mill began operations in 1911. It discharges tailings to an impoundment known as the AB-BC
tailings pond, which is located next to the Gila River. The impoundment and surrounding dike is
approximately 14,000 feet long, 3,600 feet wide, and 150 feet high.
Type of Impact/Media Affected: In December 1992,5.38 inches of rain were measured in Hayden, which was
a record. Another 6.78 inches of rain fell on Hayden in January 1993, on ground that was already
saturated. By comparison, average rainfall for the month is 1.05 inches. The rainfall led to a prolonged
flooding event during which the Gila River underwent numerous channel changes, scouring vegetation
and lowing the base level an estimated 15 feet. Swollen out of its banks by the heavy rains, the Gila
River breached the AB-BC tailings impoundment containment dike on the night of January 9,1993.
Continued flooding over the next several days resulted in a total of 13 separate breaches of the dike,
three of which eroded through the dike and into the toe of the tailings pile. The total discharge was
approximately 292,000 tons of tailings, which was about 216,000 cubic yards of material.
Sampling of the river showed that elevated concentrations of pollutants occurred at least 11 miles
downstream of the spill. The tailings formed bank and bottom deposits in the river, impairing both
recreational uses and the quality of habitat for plants and animals. The discharge also had an adverse
effect on the sediment loading of the river, the flow morphology, and the erosional patterns.
A 1995 Arizona Department of Environmental Quality (ADEQ) internal memorandum documented a
1994 ADEQ study that had been undertaken approximately 17 months after the tailings release. The
study found that the tailings had been diluted by the river's flow and had been deposited over the river's
entire flood plain. The study concluded that a vast area the riverbed's sands contained approximately
1.5 percent tailings. Although the tailings were no longer concentrated sufficiently in any one spot to the
point of visual recognition, chemical analyses of the sediments found that tailings were present in every
sample collected for many miles downstream of the breached dike. River sediments were enriched by
as much as 300 percent above background levels, with an average enrichment of 111 percent for three
parameters - sulfate, soluble solids, and copper. The study also concluded that the tailings-enriched
sands were likely to stress bottom feeders, the metabolisms of which are adversely affected by the
ingestion of excessively fine-grained inorganic sediments.
Regulatory Action/Response: The U.S. Army Corps of Engineers sent a nationwide permit verification letter to
ASARCO on March 9,1993, including four special conditions:
•. Provide estimates of the total cubic yards of material eroded by the flood;
• Provide results of representative samples of the tailings material and compare them to ADEQ's
Health Based Guidance Levels (HBGLs) for solids;
Speculate on the likelihood that future floods will erode additional portions of the dike;
and
Provide cost estimates for providing stabilization of the entire dike and other alternatives
for preventing future erosion of the tailings facility.

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ASARCO responded to these requests item by item. ASARCO's most precise estimate of the
volume of material eroded was 216,400 cubic yards. Sediment sampling results showed that only
concentrations of beryllium were above the HBGL. However, because comparable concentrations of
beryllium (i.e., also above the applicable HBGL) were noted from a sample collected above the tailings,
ASARCO contended that background conditions were responsible. ADEQ agreed and concluded in a
1995 report that nowhere were the concentrations of any toxics above the HBGLs. ASARCO
acknowledged that future flood events of the same magnitude or greater than the 1993 event are likely,
but claimed to be unable to predict how those future floods could impact the tailings because of so many
variables. ASARCO repaired the points where the flood impacted the tailings and protected them with
heavy rip-rap. The estimated cost of the repairs was $1,416,157. Cost estimates for placing light rip-rap
on the river side of the tailings containment dike are $1,000,000. ASARCO also suggested that the
Corps undertake re-channelization of the river in the Hayden area. Based on the state files available for
review, no further information was available concerning further communications relative to these four
permit conditions. Follow-up phone calls to ADEQ or EPA Region 9 staff may help clarify whether any
additional actions have been taken or are under consideration.
ADEQ sent a letter to ASARCO on September 28,1993, notifying ASARCO that the discharge of
tailings to the river was a violation of the Clean Water Act. To remedy the effects on the river and to
prevent a repeat of the discharge, ADEQ requested that ASARCO comply with the following requests:
Prepare plans for the protection of the tailings during a 500-year flood;
Prepare plans to dredge approximately 250,000 tons of sediment from the river
downstream of the tailings;
Present the dredging plans, costs, and a schedule to ADEQ; and
Reimburse ADEQ for costs incurred for investigating and preparing the case.
The February 1995 draft report of a subsequent study conducted by ADEQ made several
recommendations and conclusions that differed from the requests described above. The major
contradictory recommendation of the study was that given the extent of redeposition of natural sediments
and the lack of tailings concentrations in toxic amounts, the dredging of 250,000 tons of sediment from
the river channel was not advisable. Because the flood waters cut new channels and deepened
cutbanks, ADEQ's study also concluded that the amount of soil redeposited by natural forces far
outweighed the amount of tailings released. According to the 1995 study, no recovery of the river's
sediment is feasible because of the thorough dispersal of the tailings. As a result of the deposition of the
tailings throughout the sediments in non-toxic concentrations, ADEQ termed their present environmental
detriment as "nil." It argued that any attempt to remove the tailings would cause extensive damage to
the riparian habitat while producing marginal benefits. The study also concluded that the only effective
remediation along the affected stretch of the river, enlarging and improving the containment dikes, had
already been accomplished by ASARCO. Lastly, the study recommended that ASARCO perform a
supplementary environmental project costing $250,000. No further information on how ASARCO
responded to ADEQ's requests was available in the state files available for review.
References:
Arizona Department of Environmental Quality. Internal (draft) memorandum from Hyde, Pv toR. Best on ASARCO Hayden
tailings spill of January, 1993and the extent of tailings downstream along the Gila River. February 6,1995.
Arizona Department of Environmental Quality.	Inter-Office memorandum from Matt J-, on ASARCO Hayden Tailings Spill.
July 8,1993
Arizona Department of Environmental Quality.	Inter-Office memorandum from Matt, on ASARCO Hayden Tailings Spill.
September 2,1993.

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Page 56
ASARCO. Letter from Gambell, Nv to R. Dummer, U.S. Army Corps of Engineers. February 18,1993.
ASARCO. Letter from Gambell, N., to R. Dummer, U.S. Army Corps of Engineers. September 7, 1993.
Arizona Department of Environmental Quality. Letter from Hyde, Pv to T. Scartaccini, ASARCO Bay Complex.
September 28,1993
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1,1994.
U.S. Environmental Protection Agency. Letter from Greenberg, KH to T. Scartaccini, ASARCO Ray Complex. April 21,
1995

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Arizona
ASARCO Ray Complex:
"Discharges from Mine Threaten Water Quality
in a Sensitive Stream"
Waste and Material Management Practices: ASARCO Incorporated maintains several mineral extraction and
processing operations at two large sites in Arizona's Pinal County. The two sites are separated by
several miles, with the northernmost site located about one and a quarter miles north of Kelvin, Arizona.
In addition to being the location of ASARCO's open pit copper mine, the Ray Mine, this site includes
milling operations, a solvent extraction plant, an electrowinning plant, an acid plant, a concentrator, a
water treatment plant, and numerous impoundments. All the facilities at this site are collectively known
as the Ray Unit. The mine consists of the Pearl Handle, Amanda, Calumet, and West pits. The Pearl
Handle is the largest pit. The site is drained by Mineral Creek, which is a perennial stream most years,
with one of its principal tributaries, Elder Gulch, also draining the site. The creek joins the Gila River
south of the Ray Unit. High grade ore from the mine is shipped to ASARCO's southernmost site, which
is near the town of Hayden, for smelting.
Approximately 300,000 tons of material is mined per day. The higher grade ores are processed at
two concentrators, one at each of the two sites. The Ray concentrator crushes and processes
approximately 32,000 tons of sulfide ore daily, and 15,000 tons is sent via railcarto the Hayden
concentrator. The tailings and wastewater produced at the Ray concentrator are transported to the Elder
Gulch tailings impoundment. The Ray concentrator produces 180 tons of copper concentrate per day,
and the Hayden concentrator produces 80 tons of concentrate per day.
Approximately 7,000 tons per day of low grade silicate ore is dump leached with sulfuric acid at the
Ray Unit. In addition, lower grade sulfide ore is dump leached. Pregnant leach solution (PLS) is
collected in ponds located in the washes below the leach dumps. An electrowinning plant on-site
processes the PLS from the leach ponds and produces 90 tons of copper cathode per day.
Unauthorized discharges of Ray Unit process waters to Mineral Creek and Elder Gulch have
occurred many times in recent years, including numerous violations of permit effluent limits. During one
eight month period from January to August 1993, nine spill events occurred at the mine that resulted in
unauthorized discharges to Mineral Creek. The specific causes have included overflows, equipment
failures, and damage caused by heavy machinery.
Type of impact/Media Affectefc The Ray Unit is occasionally subject to torrential rains. One such rain event
occurred on August 28,1993, when 1.9 inches of rain fell in thirty minutes. After the rain had stopped, a
bulldozer that ASARCO had dispatched to shore up an eroding berm struck a 16-inch leachate solution
pipeline. An estimated 7,200 gallons of copper sulfate solution was spilled into the flooding water. The
mixture had a copper concentration of 410 mg/l. The mixture overflowed a storm water catchment basin
and entered Mineral Creek. The raging water also drove several boulders into a 12-inch tailings reclaim
water line, resulting in a rupture that spilled approximately 30,000 gallons of reclaim water into the creek.
On January 29,1993, a bulldozer struck and broke a sump overflow pipeline, discharging copper
sulfate solution to Mineral Creek. A year earlier, on March 12,1992, another impact to a pipeline by an
ASARCO bulldozer caused a discharge to the creek of reclaim water. The amount of that discharge and
the concentrations of any pollutants were not documented in the available files.
Ambient water quality sampling data have documented non-compliance with water quality

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standards in Mineral Creek for a variety of metals. Copper concentrations as high as 2.7 mg/l were
reported in creek waters below the mine. In 1993, copper concentrations in the creek above 1 mg/l were
recorded in May, June, July, August, and September. Water quality violations were documented in the
same stretch of the creek for beryllium. In March 1993, discharges from a tributary of Mineral Creek that
also drains the Ray Unit, Elder Gulch, exceeded standards for hexavalent chromium, sulfides, and total
arsenic.
ASARCO's discharges affect a reach of Mineral Creek that typically flows, but on occasion
becomes completely dry. Arizona's Department of Game and Fish believes that the discharges from the
Ray Unit have negatively affected both the water quality and the aquatic life of Mineral Creek. The
Department conducted a biosurvey of Mineral Creek in July 1993. In a report dated September 30,
1993, the Department found that although the numbers and diversity of aquatic insects and fish were
high above the Ray Unit, an almost complete absence of aquatic life at sampling stations was observed
directly downstream of the mine.
Arizona's designated beneficial uses of the creek are Warm Water Fishery, Full Body Contact, Fish
Consumption, and Agricultural Livestock Watering. Of these, the most protective uses, which are those
with the most stringent water quality standards, are Fish Consumption and Warm Water Fishery. Water
quality standards for the latter use category include provisions for protection from acute and chronic toxic
effects. In addition, protection of native fish populations is viewed by the Department of Game and Fish
as essential to the creek. For example, the Colorado Roundtail Chub, which is a native fish found in the
creek, is listed as a state threatened species.
Regulatory ActionfResponsa: EPA has determined that the effluent from ASARCO's Ray Unit has the
potential to cause the water of Mineral Creek to exceed standards for toxics and that the discharges may
cause acute and chronic toxicity impacts to the creek. However, the dilution effects of the creek and the
resulting effect of the dilution on the toxicity of the discharge are unknown. Based on the information
available at the time of file review, the severity of the water quality and aquatic life impact had not been
definitively determined. In mid-1994, the Arizona Department of Environmental Quality (ADEQ) was
evaluating the civil penalty that would be levied against ASARCO for these illegal discharges. At that
time, ADEQ was considering penalties ranging from $1,625,000 to $18,775,000. The later figure was
calculated based on the number of violations expected during the period and the documented number of
discharges. The former penalty figure was based on the documented numbers of violations and discharges.
Other considerations in establishing penalty amounts would include the severity of the pollution and the
economic benefit of avoiding an environmental remedy. No additional information was available
concerning regulatory responses against ASARCO for these discharges. Also, no information was
available on the cleanup cost associated with repairing the pipeline breakage or other discharges.
References:
Arizona Department of Game and Fish. Investigation of Fisheries Resources end Habitat of Mineral Creek Arizona.
September 30,1993.
Arizona Department of Game and Fish. Mineral Creek/Ray Mine Fisheries and Habitat Survey Arizona. September 30,
1993.
ASARCO Ray Complex. Letter from Scartaccini, T* to U.S. EPA. August 31,1993.
Hyde, P. Memorandum on ASARCO Hayden tailings spill of January 1993and the extent of tailings downstream along the Gila River.
February 6,1995.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1,1994.
U.S. Department of Justice. Latter from Kwasny, /v to J. Johnson, Fennemore Craig, Attorney for ASARCO. May 4, 1994.

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U.S. Environmental Protection Agency. Letter from Greenberg, K, to T. Scartaccini, ASARCO Ray Complex. April 21,
1995.
U.S. Environmental Protection Agency. Draft Fact Sheet Permit No. AZ0000035. Undated.

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Arizona
ASARCO Ray Complex:
"Leachate Solution Overflows Collection Dams
to Mineral Creek and Elder Gulch"
Waste and Material Management Practices: ASARCO Incorporated has a large mineral processing operation in
south central Arizona that is split into two major sites. The mine is located near Kearny, in Pinal County,
at the site referred to as the Ray Unit. Dump leaching, solvent extraction, electrowinning, and high grade
ore concentrating are among ASARCO's operations at the Ray Unit. Several impoundments at the Ray
Unit are used to collect copper leach solutions. A series of pipelines provide the mechanism for
transporting the collected leachate solution throughout the facility. In recent years, the operation and
maintenance of several of these leachate collection systems has been unable to prevent releases to the
environment during major rainfall events. In addition, ASARCO has neither monitored nor reported
several recent releases to streams draining its properties. A water treatment plant at the Ray Unit is
permitted under the National Pollutant Discharge Elimination System (NPDES) to discharge treated
wastewater into Mineral Creek, subject to discharge limitations and monitoring requirements. The
discharges must not cause any violations of narrative or numeric state water quality standards.
From August 1990 through November 1993, at least 19 spills of hazardous materials were reported
at the ASARCO Ray Mine. The majority of spills were from dams, pipelines, and ponds. The discharges
typically resulted from either accidental discharges associated with heavy rain or from chronic seepage
from leaching facilities into the ground water, which then entered the creek. As a result, surface water
quality has been significantly affected. A total of 41 violations of total copper, dissolved copper, and
beryllium numeric surface water quality standards were documented by the Arizona Department of
Environmental Quality (ADEQ), EPA, and ASARCO in Mineral Creek below the Ray Mine.
Type of ImpactlNledia Affected: In August 1990, a storm that dropped 3.05 inches of rain in 24 hours caused
greater storm water run-off than ASARCO's facilities were designed and maintained to handle. The
run-off overwhelmed several of ASARCO's dams and at least one basin, including the Electrowinning,
Lower Slimes, and Stacker solution collection dams, and the Contingency Basin. As a result of the
run-off, the screens leading to the solution collection pipelines became clogged with debris. The inability
to use the pipelines led to copper-laden leachate solutions overflowing the dams. The combined volume
of solution that overflowed from the three dams was estimated at approximately 324,000 gallons. The
overflow reached Mineral Creek and Elder Gulch, a tributary to the creek. Copper sludge in the
Contingency Basin, which had not been cleaned out for several years, also was washed into Mineral
Creek during the storm. The amount of sludge discharged is unknown. Improper placement and
maintenance of the Contingency Basin's berms led to that release.
In January 1991, the overflow of another storm water run-off collection dam, the Stacker East dam,
caused another discharge to a tributary of Elder Gulch. As with the previous overflows, ASARCO failed
to notify EPA of the 695-gallon discharge. EPA site inspectors discovered evidence of the discharge on
January 15. They observed discolored pools of water in the stream bed and unsightly deposits on the
stream's bank that had been left by the discharge. The concentration of copper in that release was
reported to be 690 mg/l.
On April 19,1991, a broken pipeline coupling caused another 150,000 gallons of copper solution to
be discharged to Mineral Creek. A few months later, ASARCO discharged more leach solution to the
creek. On June 18,1991, an electrical failure led to a release of 1,500 gallons of solution.

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Total copper concentrations in Mineral Creek exceeded the state standard for Agricultural Livestock
Watering; dissolved copper exceeded the standard for Aquatic and Wildlife, warm water, acute; and total
beryllium exceeded the standard for Fish Consumption.
Regulatory Action/Response: Citing multiple discharges of copper solution and sludge containing copper to
surface water bodies, EPA issued a Finding of Violation and Order to ASARCO on July 1,1991. The
Order required ASARCO to comply with its NPDES permit requirements, take all measures necessary to
prevent future unauthorized discharges to Mineral Creek and its tributaries, and submit an engineering
plan outlining improvements to ensure compliance with effluent limits. The plan was to address pipeline
repairs, modifications, and replacements, equipment installation, construction, operating procedures, and
other measures necessary to achieve consistent compliance. Modifications were required by the Order
to begin by September 1,1991, and to be complete by July 1,1992. EPA also required ASARCO to
submit quarterly reports summarizing the progress made. Further, ASARCO was required to limit
discharges resulting from 3.05 inches of rain during a 24-hour period so as not to cause violations of
Arizona Water Quality Standards or NPDES permit limits. The facility's current NPDES permit allows
the discharge of run-off when rainfall exceeds 3.05 inches in 24 hours. Other conditions of the Order
imposed on ASARCO included the following:
Report all unauthorized discharges;
Report any non-compliance with the terms of the order,
Tabulate all discharges of pollutants to Mineral Creek and its tributaries, including dates,
quantities discharged, description of the pollutants, concentrations, laboratory chemical
results;
Describe all measures taken to achieve compliance with limitations, and the associated
capital, operational, and maintenance costs;
Describe all measures taken to stop discharges of pollutants into Mineral Creek and its
tributaries, and the associated capital, operational, and maintenance costs;
Compile water quality and sediment data collected on Mineral Creek;
* Interpret water quality and sediment data;
Compare results to Arizona Water Quality Standards; and
Describe any observed fish kills and degradation of the flora and fauna of Mineral Creek
and its tributaries.
On January 7,1992, ASARCO provided a cost estimate for 46 elements of an engineering plan and
program plan for improving and modifying facilities and procedures to ensure compliance with effluent
limits. ASARCO estimated that approximately $1.2 million would be required to implement all planned
changes which were to be completed by July 1,1992. These changes included training, replacing many
steel fixtures with stainless steel, replacing or upgrading piping, enlarging or constructing secondary
containment and berms, and repairing or constructing concrete containment, such as retaining walls,
sumps, and diversion boxes. No additional information could be found in the available files that
confirmed the final costs of these elements.
References:
ASARCO Technical Services. Letter from Gambefl, Nv to R. Clawson, U.S. EPA. January 7, 1992.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1,1994.

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..... 		¦¦¦¦¦..—¦ 		——..
Page 62
U.S. Environmental Protection Agency. Latter from Saraydarian, //v to K. Morano, ASARCORay Complex. July 1,
1991.

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UUUUWUUWJUWWIJJUUWUWIJWJUUWW^^
Page 63 i
ASARCO Ray Complex:
"Pipeline Breaks Lead to Contamination
of Mineral Creek and Stressed Aquatic Life and Wildlife"
Waste and Material Management Practices: ASARCO Incorporated's Ray Complex is located in Pinal County,
Arizona. The complex encompasses two sites separated by several miles. ASARCO's open pit copper
mine is located at the northern site, known as the Ray Unit. The Ray Mine consists of four pits, the Pearl
Handle, Amanda, Calumet, and West pits, with the Pearl Handle being the largest. ASARCO mines
approximately 300,000 tons of ore per day at the mine. Milling operations, solvent extraction,
electrowinning, ore concentrating, and water treatment also occur at the Ray Unit. The Ray concentrator
processes ore and produces tailings and wastewater that are transported to a tailings impoundment. The
Ray concentrator crushes and processes approximately 32,000 tons of sulfide ore daily and produces
180 tons of copper concentrate per day. Approximately 7,000 tons per day of low grade silicate ore plus
lower grade sulfide ore is dump leached. Pregnant leach solution (PLS) is collected in ponds located in
the washes below the leach dumps. The electrowinning plant produces about 90 tons of copper cathode
per day. Approximately 15,000 tons of sulfide ore daily is sent from the Ray Unit via railcar to the
ASARCO Complex site in Hayden, which also is the location of ASARCO's smelter. The Hayden
concentrator produce's 80 tons of copper concentrate per day.
The Ray Unit is drained by Mineral Creek, which is a perennial stream most years. The creek joins
the Gila River several miles south of the Ray Unit. Arizona's designated beneficial uses of Mineral
Creek are Warm Water Fishery, Full Body Contact, Fish Consumption, and Agricultural Livestock
Watering. Of these, the most protective uses, which are those with the most stringent water quality
standards, are Fish Consumption and Warm Water Fishery. Water quality standards for the latter use
category include provisions for protection from acute and chronic toxic effects. The Agricultural
Livestock Watering water quality standard for copper is 0.5 mg/l. Arizona's Department of Game and
Fish has stated that the protection of native fish populations in the creek, including the threatened
Colorado Roundtail Chub, is essential.
On March 30,1995, ASARCO noted a low pH reading in Mineral Creek. Upon investigation,
ASARCO discovered that a 30-inch gravity flow transite pipeline was leaking. The next day, an HPDE
line to the Ray concentrator came apart at the flanged end and released approximately 150,000 gallons
of fresh water.
Type of ImpaetfMedia Affected: In response to the pipeline leak, ASARCO constructed an emergency pond
and a pumpback sump to contain the release. The sump/pumpback was able to successfully contain the
discharge. ASARCO estimated that the pipeline had discharged to the creek for approximately 3.5 hours
and that a total of 21,000 gallons of solution had reached Mineral Creek and the Gila River, with an
estimated 1,033 pounds of copper sulfate released to Mineral Creek.
On the following day, some of the water from the broken HDPE line flowed through the storm drain
system and eventually overcame the sump/pumpback system put in place the previous day. Because
the pumpback still contained leach solution at the time of the second pipeline failure, it caused
approximately 900 gallons of water with a pH of 2.96 and a copper concentration of 90 mg/l to discharge
to Mineral Creek. That discharge caused a visible plume of sediment in the water. ASARCO diverted
the creek on an emergency basis in order to prevent the spread of any additional contamination
associated with the plume. About seven hours after diverting the creek and following the completion of
pipeline repairs, ASARCO returned the creek to its normal channel. ASARCO verbally notified both the
Arizona Department of Environmental Quality (ADEQ) and EPA within 24 hours of each release.
Regulatory Action/Response: Approximately seven weeks after receiving written notification of the incidents
by ASARCO, ADEQ informed ASARCO in writing that the emergency pond ASARCO had constructed to
contain the release was an unpermitted facility. ADEQ advised ASARCO that either a temporary

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emergency waiver (TEW) request or an Aquifer Protection Permit (APP) was required for this new
facility. ASARCO responded two weeks later in writing, assuring ADEQ that the intent in constructing the
sump was to protect the environment by stopping a discharge in the shortest time possible. ASARCO
pointed out that the sump was in existence for 24 hours only, and as such, should be considered a minor
modification to the overall operations of the Ray Mine. ASARCO stated that the sump did not result in a
significant change in the volume or characteristic of the pollutants discharged to the aquifer. ASARCO
also pointed out that there was little benefit in requesting a TEW for a sump two months after the incident
and requested that ADEQ forego requesting ASARCO to seek a TEW.
ADEQ responded to ASARCO's request in writing three months later. At that time, ADEQ advised
ASARCO that the release had. been determined to be a technical issue because it was specifically
related to the design and/or operation and maintenance of the pipeline. As such, ADEQ had determined
that the incident did not qualify for a TEW and was instead a violation of State law requiring an APP.
ADEQ further stated that it is required to issue a Notice of Violation (NOV) whenever it becomes aware
of a violation.
On December 9,1995, ADEQ issued an NOV to ASARCO. The NOV stated that the calculated
copper concentration in Mineral Creek during the March 30 incident was 49.5 mg/l, which is 100 times
the surface water quality standard for Agricultural Livestock Watering of 0.5 mg/l. ADEQ also stated that
the pH standard had, in all likelihood, also been violated because it was low enough to have prompted a
search for a leak. Thus, the discharge had caused at least two violations of water quality standards and
stressed the aquatic life and wildlife downstream of the mine.
As a corrective action, ADEQ required ASARCO to submit a written description of the options
considered to minimize exposure from the 30-inch gravity flow line. ADEQ also stipulated that ASARCO
should describe the final action taken within 60 days of the NOV. An emergency action plan also was
required so that ADEQ could be assured that a comprehensive and adequate response to these
unforeseen discharges would occur in the event of any future breaks from this and similar pipelines.
ASARCO responded to the NOV on February 29,1996, by reviewing the design, construction, and
maintenance of the pipeline and submitting an emergency action plan. ASARCO decided to replace the
pipeline with HDPE. The replacement was completed on September 18,1995, three months before
ADEQ had issued the December 19 NOV. The reported cost of the replacement with the new 31-inch
line was $841,000. The new line has no couplings and has a 2.5 inch wall thickness, providing greater
strength. ASARCO believes that the new line qualifies for an APP exemption. ADEQ agreed that an
exemption should be granted and commended ASARCO on its quick and effective response as well as
the substantial improvement of replacing the older pipeline.
References:
Arizona Department of Environmental Quality. Letter from Hyde, P., toN. Gambell, ASARCO. September 8,1995.
Arizona Department of Environmental Quality. Letter from Hyde, P„ to T. Scartaccini, ASARCO Bay Complex.
December 19,1995.
Arizona Department of Environmental Quality. Letter from Hyde, P„ to N. Gambell, ASARCO Ray Mine Technical
Services. March 6, 1996.
Arizona Department of Environmental Quality. Letter from Wood, to T. Scartaccini, ASARCO Ray Complex. May
24,1995.
ASARCO Technical Services. Letter from Gambell, Nv to P. Hyde, ADEQ. February 29,1996.
ASARCO Ray Complex. Letter from Scartaccini, to U.S. EPA. April 4,1995.
ASARCO Ray Complex. Letter from Scartaccini, 7"v to P. Hyde, ADEQ. June 8, 1995.

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Fennemore Craig. Letter from Johnson, JH to G. Hess, U.S. EPA. June 19,1995.
Hyde, P. Case development memorandum on the ASARCO Ray Complex. July 1,1994.
Hyde, P. ADEQ Memorandum on ASARCO Hayden tailings spill of January 1993and the extant of tailings downstream along the Gila
River. February 6,1995.
Hyde, P. ADEQ Memorandum on Mineral Creek Water Quality at the ASARCO Ray Mine on April 1-5,1996. July 1,1996.
U.S. Environmental Protection Agency. Letter from Greenberg, Kw to T. Seartaeeini, ASARCO Ray Complex. April 21,
1995.

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Phelps Dodge New Cornelia Branch Facility:
"Soil Contamination Results from Improper Disposal
of Scrap Metals"
Waste and Material Management Practices: The Phelps Dodge New Cornelia Branch Facility is a copper mine
in the vicinity of Ajo, Arizona, approximately 130 miles west of Tucson. At the time of the file search, no
documentation was available in the files reviewed providing a general description of the mine or
summarizing the facility's processes and waste management activities. The files did contain information
on compliance inspections and subsequent correspondence.
On May 23,1994, the Sheriffs Department investigated a complaint about smoke arising from the
Phelps Dodge Slag Pile. Officers observed two piles of burning wire. Phelps Dodge had an independent
contractor that performed various salvage activities, such as recycling and disposing of scrap metal,
including insulated copper wire. On June 22,1994, at the request of the County Attorneys Office and the
Sheriffs Department, Arizona Department of Environmental Quality (ADEQ) staff conducted a hazardous
waste inspection at the Phelps Dodge Slag Pile. Samples from the bum areas indicated soil
contamination with cadmium, chromium, and lead.
Type of Impact/Media Affected: ADEQ collected nine soil samples from the burn areas, all from within six
inches of the surface. Three contaminants of concern were identified; cadmium, chromium, and lead.
Six of the samples collected demonstrated levels of Toxicity Characteristic Leaching Procedure (TCLP)
lead over the regulatory limit, and one sample demonstrated levels of TCLP cadmium over the
regulatory limit. Based on the analyses conducted, ADEQ determined that there was reason to believe
that the slag pile itself was contaminated from the open burning and open dumping of insulated copper
wire.
Replatory ActionfResponee: On May 12,1995, ADEQ issued a Notice of Violation (NOV) to the independent
contractor working for Phelps Dodge. The NOV required (1) all contaminated soil and ash from the site
be placed into closed, labeled drums that are in good condition; (2) a hazardous waste contractor remove
the contaminated soil to a licensed TSD facility; (3) TCLP testing by a certified laboratory be conducted
for metals; (4) test results be provided to ADEQ; (5) MSDS sheets for any pyro-accelerants be provided
to ADEQ; and (6) use of all equipment used in copper-wire burning be discontinued.
Although Phelps Dodge reportedly did not approve of the copper wire burning at the site, the
company agreed to address the residual impacts of the burning. ADEQ granted Phelps Dodge a 30-day
extension until July 17,1995, to file a response. Field screening was performed by an environmental
contractor to determine the amount of material to be excavated. The excavated materials were treated
as hazardous waste and were stored in containers before being shipped to the Chemical Waste
Management Facility in Kettleman Hills, California. Phelps Dodge subsequently took confirmatory
samples of the excavated areas to ensure that the residual levels of cadmium, chromium, and lead did
not exceed the state's non-residential health based guidance level (HBGL) for each contaminant. On
October 25,1995, Phelps Dodge submitted a Voluntary Environmental Mitigation Use Restriction
(VEMUR) because the soil remediation levels achieved were not considered by the state to be protective
of residential use. The non-residential HBGLs for cadmium, chromium, and lead are 244, 5,950, and
1,400 mg/kg, respectively. A VEMUR may be canceled where soil remediation standards achieve levels
protective of residential use.

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uuttttioauiaauMMW
Page 67
Phelps Dodge determined that there was no likelihood that ground water could be impacted due to
the absence of ground water in the area. The nearest ground water drinking wells are five miles from the
site. Phelps Dodge pumps ground water from a depth of 800 feet from a well field six miles north of the
site.
References:
Arizona Department of Environmental Quality. Letter from Anderson, Z7, to Arnold Harraway. May 22,1995.
Arizona Department of Environmental Quality. Letter from Kueffer, Pw toJohnZamar, Phelps Dodge. August 8,
1995.
Arizona Department of Environmental Quality. Letter from Kueffer, P„ toJohnZamar, Phelps Dodge. October 17,
1995.
Arizona Department of Environmental Quality. Letter from Kueffer, P* toJohnZamar, Phelps Dodge. November 16,
1995.
Arizona Department of Environmental Quality. Letter from Kueffer, Pv toJohnZamar, Phelps Dodge. December 15,
1995.
Phelps Dodge. Letter from Zamar, JH to Lupe Buys, ADEQ. July 17,1995.
Phelps Dodge. Letter from Zamar, Jv to Lupe Buys, ADEQ. September 18,1995.
Phelps Dodge. Letter from Zamar, to Patrick Kueffer, ADEQ. October 25,1995.
Phelps Dodge. Letter from Zamar, J* to Patrick Kueffer, ADEQ. December 5,1995.

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BHP Copper, Inc. San Manuel Facility:
"Heavy Metals Contaminate Soil at Five Locations"
Waste and Material Management Practices: This facility includes a large copper mine located in southeastern
Arizona, near the town of San Manuel, in Pinal County. The facility was recently purchased from Magma
Copper Company by BHP Copper, Inc. At the time of the file search, documentation describing the
facility's history, processes, and waste management practices was missing from the available files. The
files did contain information on the general objectives, rationales, and procedures for specific remedial
action programs at the facility which were initiated as part of a required hazardous waste generator
cleanup. A description of the practices that led to the contamination of soils with heavy metals was not
present in the files.
Type of Impact/Media Affected: Past unspecified practices at several areas in BHP's San Manuel facility have
resulted in soil heavily contaminated with metals. To date, soil in the vicinity of at least five areas of the
facility has been documented as exhibiting the characteristics of a RCRA hazardous waste for at least
one heavy metal. The most severe contamination of soil was documented by analysis of samples
collected on August 23,1996, near the smelter waste bunker. Maximum total metals concentrations for
three metals that exceeded the regulatory threshold for characteristic hazardous waste found in soil
excavated from the smelter bunker were as follows: cadmium (120 mg/kg), lead (60,000 mg/kg), and
selenium (18,000 mg/kg). Soil and debris at the tank house were contaminated with lead and selenium
above the regulatory threshold for characteristic hazardous waste. Soil at the acid plant also was heavily
contaminated with both cadmium and lead above the regulatory threshold for characteristic hazardous
waste. Soil at the truck stop has been found to be heavily contaminated with cadmium above the
regulatory threshold for characteristic hazardous waste. Lead contamination has occurred in soil in the
vicinity of the paint shop. The regulatory threshold (RT) for cadmium and selenium is 1 mg/l, while the
RT for lead is 5 mg/l.
Regulatory Action/Response: The specific circumstances that led BHP to undertake remediation projects at
the five sites identified above was not clear from state files available for review. On September 16,
1994, Arizona Department of Environmental Quality (ADEQ) and Magma Copper Company entered into
a Consent Order to address the temporary storage of hazardous waste at the San Manuel facility. No
information was present in the files concerning any other regulatory action initiated by EPA Region 9 or
ADEQ. On September 13,1996, BHP's contractor proposed a method to stabilize the D006, D008, and
D0010 contaminated soils on-site to comply with appropriate Land Disposal Restriction (LDR) standards.
The estimated quantities of excavated soils to be stabilized at four of the sites are as follows:
Smelter bunker 300 tons
Acid plant: 170 tons
Truck shop: 80 tons
Paint shop: 30 tons
The precise technology that will be used to stabilize the estimated 300 tons of soil excavated from
the smelter bunker had not been determined at the time of the file search. The stabilization method to
be used on the soils excavated from the remaining four sites had been determined; BHP's contractor
plans to use a five to ten percent Portland cement recipe. Once non-hazardous levels of leachable
metals have been achieved for each of the five waste soils, BHP plans to dispose of the stabilized waste
in a RCRA Subtitle D landfill facility. Any debris that will not pass through a six-inch screen prior to
stabilization procedures will be disposed of at a licensed hazardous waste facility if the debris is found to
contain leachable metal concentrations above TCLP criteria. The estimated costs of these remediation
activities was not available.
References:

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ADEQ, Hazardous Waste Compliance Unit. Latter from Kuaffar, Pw to J. McCain, Magma Copper Co. April 20, 1995.
Zenitech Corporation. "Waste Analysis Han for On-Site Stabilization of the Tank House Waste Pile." November 21,1994.
Zenitech Corporation. 'Waste Analysis Plan for On-Site Stabilization of Metals Contaminated Soil." May 6,1996.
Zenitech Corporation. "Waste Analysis Plan for On-Site Stabilization of Metals Contaminated Soil." September 13,1996.

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11 ninnnii irrm n
Cyprus Copperstone Gold Corporation:
"Disposal of Non-Mine Related Waste Materials
in Mine Tailings Piles"
Waste and Material Management Practices: The Cyprus Copperstone, Gold Mine is a precious metals mine
located in La Paz County, approximately 120 miles west of Phoenix. The Bureau of Land Management
(BLM) owns the land the mine is on, and Cyprus Copperstone Gold Corporation (CCGC) owns the
operating permit for extracting precious metals.
CCGC contracts out its heavy equipment operations to Morrison-Knudsen (MK). MK subcontracts
its waste oil disposal to All Western Oil (AWO). CCGC contracted with AWO to dispose of waste oil in
both 1990 (6,300 gallons) and 1991 (33,410 gallons). Information obtained during an Arizona
Department of Environmental Quality (ADEQ) inspection of the facility conducted on August 28,1992,
disclosed that approximately 30 drums buried in the "hoosier piles" located on site contained waste oil
that was possibly contaminated with trichloroethylene (TCE) levels above the Maximum Contaminant
Level (MCL). The drums were placed in over-pack containers and buried with approximately four feet of
alluvial cover.
CCGC also had disposed of used tires for several years by burying them in waste piles located
on-site. The facility also stacked empty drums of sodium cyanide near the front of the facility before
disposing of them in the tailings pile located on-site.
Type of Impact/Media Affected: Because the situation was corrected when the state's regulatory agency
became aware of it, no effects on the environment could be documented.
Regulatory Action/Response: Following the site inspection in August 1992, ADEQ's Office of Waste
Programs, Hazardous Waste Inspections Unit issued "Instructions to Responsible Parties" on January 26,
1993. Although not a formal Administrative Order, the Instructions included specific steps that CCGC
was expected to follow to make corrections:
Properly handle, clean up, and dispose of waste oil;
Control, contain, clean up, and dispose of properly emptied cyanide drums and used tires;
Perform hazardous waste determinations for all wastes generated; and
Excavate, sample, and determine if the waste oil is hazardous.
In response to the Instructions, CCGC notified ADEQ that the TCE content of the waste oil was less
than 180 parts per billion (ppb), which is well below the 500 ppb leachability limit under the TCLP test.
CCGC agreed to voluntarily excavate the drums and dispose of them at an appropriate off-site facility.
CCGC maintained that used mine truck tires generated at the site have not been buried since 1990.
Further, CCGC maintained that the past practice of burying on-site cleaned, empty drums qualified as
disposal of inert solid waste material produced in connection with mining operations. Although they are
shipped off-site, CCGC believes that Arizona solid waste facility provisions exempt the on-site disposal
of inert solid waste material produced in connection with mining operations. As such, CCGC's position is
that the practice was exempted from Arizona solid waste facility provisions. That disposal practice
ceased in 1991.
Following ADEQ's receipt of a written status report defining the measures that CCGC took to correct
the violations and a submittal containing a certificate of disposal and manifest for the 30 drums of waste
oil, ADEQ determined that no additional action was required. As of November 1996, no information
present in state files available for review indicated that any further actions had been taken against
CCGC. Follow-up phone calls may help ascertain this type of information.

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References:
Arizona Department of Environmental Quality, Hazardous Waste Inspections Unit. Letter from Anderson, /?„ to
G. Bums, Cyprus Copparstona Gold Corp. January 26,1993.
Arizona Department of Environmental Quality, Office of Waste Programs, Waste Compliance Unit. Letter
from Camp, Sv to G. Bums, Cyprus Copparstorm Gold Corp. July 22, 1993.
Cyprus Copperstone Gold Corp. Letter from Burns, to P. Nixon. March 9,1993.

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Cyprus Sierrita Corporation:
"Leaks and Seepage Affect Ground Water
and Two Nearby Washes"
Waste and Material Management Practices: Cyprus Siemta owns and operates an open pit copper mine in
southern Arizona, in Pima County, near the town of Green Valley. The facility includes two open pit
copper mines known as the Sierrita and Esperanza pits. Higher grade ore is crushed and concentrated in
one of two mills located at the mine. The concentrate is then shipped off-site for smelting. The
concentration process produces a concentrated waste slurry that is disposed of in a tailings pond. Lower
grade ore is processed through a leach dump operation in which the ore is dumped in a massive pile and
leached with a mixture of water and sulfuric acid. Copper is extracted from these solutions through a
solvent extraction and electrowinning process. The process water used in these operations is channeled
to holding facilities and eventually recycled and reused.
From the summer of 1992 until December 1994, Cyprus Sierrita discharged contaminated process
water and storm water run-off to Demetrie Wash and its tributaries from various overflows, seepages,
and pipeline leaks and breaks.
Type of Impact/Media Affected: During the summer of 1992, as a result of storm water run-off, Cyprus Sierrita
discharged into the principal wash draining the site, Demetrie Wash, an unknown quantity of
contaminated sediment. The sediment originated from a pile of dredged material that had been removed
from the bottom of a surface impoundment known as Pond C. Pond C received storm water and
washwater run-off from crusher and concentrator areas. Sediment discharged from the pile accumulated
behind a dam in the wash known as the Caterpillar Road Dam. On August 4, the dam overflowed and
discharged sediment into the wash. Analyses showed the presence of copper and other pollutants. No
information was available in the files reviewed that reported the concentrations of pollutants based on the
sediment samples, with the exception of a maximum concentration of total copper. Based on samples
collected in November 1992 and reported by Cyprus Sierrita, levels of total copper ranged from less than
1.0 mg/l to 4.6 mg/l.
From August or September 1992 into January 1993, Cyprus Sierrita discharged contaminated water
to the wash. The apparently continuous discharge originated from an underground seepage believed to
be derived from two surface impoundments. The impoundments contained a mixture of process-related
water, mill site washdown water, and storm water. Cyprus attributed the surfacing of the discharge to
heavy rainfall events during August 1992 and the erosion of alluvial material from the side of a canal that
crosses the wash. The seepage was intercepted first by a stream known as Amargosa Wash. The
gravel bed in that stream provided a conduit for the contaminated flow to reach Demetrie Wash.
On January 24 and 25,1993, a leak in a pipeline transporting process water discharged
approximately 200,000 gallons of a mixture of process wastewater and storm water run-off to an
unnamed tributary of Demetrie Wash. Again, in July 1993, Cyprus Sierrita discharged approximately
2,700,000 gallons into the same wash as a result of another pipeline break. Approximately 450,000
gallons were released to the wash in October 1993 by a broken pipeline. Several months later, in March
1994, another pipeline break allowed a discharge into Demetrie Wash of approximately 120,000 gallons.
In December 1994, approximately 5,000 gallons were released as a result of a pipeline break. Each
release involved contaminated water derived from a mixture of tailings reclaim water and ground water
pumped from an interceptor well.
Regulatory Action/Response: On November 6,1992, EPA issued a letter to Cyprus Siemta requesting
information on operation and maintenance activities of Pond C and the adjacent dam, a chemical and
physical description of Pond C dam material, and cost estimates and a schedule for removing the
material discharged from Pond C to Demetrie Wash. EPA issued a Finding of Violation and Order for
Compliance to Cyprus Sierrita on March 16,1993. The Order required Cyprus Sierrita to cease all

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unauthorized discharges of pollutants; monitor, interpret, and report to EPA weekly on concentrations of
arsenic, cadmium, chromium, dissolved copper, lead, manganese, mercury, selenium, silver, zinc,
hardness, sulfates, and total suspended solids; confirm the source and cause of the discharges surfacing
in Demetrie Wash; describe the work completed to cease the discharges; provide a detailed cost
breakdown for the work required to stop the discharges; and prevent any future unauthorized discharges
of pollutants.
Cyprus Sierrita has reportedly undertaken extensive work to remove the accumulated material from
near Pond C and the area of the tributary. The work was completed in December 1992. The facility also
constructed a catchment basin to retain solids in the event of rainfall during the removal period. In
January 1993, Cyprus Sierrita reported to EPA that the costs associated with the removal of the material
were approximately $78,400. The mine-related materials that had accumulated in the wash were
removed by the end of April 1993. Costs for that removal activity could not be determined during the file
search and appear not to have been reported yet by Cyprus Sierrita. The mine's management maintains
that "it is impossible to provide a breakdown of the portion of the total costs attributable to discharge
prevention" because the costs are not accounted for separately. As an example, mine managers claim
that only a small portion of the costs of collecting and processing leach solutions for the recovery of
copper can be attributed solely to prevention of discharges.
Cyprus Sierrita also reported acting on several fronts to control the discharge of ground water that
surfaced in Demetrie Wash in August and September 1992. Short term corrective actions involved
studying conductivity to determine the discharge's origin, excavating a series of trenches, and operating
pumps in the trenches. The longer term efforts included a ground water investigation, the lining of the
canal, the construction of trenches in an attempt to intercept any subsurface flows towards the wash, a
geotechnical investigation, and construction of a hydraulic barrier. Although the facility apparently did
provide EPA with the expenditures for complying with this item of the order, those costs were not present
in the files reviewed.
On March 25,1996, the U.S. Department of Justice issued a civil claim against Cyprus Sierrita on
behalf of the State of Arizona and the United States pursuant to the Clean Water Act. Cyprus Sierrita
entered into a binding Consent Decree to pay a total civil penalty of $88,000. No further information
concerning the decree was present in the available files at the time of file review.

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Page 74
References:
Cyprus Sierrita Corp. Letter from Scott, RJ„ toU.S.EPA. April 19,1993.
Cyprus Sierrita Corp. Letter from Shinn, M., to U.S. EPA. January 13,1993.
U.S. Department of Justice. Consent Decree Among the United States, the State of Arizona, and Cyprus Sierrita Corp. March
25, 1996.
U.S. Department of Justice. The State of Arizona, Complaint and Chrii Action vs. Cyprus Sierrita Corp. March 25,1996.
U.S. Environmental Protection Agency. Letter from Serayadarian, Hw to Cyprus Sierrita Corp. March 16, 1993.

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Associated Minerals (USA), Inc.:
"Turbid Discharge Enters Nearby Creek"
Waste and Material Management Practices: Because this incident occurred while the facility was owned by
Associated Minerals, Inc., the practices used by them are described. Following bulldozer clearing
operations, the minerals are mined using a floating dredge and processing barge. A centrifuge is used to
separate the heavy minerals from the soil fraction. High volume waste materials that are generated
during the mining process consist of four percent humus and 96 percent tailings (quartz sands). These
materials are deposited behind the excavator in the mining pond and are allowed to dry, after which they
undergo reclamation. Reclamation involves replacing the topsoil and reforesting with pine trees. Mining
wastewater from the dredging and separation operations are heavily laden with dissolved and suspended
solids. The wastewater treatment system at the facility consists of flocculation with alum and/or sulfuric
acid before the treated effluent is released to a series of settling ponds on 180 acres. The effluent from
the ponds is neutralized with caustic and discharged through a Parshall flume to a ditch which flows to
Clark's Creek.
On March 9,1990, an earthen dam in front of two steel culverts was removed and not replaced
during reclamation operations. From March 10 to 11,1990, a rainfall event caused a washout of the
reclamation soils. The washout reached Terrel Creek and Greens Creek.
On August 27,1990, an unpermitted discharge from the facility mining area reclamation activities to
a tributary of Green's Creek occurred, following a rainfall event.
Type of Impact/Media Affected: Terrel Creek is a tributary to Greens Creek, which is classified as a Class III
water in Florida. Class III waters are to be used for recreation and for the propagation and maintenance
of healthy, well-balanced populations offish and wildlife (Ch. 17-3.161, FAC). The washout affected
Terrel Creek, according to Saint Johns Water District Officials. The nature of the impact (e.g., siltation),
however, was not documented in the Compliance Evaluation Inspection or in the Performance Audit
Inspection.
The turbidity of the discharge from the mining area to the tributary of Greens Creek on August 27,
1990, was 204.0 Nephelometric Turbidity Units (NTUs). The turbidity on August 30,1990, was 140
NTUs, at which time Florida Department of Environmental Regulation (FDER) investigators noted that
the tributary was being affected by the turbidity. The discharge violated State surface water quality
criteria (Rule 17-302.510(3)(r)) prohibiting a discharge which elevates the receiving waters to greater
than 29 NTUs over background levels. The background level of the receiving waters was not noted in
the documents addressing this release. The discharge also violated three Consent Orders, OGC Case
No.'s IW-003-81-SJRS, 82-0205, and 86-0130 from March 4,1981, April 1,1982, and July 18,1988,
respectively.
Regulatory ActionfRaspoiue: The March 1990 violation was noted in U.S. EPA Region IVs August 1990
Compliance Evaluation Inspection which required a response from the facility describing any actions
taken to remedy the situation. Facility personnel diked the area in front of the culverts and installed a
sump pump to drain the area. The culverts were capped several weeks later.
A Warning Notice was issued in response to the August 1990 discharge by FDER and was sent on

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Page 76
September 7,1990. A Consent Order was drafted requiring the facility to take the necessary steps to
prevent further violations of State water quality standards (e.g., treatment prior to release, preventing the
release of turbid waters). In addition, the facility was required to submit a feasibility study identifying
methods to prevent any future unpermitted discharges to waters of the State. The elevation of a
perimeter road at the site was raised to halt the flow of the discharge to the creek.
References:
Florida Department of Environmental Regulation, Office of the Northeast District. State of Florida Department
of Environmental Protection, Complainant, vs. Associated Minerals (USA), lncv Respondent, Consent Order- 1st Draft, OGCCaseNo.
90-1753.
Florida Department of Environmental Regulation. Interoffice Memorandom from Jay Carver to Files. January 13,
1982.
Florida Department of Environmental Regulation. Interoffice Memorandum from Jay Center to Mary Jean O'Neil, with
attached Performance Audit Inspection Report. January 21,1985.
U.S. Environmental Protection Agency Region IV, Water Compliance Unit, Environmental Compliance
Branch. Letter from Ronald L. Barrow to Steve Gilman, Associated Minerals (USA)lnc* with attached Compliance Evaluation
Inspection. November 5,1990.

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Page 77
Bartow Phosphate Complex:
"Ground Water Contaminated at CF Complex"
Waste and Material Management Practices: The Bartow facility gypsum stack receives phosphogypsum in
slurry form, a waste from the phosphoric acid production process. The slurry is pumped to
impoundments located on top of the stack, where the gypsum is allowed to settle. The liquid is either
directly removed from the settling pond and sent to a cooling pond or collected in seepage ditches that
circumscribe the gypsum stack. In 1993, portions of the gypsum stack were as high as 120 feet.
The Bartow Chemical Complex is underlain by three aquifers: (1) the surficial aquifer system which
underlies essentially all of Polk County and is utilized primarily for domestic and low volume irrigation
uses; (2) the intermediate aquifer system which is semi-confined to confined throughout most of Polk
County and is used mainly for low-volume irrigation wells; and (3) the Floridan aquifer which is generally
1,000 feet thick and can be found starting at depths of approximately 200 feet. The Floridan is the major
source of potable water in Polk County and central Florida.
Ground water quality data collected from a monitor well located near the facility boundary in August
1984 showed exceedances in the surficial aquifer over state limits for eight constituents.
Type of Impact/Media Affected: The exceedances in the surficial aquifer of State limits were for the following
constituents (Florida standards are shown in parentheses): arsenic, 1.1 mg/l (0.05 mg/l); cadmium,
0.024 mg/l (0.01 mg/l); chromium, 1.7 mg/I (0.05 mg/l); sodium, 2,090 mg/l (160 mg/l); fluoride, 4,780
mg/l (1.4-2.4 mg/l); gross alpha, 5,830 pCt/I (15 pCi/l); radium 226/228, 7.5 pCi/l (5 pCi/i). Ground water
samples collected quarterly between 1989 and 1990 showed similar values. Maximum concentrations
observed in these samples were as high as 1.8 mg/l of arsenic, 0.38 mg/l of cadmium, 3.0 mg/l of
chromium, 0.15 mg/l of lead, 2,530 mg/l of sodium, 4,960 mg/l of fluoride, 6240+/-500 pCi/l of gross
alpha, and 18+/-1.7pCi/l of radium 226/228.
As part of a monitoring program implemented to assess contamination, water quality data collected
between 1992 and 1996 at wells located approximately 1,750 feet from the gypsum stack toe and 1,250
feet from the gypsum management system toe have shown ground water impacts. For example, well
SW-11 in March 1996 showed a pH of 5.17, sodium at 698 mg/l, sulfate at 2,950 mg/l (The Florida
Department of Environmental Protection (FDEP) secondary drinking water standard is 250 mg/l), gross
alpha at 62.0+/-21 pCi/l, and radium 226/228 at 9.6 pCi/l.
Regulatory ActionfResponse: FDEP issued a warning Notice in July 1985. CF Industries submitted a request
for an extension of its Zone of Discharge in January 1987. The zone of discharge is defined in state
regulations as the volume underlying or surrounding the phosphogypsum stack or cooling pond, and
extending to the base of a specifically designated aquifer within which an opportunity for the treatment,
mixture, or dispersion of wastes into receiving ground water is afforded. FDEP denied the extension
request in March 1990. A Consent Order was executed in July 1991. As part of the conditions of the
Consent Order, CF Industries agreed to pay the sum of $44,800 to the FDEP Pollution Recovery Fund in
settlement. CF Industries also agreed to install a slurry wall along the north property line as an interim
remedial measure. Finally, CF Industries agreed to take corrective actions to mitigate the ground water
impacts.
As part of the mitigation action plan, CF Industries presented a Contamination Assessment Plan
which was approved by FDEP in July 1992, a Quality Assurance Project Plan which was approved in
December 1992, and a Contamination Assessment Report which was approved in June 1995. The
Consent Order was amended in November 1995 to allow for alternative options to the slurry wall. One
such proposal included capping of the northern section of the gypsum stack, following the criteria
established in 17-673, FAC, a run-off management system, and an east-west trending cut-off ditch to
isolate the northern section from the rest of the stack. The goal of these measures was to reduce the

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source of contamination.
In October 1995, CF Industries presented a Feasibility Study in which a monitoring-only plan was
proposed for the area beyond the facility's zone of discharge. Additional ground water and surface water
data from the Skinned Sapling Creek, a Class III surface water stream, presented in a July 1996
summary report, indicated impacts to ground water but no impacts to surface water.
References:
Andaman & Associates. Letter from Rajendra K. Shrestha and Nadim F. Fuleihan to Parker Keen, CF Industries, Re: Amendments
to Conceptual Interim Remediation Plan, CF Industries, lncv Bartow Phosphate Complex, Polk County, Florida. September 10,
1993.
Ardaman & Associates. Letter from John P. Bunch and Nadim F. Fuleihan to Craig Kovach, CF Industries, Re: Water Quality Data;
Bartow Phosphate Complex. June 11, 1996.
CF Industries. Letter from Parker W. Keen to Sam Zamani, FDEP, Re: Summary of Meeting with DEPat CF Industries and
Amendment to the Conceptual Interim Remediation Plan. September 13,1993.
CF Industries. Letter from M. Lyme Vadelund to Sam Zamani, FDEP, Re: Modified Interim Remedial Action Plan; Bartow Phosphate
Complex (Consent Order 90-1396). July 15,1994.
Florida Department of Environmental Protection. Consent Order90-1396. The State of Florida Department of
Environmental Regulation v. CF Industries, Inc. July 19,1990.
Florida Department of Environmental Protection. Letter from Nancy Deskins to Parker Ken, CF Industries, Re: Bartow
Phosphate Complex, Conceptual Interim Remediation Plan. July 22, 1993.
Florida Department of Environmental Protection. Memorandum from Thomas Douglas to Sam Sahebzamani, Southwest
District, Re: CF Industries IRAP; Bartow Phosphate Complex Consent Order 90-1396. September 7, 1993.
Florida Department of Environmental Protection. Amendment to Consent Order 90-1396. The State of Florida
Department of Environmental Regulation v. CF Industries, Inc. November 2,1995.
Florida Department of Environmental Protection. Memorandum from David Clowes to Vishwas Sathe, Re: Feasibility
Study (FS), per Consent Order No. 90-1396. October 27,1995.
Florida Solite Company:
"Contaminated Discharge Enters Marsh and Creek"
Waste and Material Management Practices: Previously, raw clay, slate, shale, sand, dust, and other materials
were extracted using a dragline at an on-site mine approximately 3,000 feet from the process area. The
materials were transported to the raw feed storage area in dump trucks. In the feeder, the materials
were cut into lumps and fed to a conveyor system, which transported them to the kilns. The kilns used
hazardous and non-hazardous waste fuel sources. Water sprayers were used with the wet scrubbers on
the kilns to cool and condense gases and lightweight aggregate kiln dust (LAKD). The scrubber water
was discharged to the Scrubber Pond. After further processing of the clay, the product was stored in
piles near the Scrubber Pond and was sprayed with water which flowed to the Scrubber Pond by
overland flow. Under high flow conditions, the Scrubber Pond was designed to discharge to an Overflow
Pond, a 21-acre surface impoundment that contained storm water, scrubber water, and sediment soils.
In April, June, July, and October 1991, heavy rainfall caused the Overflow Pond to discharge
scrubber water, sediment soils, and storm water through the emergency spillway to an adjacent marsh.

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Type of Impact/Media Affected In 1990 sediment samples of the Scrubber Pond, which enters the Overflow
Pond, indicated that hazardous constituents, such as lead, PCB-1260, seven extractable organic
compounds including napthalene and ethyldimethylbenzene, and five purgeable organic compounds
including ethyl benzene and ethylmethylbenzene, were present. The volumes of the discharges are not
known, but the elevations of overflows were recorded. The pH following the April 1991 discharge was
monitored. However, the data were reported as a range, including a pH from 2.98 to 10.41, without
mean or median values. In a 1992 report, ground and surface water contamination were reported as a
result of the acidic releases in April. The discharge reached Black Creek. Data on concentrations of
constituents in Black Creek and the affected marsh were not documented in the files reviewed.
However, the Administrative Order on Consent indicated that the hazardous constituents from the
Overflow Pond may have been carried to the marsh.
Regulatory Action/Response: A Warning Notice (No. WN91-0028-IW10-NED) was issued following the April
1991 discharge because Florida Solite was unauthorized to discharge contaminated process water and
storm water from the Overflow Pond, and the discharge violated surface water quality standards for pH.
In addition, an Administrative Order on Consent was issued by the U.S. EPA requiring the facility to (1)
perform confirmatory sampling to identify and investigate solid waste management units and areas of
concern that may have released hazardous wastes, (2) submit to a RCRA Facility Inspection to
determine the nature and extent of the releases, (3) conduct a corrective measures study to identify
alternatives to prevent, mitigate, or remediate any releases, (4) implement any corrective measures
selected by EPA, and (5) implement any other activities to correct or evaluate potential impacts on
human health or the environment. The progress of these requirements was not noted in the files
reviewed.
References:
Boehnke, D.N. Cement Kiln Incineration of Hazardous Wastes and the Solite Corporation of Florida. Jacksonville University.
1992.
Florida Department of Environmental Protection. Hazardous Waste Inspection Report. May 29,1996.
Florida Department of Environmental Regulation. Warning Notice (No. WN9I-0028-IW10-NED). June 10,1991.
Florida Solite Company. Latter from Tony Saunders to Robert Leech, Florida Department of Environmental Regulation. May
19, 1991.
U.S. Environmental Protection Agency Region IV. Administrative Order on Consent (U.S. Environmental Protection
Agency Docket No. 95-05-R), In the Matter of Carolina Solite Corporation d/b/a Florida Solite Company.

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Fort Meade Mine:
"Phosphate Pipeline Spills to Peace River Tributary"
Waste and Material Management Practices: At the Ft. Meade Mine, draglines remove ore from mining areas
and water is added. The slurried phosphate matrix is piped to a washer plant for sizing and testing prior
to sending it to the beneficiation plant. Tailings are used for reclamation by pumping them to fill voids
left by the mining of phosphate. Tailings also are used for settling pond construction.
On October 8,1992, a failure of a 16-inch diameter pipeline was detected by an operator. The
pipeline was part of a pumping system used to transport phosphate slurry from the active mining
operation to the beneficiation facility approximately five miles away. Once detected, the pumping
system was shut down and the area inspected for possible spillage. The spillage was reported to be
limited to a railroad ditch that parallels the pipeline. The inspector did not notice that the ditch eventually
drained to a box culvert and entered a tributary to Peace River, a Class III waterbody. An estimated
100,000 to 200,000 gallons of slurry were released.
Type of ImpactfMedia Affected: The Florida Department of Environmental Protection (FDEP) personnel took
water quality samples on October 8 and 9 at points upstream and downstream of the spill area. Total
phosphorous was as high as 9.5 mg/l (compared to background levels of 1.0 mg/l) in areas downstream
of the spill. Iron levels at two sampling stations downstream from the spill were 1.28 and 1.09 mg/l,
above the State standard of 1.0 mg/l. Gross alpha levels were as high as 72 pCi/l, in violation of the 15
pCi/l State standard. One station showed radium 226/228 levels of 7.3 pCi/l, above the 5 pCi/l standard.
Turbidity levels measured by Cargill in the affected tributary, 150 feet upstream of the creek mouth to
Peace River, were as high as 410 Nephelometric Turbidity Units (NTU) and dropped to 14 NTU on
October 12. The total suspended solids (TSS) level at that station was 477 mg/l on October 8, above the
NPDES permit daily maximum of 60 mg/l.
Regulatory Action/Response: Two warning letters were submitted by FDEP on December 23 and 28,1992.
Remedial actions started on October 8 by placing over 200 staked hay bales in various locations across
the tributary. On October 10, cleanup activities were initiated, including sediment extraction with hand
tools from the banks of the tributary, sediment removal with heavy equipment from the railroad right of
way, culvert and road cleanup with water tankers and vacuum trucks, and sand bag placement across
the tributary near the mouth of the Peace River to hold back any slurry laden waters in the event of a |
large rainfall. Over $45,000 was spent in cleanup related activities.
Other initiatives taken at the mine included a pipeline inspection program, installation of emergency
stop buttons in the pit control center, and impact release devices upstream of booster pumps to relieve
excess pressure in case of a water hammer. Over $87,000 was spent on these and related initiatives to
prevent future incidents of a similar nature.
References:
Cargill Fertilizer. Draft Environmental Incident Report, January 12,1993.
Florida Department of Environmental Protection. Memorandum fromKathy Hicks to Vishwas Sathe, Industrial Waste
Compliance/Enforcement Re: Cargill Slurry Spill Results; Polk County. November 24,1992.
Florida Department of Environmental Regulation. Warning Latter No. 92058-DF53SWD. December 23,1992.
Florida Department of Environmental Regulation. Warning Latter No. 82-0041-IW53SWD. December 28,1992.

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Page 81
Highland Mine:
"Contaminated Storm Water Enters Tiger Branch Creek"
Waste and Material Management Practices: E.I. DuPont de Nemours and Company, Inc. (DuPont) operates a
heavy mineral sands mining and mineral processing facility called the Highland Mine. Heavy mineral
sands are extracted and processed to produce titanium dioxide, a white pigment. Mining wastewater and
contaminated storm water generated at the mine site are treated at the on-site wastewater treatment
facility. The treatment process includes acidification with ferric chloride or sulfuric acid for flocculation of
colloidal material, settling in a series of 13 sedimentation basins and pH adjustment stations,
neutralization with hydrated lime to a pH between 6.0 and 8.5, and additional settling. The treated waters
are discharged through a Parshall flume to Boggy Branch, which connects with the North Fork of Black
Creek, a navigable water. Both Boggy Branch and the North Fork of Black Creek are Class III Florida
waters which are for recreation and propagation and maintenance of a healthy, well-balanced population
of fish and wildlife (Ch. 17-3.161, FAC).
Beginning on November 15,1995, an unreported and unpermitted surface water discharge of
partially treated (water had undergone some settling and treatment) storm water occurred due to
inadequate berm and swale. Information on the construction, height, or maintenance of the berm and
swale was not available in the files reviewed.
Type of Impact/Media Affected: The unpermitted discharge of contaminated storm water to Tiger Branch
Creek exceeded State surface water quality standards for pH and turbidity (FAC 62-302.530). Sampling
by the Florida Department of Environmental Protection (FDEP) on December 6,1995, indicated that the
pH was 5.6 and the turbidity was 114 Nephelometric Turbidity Units (NTUs). At the reference site, pH
was 6.6 and turbidity was 0.8 NTU. In addition, conductivity in Tiger Branch Creek was 47 umhos/cm,
versus 35 umhos/cm at the reference site. The flow of the discharge was estimated at approximately
100 gallons per minute (gpm) and was continuous for 11 days.
Regulatory Action/Response: A complaint was received by FDEP on December 1,1995, from an officer of
the Florida Game and Fresh Water Fish Commission regarding an observed unpermitted surface water
discharge.
A Consent Order was issued requiring DuPont to fill the berm and swale with clean fill and then
compact the area to completely eliminate the release of residual contaminated waters. DuPont Highland
also was required to prepare a site assessment report to address all outfall structures within the facility
and throughout the property. In addition, monthly inspections and reports of the perimeter and internal
discharge structures were required. A settlement payment of $4,100 was made according to the Consent
Order.
References:
Florida Department of Environmental Protection. Interoffice Memorandum from Daniel Hull, Industrial Wastewater
Section, to Ernest £. Fray. December 22, 1995.
Florida Department of Environmental Protection. Letter from Daniel Hull Industrial Wastewater Section, to David £
Wright, EJ. DuPont de Nemours & Co„ Inc. December 11,1995.
Office of the Northeast District. State of Florida Department of Environmental Protection, Complainant vs. EJ. DuPont de
Nemours & Co* Incv Respondent Consent Order. OGC Case No. 9&2905.
Office of the Northeast District. State of Florida Department of Environmental Protection, Complainant, vs. EJ. DuPont de
Nemours & Cow Incv Respondent. Notice of Violation and Orders for Corrective Action. OGC Case No. 90-0517.

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Page 82]

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Highland Mine:
"Release of Turbid Wastewater Results
in Siltation and Fish Kill"
Waste and Material Management Practices: E.I. DuPont de Nemours and Company, Inc. (DuPont) operates a
heavy mineral sands mining and mineral processing facility called the Highland Mine. Heavy mineral
sands are extracted and processed to produce titanium dioxide, a white pigment. Mining wastewater and
contaminated storm water generated at the mine site are treated at the on-site wastewater treatment
facility. The treatment process includes acidification with ferric chloride or sulfuric acid for flocculation of
colloidal material, settling in a series of 13 sedimentation basins and pH adjustment stations,
neutralization with hydrated lime to a pH between 6.0 and 8.5, and additional settling. The treated waters
are discharged through a Par-shall flume to Boggy Branch, which connects with the North Fork of Black
Creek, a navigable water. Both Boggy Branch and the North Fork of Black Creek are Class III Florida
waters which are for recreation and propagation and maintenance of a healthy, well-balanced population
offish and wildlife (Ch. 17-3.161, FAC).
On February 10,1990, a discharge of highly turbid industrial wastewater (from the dredge pond)
mixed with storm water occurred. The water was overflowing from a system of settling ponds and
entering Tiger Branch, a tributary to Boggy Branch and the North Fork of Black Creek. The discharge
was a result of a culvert being plugged by a build-up of sediment. The duration of the discharge is not
known, however, it had ceased by February 15,1990.
From June 9,1990, through September 30,1991, discharge of process water without a NPDES
permit occurred. An investigation by the Florida Department of Environmental Regulation (FDER)
personnel indicated that the discharge was not from the permitted outfall but was from the process water
perimeter ditch. Seepage from the process water perimeter ditch to the south of the North Arm of Boggy
Branch formed a small creek outside, but parallel to, the process water perimeter ditch. An additional
discharge occurred from seepage along the toe of the levee surrounding ponds 11,12, and 13 which
entered a perimeter ditch north of the ponds. This perimeter ditch was not designed to carry process
water. It discharged to a channel which entered the bay head. Just outside the facility property
boundary, the two unpermitted discharges along with two other small creeks from the bay head joined to
form a single stream before entering Boggy Branch.
Type of Impact/Media Affected: A Florida Fish and Game Officer notified DuPont of the discharges after
which FDER received a telephone notification from DuPont on February 14,1990, of a storm water
discharge to Tiger Branch. Following the notification, St. Johns River Management District personnel
sampled the containment lagoon, which indicated turbidity violations. Turbidity was greater than 200
Nephelometric Turbidity Units (NTUs) whereas, at a reference site, turbidity was only 2 NTU. On
February 16,1990, DuPont again assured FDER that the discharge consisted only of storm water.
During a mine inspection by FDER on February 29,1990, FDER was told that the storm water had
mixed with untreated industrial wastewater before draining from the Mine and entering Tiger Branch.
This discharge violated Section 376.302 F.S., which prohibits the discharge of pollutants into or upon any
waters of the State and/or violates a FDER standard. The turbid discharge affected approximately 25
miles of a high quality river system. Further study of the area indicated that Boggy Branch was being
affected by deposition of materials in the stream bed, including alumina from the mine, silt, and rotting
material as thick as 1.5 to 2.5 feet.
A noticeable change in the water quality of the North Fork of Black Creek occurred around June 11,
1990. No significant rainfall had occurred in the area that would contribute to run-off, and DuPont had
not recorded a discharge since June 7. However, water was flowing (as described above) from the area
of the Highlands Mine into Boggy Branch. Sampling by FDER from June 10 to 18,1990, indicated that
this water had a significantly lower pH, higher sulfuric acid content, and higher conductivity than the
background levels in Tiger Creek and the North Fork of Black Creek. The pH of the seepage in the

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Page 84
channel and several downstream sampling locations ranged from 3.3 to 5.1, however, the permit
specifies that effluent pH should not fall below 6.0. Specific conductivity at the same sampling locations
ranged from 270 to 620 umhos/cm, in contrast to a range of 28 to 68 umhos/cm in upstream reference
areas. Sulfate, which was zero to six mg/l in the upstream areas, ranged from 116 to 295 mg/l at the
sampling locations.
The impacts on Boggy Creek included destruction of all life forms in the stream as far as 10 miles
downstream of the permitted outfall, including the benthic community and at least 1,368 fish. Species
removed from Boggy Branch as a result of the unpermitted discharge included redfin pickerel, spotted
sunfish, yellow bullhead, lake chubsucker, pirate perch, flier, dollar sunfish, gambusia, and brown
bullhead. On June 9, at a popular swimming hole downstream of the mine, at least two dozen dead
bream and bass were noted. Fish population samples on June 26,1990, yielded only one fish in the
sample area - a yellow bullhead of three inches in length. Terrestrial and wetland ecosystems also were
affected by the impact on Boggy Branch because plants and animals depend on the water and food
provided by the stream. In addition to the human health impacts from the polluted waters, such as the
eye and skin irritation experienced by children swimming in the water as reported in The Flordia Times-Union,
the discharge impaired the recreational enjoyment provided by the stream. Further study of the area
indicated that Boggy Branch was being affected by deposition of materials in the stream bed, including
alumina from the mine, silt, and rotting material as thick as 1.5 to 2.5 feet.
Regulatory Action/Response: As a result of the February 10,1990, discharge, FDER issued a Notice of
Violation and Orders for Corrective Action on April 11,1990. The Notice of Violation required DuPont to
cease all discharges expected to cause a violation of water quality minimum criteria and standards in
FAC Ch. 17-3 and to install and implement any actions needed to cease these discharges.
In response to the June 1990 to September 1991 discharges, FDER received and investigated a
complaint of a fish kill in the Nortb Fork of Black Creek from citizens of Clay County, Florida, on June 9
and 11,1990, respectively. An Administrative Complaint was issued to DuPont by U.S. EPA Region IV
for discharging without a valid NPDES permit, in which 476 violations of the Clean Water Act are
alleged. A Consent Agreement and Order Assessing Administrative Penalties were issued. DuPont was
ordered to pay $86,333 to U.S. EPA Region IV for alleged violations of the Clean Water Act.
DuPont began to pump the discharge in the north channel back into the neutralization ponds ten
days after the discovery. However, sheet flow from the south side of the North Arm of Boggy Branch
continued until the perimeter ditch construction project was completed. The discharge was treated with
caustic for neutralization. DuPont also applied for a NPDES permit modification to add a new discharge
point at the unpermitted outflow.
References:
Florida Department of Environmental Regulation. Consent Order (OGC Case No. 90-1096), FDER, complainant vs. EJ.
DuPont de Nemours and Co., Respondent
Florida Department of Environmental Regulation. Interoffice Memorandum from Bob Leetch to Files. March 6,
1990.
Florida Department of Environmental Regulation. Interoffice Memorandum from Steve Swann to Jerry Owen, Water
Programs Administrator. June 13,1990.
Florida Department of Environmental Regulation. Memorandum from Gary Byeriey, Fisheries Biologist to Ernie Fray.
June 10,1990.
Florida Department of Environmental Regulation. Interoffice Memorandum from Steve Swann to Richard Drew,
Wastewater Facilities Administration Section. March 25,1991.
Florida Department of Environmental Regulation. Memorandum from Gary Byeriey, fisheries Biologist to Steve Swann.

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M"JWWWWWWWWAWJWWWWWWJ^^
!		Page
July 17,1990.
Florida Department of Environmental Regulation. Notice of Violation and Orders for Corrective Action 10GC Case No.
90-0517), FDER, complainant, vs. EJ. DuPont de Nemours and Co* Respondent.
Florida Department of Environmental Regulation-Resource Management. Memorandum from Carolyn INirz to
Wayne Flowers, FDER-Legal Services. February 26,1990.
Strieder, B. "DER probes Black Creek Fish Kill." The Florida rums-Union. June 12,1990.
U.S. Environmental Protection Agency Region IV. Administrative Complaint. In the Matter ofEJ. DuPont de Nemours &
Co* Inc. Docket No. CWA-N 92-518.
U.S. Environmental Protection Agency Region IV. Consent Agreement and Order Assessing Administrative Penalties. In
the Matter of EJ. DuPont de Nemours & Co* Inc. Docket No. CWA4V 92-518.

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Page 86
Florida
Hopewell Phosphate Mine:
"Mine Water Spill Damages Wetlands and Alafia River"
Waste and Material Management Practices: Mined phosphate ore consists of about one-third phosphate,
one-third sand, and one-third clay. During the beneficiation process at Hopewell Mine, the clay and sand
are removed and the phosphate is recovered for further processing. The sand is stockpiled and
frequently used in reclamation projects. The clays are slurried and routed to the settling basins. After
the clay settles, the water is decanted and reused by the plant to slurry more clay. If the basin takes on
more water than is required for efficient operations, excess water is discharged through permitted
outfalls. Discharged water must meet Florida Class III water quality standards.
The Hopewell Mine operates two clay settling ponds, HL-1 and HL-2. On November 19,1994, the
earthen berm immediately surrounding the spillway discharge structure in the southeast comer of the
dam failed along a section of approximately 100 feet. Approximately 482 million gallons of water were
lost, and most of it traveled over adjacent private property to the North Prong of the Alafia River, which
feeds into Tampa Bay. The incident occurred at pond HL-2, a pond of approximately 191 acres with
11,600 linear feet of dike embankment, that entered into operation in July 1994. The crest elevation for
the perimeter dike is 130.0 feet and the impoundment has a maximum design fluid elevation of 125.0
feet. The clay settling area HL-2 received a construction permit from the Florida Department of
Environmental Protection (FDEP) in January 1994, and was built after the enactment of Chapter 62-672,
FAC, that regulates construction of earthen dams.
Type of Impact/Media Affected: The spilled effluent affected nearby wetlands where channels were scoured at
least 10 feet deep, wetland forest trees were laid flat by the force of the flow, and up to several feet of
clay and sand were deposited. At least 1.74 acres of wetlands needed restoration. The spill also
affected nearby private property, including a small bridge, a culvert, two crossings, and a pond weir.
Water quality data indicated turbidity and total suspended solids (TSS) exceedances of State water
quality standards at several sampling points in the Alafia River. Samples taken at the Alafia River,
approximately eight miles downstream from the Hopewell Mine, indicated that turbidity rose as high as
308 Nephelometric Turbidity Units (NTUs) at SR39. Turbidity returned to less than 29 NTUs about 24 to
36 hours after the incident. TSS at the same sampling point on the Alafia River peaked at 330 mg/l,
whereas the maximum daily standard is 60 mg/l.
Regulatory Action/Response: On November 21,1994, the Hillsborough County Environmental Protection
Commission (HCEPC) issued a Warning Notice for unpermitted turbid water discharges to the North
Prong of the Alafia River resulting in turbidity and siltation within the riverine flood plains. A second
Warning Notice was issued by HCEPC for impacts to both herbaceous and forested wetlands. FDEP
also issued a Warning Letter on November 23. The clay settling area HL-2 was repaired and received
recertification on April 7,1995. In June 1995, IMC-Agrico submitted for review an Emergency Response
and Contingency Plan for dam failure cases. A Consent Order was signed between HCEPC and
IMC-Agrico on August 9,1995. As part of this Consent Order, IMC Agrico was required to restore 1.74
acres of wetlands, perform restoration work to affected private properties ($30,000), and contribute
$110,000 to the Hillsborough County Pollution Recovery Fund. Restoration of the wetlands started in
May 1996.
References:
Florida Department of Environmental Protection. Permit/Certification IC29-239858. Project Construction of Clay
Settling Area HL-2 for the Hopewell Mine. January 24,1994.

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Florida Department of Environmental Protection. Warning Latter No. WN94-0040IW29SWD. November 23,1994.
Hillsborough County Environmental Protection Commission. Consent Order. The Environmental Protection
Commission of Hillsborough County vs. IMC-Agrico Company GP, Inc. August 9,1995.
Hillsborough County Environmental Protection Commission. Inspection Report. IMC-Agrico Company, Hopewell
Mine. November 1994.
Hillsborough County Environmental Protection Commission: Memorandum from Chuck Courtney to Roger Stewart
Re: Status of IMC spill investigation-Ecosystems Management. November 22, 1994.
Hillsborough County Environmental Protection Commission. Memorandum from Woodrow Betchelor to Roger
Stewart, Re: IMC HL-2 Dam Failure, Chronology of Events. November 22, 1994.
Hillsborough County Environmental Protection Commission. Warning Notice No. 17877. November 21,1994.

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IMC Fertilizer, Inc.:
"Gypsum Stack Contaminates Surface Water,
Ground Water, and Soil"
Waste and Material Management Practices: In the 1930's, the land beneath the P-21 gypsum stack was mined
for phosphate as part of the Oakridge Mine. As this mining occurred prior to the development of the
flotation processing technology, only the upper portion (pebble) of the matrix was removed. The lower
matrix zone (concentrate) remains beneath the gypsum. Beginning in the late 1950's waste gypsum
from a chemical processing plant (at what is now the C.F. Industries complex) was deposited in the P-21
gypsum stack. Water derived from the chemical plant also was deposited on-site in a cooling pond
located on the southern edge of the gypsum area.
Placement of gypsum and cooling water was discontinued in 1963. No waste has been disposed of
in this stack since that time. The P-21 gypsum stack did not have any liners beneath it. The cooiing
pond also was unlined.
The site is underlain by three principal hydrogeologic units: (1) the surficial aquifer system,
approximately 25 feet thick in the P-21 area, which underlies essentially all of Polk County and is used
primarily for domestic and low volume irrigation uses; (2) the intermediate aquifer system, which is
semi-confined to confined throughout most of Polk County and is used mainly for low-volume irrigation
wells; and (3) the Floridan aquifer, which is generally 1,000 feet thick and is the major source of potable
water in Polk County. A downward vertical gradient exists between the intermediate aquifer system and
the Floridan aquifer.
Previous activities at the site resulted in contaminated surface water, soils, and ground water in the
surficial aquifer.
Type of Impact/Media Affected: Ground water monitoring reports submitted by the facility between 1987 and
1990 show levels of fluoride, arsenic, gross alpha radiation, and radium-226/228 in excess of State
ground water quality standards, at the edge of the zone of discharge. The zone of discharge is defined in
State regulations as the volume underlying or surrounding the phosphogypsum stack or cooling pond and
extending to the base of a specifically designated aquifer, within which an opportunity for the treatment,
mixture or dispersion of wastes into receiving ground water is afforded. Constituent concentrations were
measured in this period as high as (Florida standards are shown in parentheses) 8.7 ppm of fluoride
(standard 4 ppm), 0.061 ppm of arsenic (standard 0.05 ppm), 0.061 187 pC/L of gross alpha (standard 15
pC/L), and 132 pC/L of radium-226/228 (standard 5 pC/L).
In 1989, IMCF contracted for the preparation and implementation of a preliminary contamination
assessment plan for the investigation of the soil, ground water, and surface water associated with the
north and west portions of the P-21 gypsum area. Surface water samples collected in 1989 and 1990 at
points between 500 and 1,000 feet from the gypsum pile indicated violations of State surface water
quality standards. These samples were collected from small tributaries to Skinned Sapling Creek,
located north of the gypsum area, which were influenced by ground water seepage. Fluoride levels were
observed as high as 20.6 ppm (standard 10 ppm), and pH levels as low as 4.0 (standard 6.0). Ground
water data also indicated State standards contraventions at the edge of the zone of discharge. Gross
alpha values were as high as 87.5+/-27 pC/L; fluoride, 5.5 ppm; and radium-226,19.7+/-4 pC/L
Samples collected at various wells inside and at the edge of the zone of discharge indicated iron, total
dissolved solids (TDS), sulfate, turbidity, gross alpha levels, radium-226/228, and pH levels above State
maximum contaminant levels (MCLs). Maximum values listed in the report were as follows: pH, 11.0;

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Page 89
turbidity, 450 NTU; TDS, 2,900 ppm; sulfate, 1,795 ppm; fluoride, 12.4 ppm; iron, 57.1 ppm; gross alpha
87.5+/-27 pC/L; and radium 226,19.7+/-0.4 ppm. Soil samples showed chromium, iron, zinc, and sulfate
concentrations greater than background.
Regulatory ActionfResponsa: After the gypsum pile was inactivated, the property changed hands several
times with IMCF acquiring the property in 1984 from Estech, Inc. At that time, Estech had already
submitted a ground water monitoring permit application to the Florida Department of Environmental
Regulation (FDER) for review. The ground water permit for the P-21 gypsum area was issued in March
1986. A concern about the potential for storm water run-off from the pile to be entering the tributaries of
Skinned Sapling Creek located to the immediate northwest of the pile prompted an investigation of the
exact nature of the influence of the pile on the stream. IMCF selected a contractor to perform the work.
Based on the results of this work and previous sampling, FDER issued a Warning Notice to the facility
for ground and surface water contraventions. FDER and IMCF signed a Consent Order in March 1993.
The Consent Order required IMCF to implement corrective actions, including appropriate closure of the
P-21 gypsum stack. Also, IMCF was required, in cooperation with the Florida Game and Fresh Water
Fish Commission, to implement a project to improve the fisheries function of a Class II reservoir, and to
provide barrier-free fishing access for physically challenged individuals at Medard Park, at a total cost of
$66,000.
A Contamination Assessment Plan and Quality Assurance Project Plan were presented in May
1993, and were approved in September 1994. In June 1996 a Contamination Assessment Report was
submitted to the Florida Department of Environmental Protection (FDEP) for review and comment.
During mining of the areas to the east and south of the P-21 gypsum stack, the soils and sediments
associated with the location of the cooling pond were removed. Water from this area was pumped to the
Noralyn beneficiation plant. As part of the mined land reclamation of the area, the mined areas,
including the location of the cooling pond, were being filled with sand tailings and covered with
overburden in 1993, according to a report by IMCF.
References:
Florida Department of Environmental Protection. Civil Penalty Authorization, Violator: IMC Fertilizer, Inc. January 7,
1991.
Florida Department of Environmental Protection. Consent Order 81-2456. The State of Florida Department of
Environmental Regulation v. IMC Fertilizer, Inc. March 12, 1993.
Florida Department of Environmental Protection. Warning Notice No. 91-000&W53SWD. February 5,1991.
Geraghty & Miller. Letter from Kenneth Miklos to Vishwas Sathe, FDEP, Re: Status Report for August 1998, IMC-Agrico, Bartow,
Florida, FDEP Consent Order91-2456, P-21 Gypsum Disposal Area-CAP/CAR. September 12, 1996.
Geraghty & Miller. Letter from Kenneth Miklos to Vishwas Sathe, FDEP, Re: Status Report for June 1998, IMC-Agrico, Bartow,
Florida, FDEP Consent Order 91-2456, P-21 Gypsum Disposal Area-CAP/CAR. July 12, 1996.
Geraghty & Miller. Preliminary Contamination Assessment Plan, prepared for IMC Fertilizer. 1990.
IMC Fertilizer. Contamination Assessment Plan, P-21 Gypsum Disposal Area. Submitted to FDEP, May 18,1993.

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Page 90
Resubmitted, August 11,1993.
IMC Fertilizer. Letter from G. Greg Williams to Sam Sahabzamani, Florida Department of Environmental Regulation, Re: FDER Draft
Consent Order 91-2456. April 30,1992

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Page 91
Florida
MMM Nichols Phosphate Mine:
"Unauthorized Mine Water Discharges Affect Alafia River"
Waste and Material Management Practices: The MMM Nichols phosphate mine generates wastewater from
mining and beneficiation of phosphate rock and from storm water run-off. One important activity at the
phosphate mine is reclamation. Reclamation areas are surrounded by earthen berms designed to
channel storm water into a water recovery/recirculation system. Relief pipes are installed in the berms
for discharge.
A series of six incidents of releases of large volumes of turbid water into nearby surface waters
occurred between December 1989 and January 1993. In December 1989,40,000 gallons of turbid water
were released into Guy Branch due to a pipeline failure. In June 1991,400,000 gallons of turbid water
were released into Guy Branch after a heavy rain. In July 1992, in two different incidents, 780,000
gallons and 1,510,000 gallons of turbid water were released into Thirty-Mile Creek. These incidents were
caused by the combination of three unauthorized 12-inch pipes that were placed near the bottom of a
berm separating the North Prong of the Alafia River from a reclamation site located near the northwest
property boundary and by the collapse of portions of the berm in the reclamation area. In January 1993,
in two different incidents, one day apart, 130,000 gallons and 150,000 gallons of turbid water were
released into Thirty-Mile Creek due to inadequate storm water run-off management practices.
Type of Impact/Media Affected: Water quality samples collected on July 21,1992, after the second incident of
that month in Thirty-Mile Creek, indicated very high levels of turbidity and total suspended solids (TSS),
both in violation of the Class III fresh water state standards. Turbidity was 3,000 Nephelometric Turbidity
Units (NTUs). The standard is 29 NTUs above natural background conditions, which is usually around 12
NTU. TSS was 4,650 mg/l, whereas the daily standard maximum is 60 mg/l. Water quality samples
collected in January 1993, after the two incidents of that month at Thirty-Mile Creek, showed turbidity
levels of 129.0 and 300.0 NTUs, respectively. Measurements upstream from where the turbid water
entered the stream, showed turbidity levels of 4.3 and 31.0 NTUs, respectively. TSS levels at the
affected location on those same two days were as high as 10.30 and 233.0 mg/l.
Regnlatory ActionfResponse: The regulatory actions at the State level focused on the 1992 incidents. On
July 17 and 20,1992, the Florida Department of Environmental Protection (FDEP) received complaints
concerning turbidity in the Alafia River near Riverview. Examination of aerial photographs indicated
several reclamation areas near the North Prong of the Alafia River. After inspection of these areas, the
unauthorized pipes were discovered at the Nichols mine. Releases from these pipes along with two
breach incidents at the reclamation area berms on two days were the cause of turbid waters. FDEP
issued a Warning Letter on July 24,1992. EPA Region IV sent a Notice of Proposed Assessment of a
Civil Penalty to MMM Company on August 19,1993. On July 30,1996, FDEP sent to MMM Company a
final draft of a Consent Order for the 1992 incidents. As part of the proposed Consent Order, MMM
Company would pay $100,000 in civil penalties to Hillsborough County and convey a perpetual
Conservation Easement of approximately 80 acres of property to the Southwest Florida Water
Management District, or make an additional payment of $80,000. This Consent Order was under
discussion at the time of preparing this report.
References:
Florida Department of Environmental Protection. Latter from Jeff Hilton toLD. Hinson, MMM, Re: Consent Order
92-2270. July 30, 1996.
Florida Department of Environmental Protection. Memorandum from Kathy Hicks to Vishwas Sathe, Industrial Waste

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								¦¦¦¦•	.SH..	.. 		¦' -——¦"—¦— -¦n.MJon—s 		•'¦¦¦¦'¦ ¦¦"¦¦¦¦¦¦¦	.v,-.	¦
fg 8g.g?.
Compliance/Enforcement Re: Mobil Mining and Minerals - Nichols Mine; Polk County. September 21,1992.
Florida Department of Environmental Protection. Memorandum from Richard Garrity to Carol Browner, Re: Mobil Mining
and Minerals-Nichols Mine; Polk County. January 11,1993.
Florida Department of Environmental Protection. Warning Latter No. 92-0027IW53SWD. July 24,1992.
Mobil Mining and Minerals Company. Letter from LJJ. Hinson to Vishwas Sathe, FQEP, Re: Incident Report Nichols Mine.
July 30,1992.
Mobil Mining and Minerals Company. Letter from LD. Hinson to Vishwas Sathe, FDEP, Re: Incident Report, Nichols Mine.
January 22,1993.
Mobil Mining and Minerals Company. Letter from L.D. Hinson to Vishwas Sathe, FDEP, Re: Warning Letter # 920027IW53
SWD. August 4,1992.
U.S. Environmental Protection Agency Region IV. Latter from W.Ray Cunningham to LJD. Hinson, MMM, Re: Notice of
Proposed Assessment of a Civil Penalty. August 19,1993.

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Mulberry Phosphates Plant:
"Fluoride Contamination at Edge of Authorized Zone of Discharge"
Waste and Material Management Practices: Gypsum generated during the production of phosphoric acid at the
Mulberry plant is stored in two gypsum stack areas designated as the North Stack and the South Stack.
Construction of the North Stack was initiated at the start-up of the plant in the early 1950's. It is located
within a mine pit left from the extraction of phosphate matrix. The North Stack is used for storage of
gypsum during periods of maintenance or while flow is re-routed in the more active South Stack. The
North Stack also is used to store process water to provide additional area for evaporation. The North
Stack is unlined.
Ground water samples from May 1990 indicated contamination due to off-site surface drainage
from the North Stack.
Typo of Impact/Media Affected: Analytical tests on ground water samples obtained from temporary shallow
test wells installed during a June 1990 study indicated concentrations of fluoride that exceeded the 4
mg/l minimum standard provided in 17-3.404, FAC at the edge of the zone of discharge. The zone of
discharge is defined in State regulations as the volume underlying or surrounding the gypsum stack or
cooling pond and extending to the base of a specifically designated aquifer, within which an opportunity
for the treatment, mixture, or dispersion of wastes into receiving ground water is afforded.
Data provided as part of an application for renewal of a permit to operate a wastewater treatment
and disposal system at the site indicated that samples obtained from several monitoring wells on site
exhibited exceedances of primary or secondary water quality standards in 1990. For example, well
MW-6 showed pH levels between 5.5 and 5.7 (standard 6.0); wells MW-3 and MW-6 had periodically
exceeded the secondary standard for iron (0.3 mg/l) with measurements ranging from 3.2-7.0 mg/l and
0.6-1.4 mg/l, respectively; and well MW-1 exceeded the primary State standard for fluoride (which is
more stringent than the Federal standard at 1.4-2.4 mg/l, temperature dependent) with values ranging
from 1.3 to 2.3 mg/l.
Regulatory Action/Response: After receiving the ground water quality samples taken on May 22,1990,
showing the fluoride standard exceedance at the edge of the authorized zone of discharge, the Florida
Department of Environmental Protection (FDEP) issued a Warning Letter on February 5,1991. A
Consent Order was signed on this case on March 19,1992. The Consent Order required the
implementation of a Preliminary Contamination Assessment, and the implementation of appropriate
corrective actions if contamination was found. As a result of off-site surface drainage water quality
impacts, FDEP issued a Consent Order that required a ground water study in the area immediately north
of the North Stack. Based on the conclusions and recommendations of the ground water study, a
seepage intercept drain to control seepage from the North Stack was installed. The Consent Order also
required a payment of $10,000 in penalties.
A Preliminary Contamination Assessment Plan was presented to FDEP on April 1993. The plan
called for the installation of six surficial aquifer monitoring wells, extending to depths of 25 to 30 feet.
The Plan was approved in September 1993. A Preliminary Contamination Assessment Report was
presented in December 1993. A Contamination Assessment Plan was presented in October 1994, along
with a Quality Assurance Plan. After some revisions, both plans were approved in July 1995. The
Contamination Assessment Report was presented in December 1995. FDEP sent comments on this
report in January and April 1996. The report was modified and additional monitoring wells were installed.
By August 1996, the additional contamination report activities requested by FDEP were being developed.
References:
Armac Engineers, Inc. Preliminary Contamination Assessment Plan, FDER Consent Order No. 92-1179. Prepared for

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Mulberry Phosphates, Inc. April, 1993.
Florida Department of Environmental Protection. Consent Order 921179. The State of Florida Department of
Environmental Regulation v. Mulberry Phosphates, Inc. March 19, 1992.
Florida Department of Environmental Protection. Warning Notice No. 91-00061W53SWD. February 5,1991.
Royster Company. Application for Renewal ofPermit to Operate Domestic/Industrial Wastewater Treatment and Disposal
Systems, submitted to FDEP. April 11, 1991.

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New Wales Chemical Complex:
"Sinkhole Forms Beneath Phosphogypsum Stack"
Waste and Material Management Practices: The phosphoric acid plants in the New Wales chemical complex
utilize the wet dihydrate process wherein the phosphate rock is reacted with sulfuric acid to produce
phosphoric acid. The production of phosphoric acid generates gypsum as a byproduct. Approximately
five tons of gypsum are generated for each ton of P205
produced. The gypsum is slurried and transported at approximately 20,000 gallons per minute (gpm) to
the gypsum stack where it is allowed to settle in settling compartments. Water used in the production
process is circulated through a combined mixed/plug flow cooling pond and channels which completely
encircle the gypsum stack. A 345-acre clay settling area is used in the non-contact process water
circulation system.
The gypsum stack was started in 1975 when the plant was opened and spreads over an area of 430
acres with a height of about 200 feet (approximately 100 million tons). The cooling pond and channels
occupy an area of 281 acres. The gypsum stack has no liners and has been used only intermittently
since a new, lined stack was started in July 1993 south of the old stack. The last deposition of gypsum in
the old stack was documented to have occurred in April 1994. Small amounts of radioactive waste
material (e.g., filter cloths, scale from uranium operations, residues from Bartow Uranium
Decommissioning, etc.) were buried in the center, southwest, and southeast toes of the gypsum stack.
On June 27,1994 a site supervisor at the facility noticed a depression within the southwestern
quadrant of the unlined phosphogypsum stack. The depression was approximately 160 feet in diameter
and 180 feet in-depth. Further investigation revealed that the depression was caused by a sinkhole
beneath the stack.
Type of Impact/Media Affected: The gypsum stack is underlain by three aquifers. The surficial aquifer
averages 31 feet thick in the site. The intermediate aquifer is separated from the surficial aquifer by a
confining unit and is about 75 feet thick. The intermediate aquifer is underlain by a relatively low
permeability "Tampa clay" that ranges in thickness from 9 to 14 feet. Under the Tampa clay is the
Floridan aquifer, a 700-foot thick U.S. Drinking Water aquifer. This aquifer is a primary source of
drinking water for Central Florida.
Water quality data collected at a deep production well for the chemical complex, located
approximately 1,000 feet from the stack edge and 3,600 feet from the sinkhole, started to show an
increase in orthophosphate on July 10,1994. The production wells at the plant pump water at a rate of
about 6,000 gpm, effectively creating a zone of capture that encompasses the entire gypsum stack, all of
the plant site, and the entire cooling pond. This zone of capture prevented off-site migration of
contaminants that had affected the surficial and intermediate aquifers due to activities at the complex.
By July 27,1994 concentrations of sulfate (309 mg/l) and total dissolved solids (TDS) (833 mg/l) at
the deep production well had exceeded drinking water standards, and levels were still increasing,
confirming an impact to the Floridan aquifer. By the last week of September, the concentrations were as
high as (pre-sinkhole concentrations are presented in parentheses) 80 mg/l of orthophosphate (5 mg/l),
90 mg/l of sodium (45 mg/l), 480 mg/l of sulfate (255 mg/l), and 1,400 mg/l of TDS (700 mg/l). By March
1995, the sinkhole appeared to have been successfully plugged, and some parameters, particularly
orthophosphate, started to decrease.
Regulatory ActionJReeponee: After the sinkhole was discovered, Florida Department of Environmental
Protection (FDEP) personnel visited the site on June 28,1994. Daily reports were produced on sinkhole
related activities. A perimeter berm was built around the sinkhole to prevent water run-off. A Technical
Advisory Committee (TAC) was organized by FDEP with members from various state and local
agencies. A Warning Letter was sent by FDEP on July 27,1994, for exceedance of drinking water
standards at the deep production well in the plant. The facility and the TAC held periodic meetings to

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Page 96
agree on a course of action. The field exploration program undertaken in the vicinity of the sinkhole was
completed by the end of August and included the drilling of four inclined holes, two vertical holes, a
gyroscopic directional survey of each inclined hole, cross hole seismic surveys, and installation of
piezometers. The results of this program indicated that the diameter of the erosion cavity was on the
order of 90 to 110 feet, and the diameter near the base of the confining unit was on the order of 40 to 60
feet.
A plan of action for sinkhole repair was submitted to FDEP for review on September 30,1994. The
main objective of the plan was to re-establish the structural and hydraulic integrity of the confining unit by
filling the bulk of the erosion cavity with a cement grout mix. The plan was conditionally approved by
FDEP on October 26. Approximately 7,200 cubic yards of grout were used. The estimated cost of repair
work was on the order of six million dollars. Piezometric levels started to rise and some constituent
concentrations started to decline by March 1995. After confirmation that the sinkhole was successfully
plugged, FDEP approved a proposal to fill the sinkhole depression and stress relief cracks with
phosphogypsum slurry on June 20,1995. By December 1995 the sinkhole was fully remediated.
Although the gypsum stack had the capacity to operate until 2001, accelerated closure of the stack was
being considered in January 1996.
References:
Andaman & Associates. Memorandum from JI. Garlanger andN.F. Fuleihan to GJ. Rubin, IMC-Agrico, Re: Response to Request
for Additional Information, Sinkhole Investigation and Remediation at the Original Gypsum Stack at the New Wales Plant, IMC-Agrico
Company, Polk County, Florida. August 31,1994.
Ardaman & Associates. Memorandum from N.F. Fuleihan to GJ. Rubin, IMC-Agrico, Re: Copies of Transparencies Pertaining to
Water Quality Trends as Presented at the September28,1994 TAC Meeting. September 29,1994.
Ardaman & Associates. Memorandum from N.F. Fuleihan to GJ. Rubin, IMC-Agrico, Re: Recommended Plan of Action for
Sinkhole Repeir, Original Gypsum Stack at the New Wales Plant. September 30,1994.
Ardaman & Associates. Memorandum from N.F. Fuleihan to GJ. Rubin, IMC-Agrico, Re: Response to FDEP's Review Comments
on Recommended Plan of Action for Sinkhole Repair, Original Gypsum Stack at the New Wales Plant. October 17, 1994.
Florida Department of Environmental Protection.	Letter from Sam Zamani to GJ. Rubin, IMC-Agrico, Re: Sinkhole
Formation New Wales Chemical Complex. July 5, 1994.
Florida Department of Environmental Protection.	Letter from Sam Zamani to GJ. Rubin, IMC-Agrico, Re: Sinkhole
Formation New Wales Chemical Complex. July 12, 1994.
Florida Department of Environmental Protection.	Letter from Sam Zamani to GJ. Rubin, IMC-Agrico, Re: New Welas

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Page 97
Facility; Sinkhole Remediation. June 20,1995.
Florida Department of Environmental Protection. Letter from Sam Zamani to GJ. Rubin, IMC-Agrico, Re: New Wales
Facility; Sinkhole Remedial Action. October 26,1994.
Florida Department of Environmental Protection. Letter from Sam Zamani to GJ. Rubin, IMC-Agrico, Re: New Wales
Facility, Unlined Gypsum Stack. February 21,1996.
Florida Department of Environmental Regulation. Warning Latter No. 94-0002PGM53SWD. July 27,1994.
Florida Department of Environmental Protection. Memorandum from Sam Zamani to Sam Elrabi, Industrial Wastewater
Program, Hillsborough County Environmental Protection Commission, Re:. IMC-Agrico Company - Summary Report on Sinkhole
Investigation. September 12, 1994.
IMC-Agrico. Letter from GJ. Rubin to FDEP and distribution list. Re: New Wales Gypsum Stack Weekly Sinkhole Update Through
July 10,1994.
IMC-Agrico. Letter from GJ. Rubin to FDEP and distribution list. Re: New Wales Gypsum Stack Weekly Sinkhole Update Through
July26,1994.
IMC-Agrico. Letter from GJ. Rubin to Sam Zamani, FDEP. Re: North Gypsum Stack Sinkhole, New Wales Plant. March 30,
1995.
IMC-Agrico. Letter from GJ. Rubin to Sam Zamani, FDEP. Re: North Phosphogypsum Stack System, New Wales Plant. January
10, 1996.

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' ¦	.	. r. . ...
Florida
Payne Creek Phosphate Mine:
"Settling Pond Break Releases Wastewater
to Local Streams"
Waste and Material Manapment Practices: During the beneficiation process at the Payne Creek Phosphate
Mine, which separates phosphate rock from the mined matrix, large volumes of clay-laden slurry water
are produced. This water is pumped to large above-grade settling ponds to allow the clay to settle from
the water prior to reuse or discharge.
At 2:00 p.m. on October 2,1994, the dike of an inactive settling area (PC-5) was breached over a
section of approximately 150 linear feet, causing very rapid dewatering of the impoundment. All dams
involved were constructed in accordance with Chapter 17-9, FAC, in 1981 and certified for operation in
1982. Field observations by ARMAC staff engineers indicate that the dams were well maintained and
met the current shape and stability requirements of Chapter 17-672, FAC. The cause of the dam failure
was not clearly indicated in the files reviewed, however, "possible weakening" of the dam was suggested.
This release then caused a dike separating the inactive area from an active clay settling area (PC-9) to
breach over a section of approximately 100 linear feet. The liquid from the active area also flowed out
through the inactive area. The water level in PC-9 dropped 14 feet. The total area of PC-9 is
approximately 600 acres. An estimated two billion gallons of mine water were lost from the Payne Creek
Mine and flowed over the CF Industries Hardee Complex Operations, another phosphate mine located
immediately to the south.
The majority of the water released and an undetermined amount of clay material were retained
within CF Industries' mining and reclamation areas. CF Industries had four reclamation areas totaling
approximately 250 acres as well as a 210-acre mined-out area. In addition, the facility had an elevated
mine recirculation water ditch that crosses Hickey Branch. The volume of water spilled, however, was
greater than the holding capacity of these areas. In order to protect the integrity of the mine water
recirculation ditch berm and to reduce the risk of a larger spill, excess water was released through two
permitted outfalls. Approximately 130 million gallons of water were discharged to Hickey Branch, a
tributary of Payne Creek. The remaining natural portion of Hickey Branch, and that portion affected by
the spill, is approximately two miles in length. From its confluence with Hickey Branch, Payne Creek
flows approximately ten miles to Peace River.
Type of Impact/Media Affected: Water quality samples were collected by IMC Agrico in Hickey Branch, Payne
Creek, and the Peace River to be analyzed for turbidity, total suspended solids (TSS), and total
phosphorus (TP). Samples were collected between October 3 and 5,1994. Turbidity levels were as high
as 800 Nephelometric Turbidity Units (NTUs) which is in excess of an assumed background level of 3
NTUs from October 3 to October 5. Rule 17-302.530, FAC, defines a standard of maximum turbidity of
29 NTUs. Turbidity levels further downstream at Payne Creek remained elevated until October 4 and
reached a maximum of 312 NTUs. Turbidity and TSS concentrations decreased progressing
downstream, indicating some settling out of the suspended materials. Turbidity at Peace River was
highest on October 4 at 17 NTUs.
TSS levels at Hickey Branch were greatest at 1,590 mg/l on October 3, decreasing thereafter. The
daily maximum permitted level is 60 mg/l. Maximum levels at the Payne Creek station were 336 mg/l on
October 4. Levels of TP at Hickey Branch reached a maximum of 209 mg/l and at Payne Creek of 14
mg/l. On October 5, TP levels had decreased to 1.6 and 0.83 mg/l at these stations, respectively. Other
water quality parameters, such as fluorides, sulfate, pH, and dissolved oxygen, among others, were not
measured.

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Page 99
Four cells of reclaimed wetland areas at CF Industries were adversely affected by the spill. An
assessment of ecological impacts to Hickey Branch and Payne Creek was contracted by IMC-Agrico and
was performed on November 3,1994. The vertebrate sampling indicated a greater abundance of
individual fish at a reference station than at the test sites. This may indicate that the fish were
temporarily displaced from the habitats affected by the spill, but the data are not conclusive.
Regulatory Action/Response: The Florida Department of Environmental Protection issued a Warning Letter
on December 16,1994. After the breach was contained in IMC-Agrico's ponds, work was started to
remove the clay slurry and water from the CF property and the restored wetlands. Clay removal from
affected wetlands occurred from October 1994 to June 1995. The wetland vegetation was enhanced
afterwards by replacing upland trees, adding other plants, and maintaining water flow to wetlands during
dry periods.
IMC-Agrico has agreed to pay an in-kind environmental mitigation penalty of $110,700 to be used
for construction of facilities at a county park.
References:
ARMAC Engineers, Inc. Letter from Ross T. McGiHivray to Kenneth Williams, IMC-Agrico Company, Re: DEP17-672Analyses
for Earthen Dams. October 12,1994.
Biological Research Associates, Inc. Assessment of Ecological Impacts to Hickey Branch and Payne Creek (Hardee County,
Florida} Resulting from Failure of a Clay Settling Pond Dam. Prepared for IMC-Agrico. March 2,1995.
CF Industries. Letter from James G.Sampson to Henry Domim'ck, FDEP, Re: IMC-Agrico Release of Water on CF Property.
October 5,1994.

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CF Industries. Letter from Jamas G. Sampson to Joann Hearon, FDEP, Re: Release of IMC-Agrico Water Through CF's 001 Outfall.
October 6,1994.
Florida Department of Environmental Regulation. Interoffice Memorandum from JoAnn Harron to Jaff Hilton. October
3,1994.
n
Florida Department of Environmental Regulation. Memorandum from Lisa Carter to Jeff Hilton, Industrial Waste
Compliance/Enforcement He: IMC-Agrico Payne Creek Mine - Polk Co. April 14,1995.
Florida Department of Environmental Regulation. Warning Letter No. WN94-0042IW53SWD. December 16,1994.
IMC-Agrico. Letter from G. Greg Williams to Tom Plouff, Environmental Protection Agency-Region IV, and Henry Dominick, FDEP,
Re: Failure of Clay Settling Area PCS and Subsequent Discharge of Water to Hickey Branch, IMC-Agrico Company - Payne Creek
Operations. October 5,1994.
IMC-Agrico. Letter from SI. Presnell to JeffHilton, FDEP, He: Settlement by Short Form Consent Order in Case of IMC-Agrico
Company's Payne Creek Phosphate Mine. October 15,1996.
IMC-Agrico. Letter from S.L. Presnell to Nan Raggett FDEP, Re: IMC-Agrico Remediation Efforts. July 19,1995.

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Page 101

Potash Corporation of Saskatchewan:
"Hazardous Waste Releases Result in Soil Contamination"
Waste and Material Management Practices: Occidental Chemical Corporation (Oxychem) operates two
phosphate mining and mineral processing facilities near White Springs, Florida - the Swift Creek Mine
and Chemical Complex and the Suwannee River Mine and Chemical Complex. The facilities occupy
144,000 acres, with the Swift Creek operation located five miles west of the Suwannee River operation.
The site was opened in 1964, and mining operations began in 1965 and 1975 at the Suwannee River
Mine and the Swift Creek Mine, respectively. The Suwannee River Mine has been inactive since 1992.
Products include phosphoric acid, sulfuric acid, and granular products, such as fertilizers and animal
feed.
Both facilities consist of a phosphate mine and a chemical complex. To access the phosphate rock,
the area is strip mined using drag lines which remove the clay and overburden. Once removed, the
phosphate ore is placed in a shallow pit and is slurried. The slurry is pumped to a washer plant and
oversized mudballs and pebbles are removed. Beneficiation operations include a phosphatic clay
settling system with recirculation to the mine's hydraulic system. Discharge includes dewatering effluent
and storm water run-off. The chemical complexes include process water treatment areas, gypsum
stacks, cooling ponds, process water recirculation systems, and non-process water retention systems.
Treated process water and contaminated non-process water are permitted to be discharged to Swift and
Hunter Creeks which flow to the Suwannee River. The site also includes rail facilities for rail car loading
with phosphoric acid, two solid waste landfills, and a construction and demolition waste landfill.
During an EPA hazardous waste compliance inspection in May 1996, five waste management
violations were noted, two at the Swift Creek operation and three at the Suwannee River operation.
Type of Impact/Media Affucta± An EPA hazardous waste compliance inspection was conducted at the
Oxychem facilities from May 18 through 20,1993. As a result of the inspection, the following violations
were identified at the Swift Creek operation: (1) overfilling of railcars with phosphoric acid which flows
onto the soil, violating 40 CFR §§ 265.31 and 265.196(c); and (2) dumping unidentified gray scale, black
fines, and yellow solids at the Solid Waste landfill without a hazardous waste determination. Violations
also were noted at the Suwannee River operations: (1) failure to inspect and maintain the unloading
system, resulting in a major spill of molten sulfur due to blockage of the channel transporting molten
sulfur to the launder pit; (2) dumping gray scale at the Solid Waste landfill without a hazardous waste
determination; and (3) dumping over 300 unlabeled drums containing a corrosive compound without a
hazardous waste determination into the Solid Waste landfill.
Regulatory Action/Response:
A Warning Letter was issued by the Florida Department of Environmental Protection (FDEP) on August
11,1993, following the facility inspection, which noted the violations and advised the facility to cease any
operations contributing to the violations. A response to the Warning Letter was written August 19,1993,
in which the Swift Creek facility identified the gray scale as scale from cleaning sulfur storage tanks, the
black fines as blasting material used in tank cleaning or paint removal, and the yellow scale as sulfur
from a spill clean-up. The facility operator refuted the violation at the loading car area because it
involved a release of a product, not a waste, and was, therefore, exempt. However, a hose has been
connected to the last railcar to route the overflows to a recycle sump. At the Suwannee River
operations, tests on some of the corroding drums containing bricks indicated that all passed the Toxicity
Characteristic Leaching Procedure (TCLP) for metals. The drums did contain bricks containing sulfur
which oxidized, resulting in the formation of sulfurous acid, corrosion of the drums, and spillage to the
soil. The facility proposed and FDEP approved treating this area with lime, however, no information in
the files reviewed indicated that lime treatment had been completed. The gray scale at the landfill also

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Page 102
was negative for TCLP metals. The facility is negotiating a Solid Waste Site Closure Permit which will
require an earthen cap and ground and surface water monitoring. The molten sulfur spill at the
unloading area was cleaned up. The facility's response to the Warning Letter was deemed acceptable by
the Department.
References:
Florida Department of Environmental Protection. Letter from Vicky G. Valade to Charles B. flu/ts. Occidental Chemical
Corporation. September 14,1993.
Florida Department of Environmental Protection. Warning Letter (WL93-0412HW24NED! from Ernest £ Frey to Eugene
McNeill, Occidental Chemical Corporation. August 11,1993.
Occidental Chemical Corporation. Letter from Charles B. Pults to Ashwin Patel, FDEP. August 19,1993.
Occidental Chemical Corporation. Letter from Charles B. Pults to Ralph T dine, U.S. Environmental Protection Agency.
June 2,1993.
Occidental Chemical Corporation. Letter from Charles B. Pults to Vicky Valade, FDEP. July 9,1993.
U.S. Environmental Protection Agency Region IV. Letter from Jeffrey T. Pallas to Eugene McNeill, Occidental Chemical
Corporation, including RCRA Inspection Report. June 15,1993.

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Potash Corporation of Saskatchewan:
"Mining Effluent Degrades Nearby Stream"
Waste and Material Management Practices: Occidental Chemical Corporation (Oxychem) operates two
phosphate mining and mineral processing facilities near White Springs, Florida - the Swift Creek Mine
and Chemical Complex and the Suwannee River Mine and Chemical Complex. The facilities occupy
144,000 acres, with the Swift Creek operation located five miles west of the Suwannee River operation.
The site was opened in 1964, and mining operations began in 1965 and 1975 at the Suwannee River and
the Swift Creek Mines, respectively. The Suwannee River Mine has been inactive since 1992. Products
include phosphoric acid, sulfuric acid, and granular products, such as fertilizers and animal feed.
Both facilities consist of a phosphate mine and a chemical complex. To access the phosphate rock,
the area is strip mined using drag lines which remove the clay and overburden. Once removed, the
phosphate ore is placed in a shallow pit and is slurried. The slurry is pumped to a washer plant and
oversized mudballs and pebbles are removed. Beneficiation operations include a phosphatic clay
settling system with recirculation to the mine's hydraulic system. Discharge includes dewatering effluent
and storm water run-off. The chemical complexes include process water treatment areas, gypsum
stacks, cooling ponds, process water recirculation systems, and non-process water retention systems.
Treated process water and contaminated non-process water are permitted to be discharged to Swift and
Hunter Creeks which flow to the Suwannee River. The site also includes rail facilities for rail car loading
with phosphoric acid, two solid waste landfills, and a construction and demolition landfill.
Seven-day chronic toxicity tests on Pimephatespromelas (a minnow) in December 1992, and in January
and December 1993 indicated toxicity in the discharge from Outfall 001 entering Swift Creek. Outfall
001 is permitted to discharge treated process water and contaminated non-process water within permit
limits.
Type of Impact/Media Affected: On August 15,1994, the Florida Department of Environmental Protection
(FDEP) conducted a fifth year inspection of the two Oxychem facilities. The inspection included Toxics
Sampling, Compliance Biomonitoring, Impact Bioassessment, and Water Quality Inspections. The
Toxics Sampling Inspection indicated that no organic priority pollutants or pesticides were present in the
discharge and that levels of metals were not exceeding Class III standards. The Compliance
Biomonitoring Inspections indicated that the effluents were not acutely toxic to the two test organisms.
The Impact Bioassessment Inspection, however, revealed that the benthic macroinvertebrate
community at Swift Creek was moderately impaired and at Hunter Creek was severely degraded due to
changes in water quality as a result of facility discharges. Degradation included decreases in taxa
richness, the Ephemeroptera/Plecoptera/Trichoptera (EPT) index (e.g., only 50 percent of the reference
site value), the proportion of filter feeders, and an increase in the percent contribution of dominant taxa.
Pollution sensitive organisms, such as ephemeropterans and trichopterans, were reduced or eliminated
at both sites (e.g., ephemeropterans were decreased by 97 and 55 percent at Swift Creek and Hunter
Creek, respectively). The algal and periphyton communities at Swift Creek and Hunter Creek,
respectively, were degraded downstream of outfalls due to high nutrient conditions.
The Water Quality Inspection indicated extreme nutrient enrichment in Swift Creek with
concentrations of ortho-phosphate, total phosphorus, and ammonia being higher than those in 95 percent
of other Florida streams. Unionized ammonia from the Swift Creek Mine outfall violated permit limits
(0.0213 mg/L) and Class III water quality standards. Hunter Creek also had phosphorous concentrations
higher than those found in 75 percent of other Florida streams. Dissolved oxygen levels in effluent
entering Swift Creek violated permit limits. The changes in water quality due to the discharges,
particularly the nutrient enrichment, caused the degradation of the benthic communities. In general, the
facility was violating the standard prohibiting imbalances of aquatic fauna and aquatic flora (Rule
62-302.560(29), FAC).

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Page 104
Regulatory Action/Response: A toxicity identification evaluation (TIE) was to be conducted by an Oxychem
contractor to determine the cause of toxicity. It was suspected that the test organisms were ingesting
something in the discharge, such as a bacteria. As of April 24,1995, FDEP had not received the results
of the TIE. In October 1994, chronic bioassays were conducted at the reference site used in the August
1994 tests. All organisms died within 24 hours due to a pH of 4.1. Therefore, the facility requested a
permit modification so the bimonthly toxicity tests would reflect the natural toxicity at the reference site.
FDEP is reluctant to change the permit because toxicity testing permit requirements should not be based
on background conditions. Further information, such as the TIE results, has been requested by FDEP
from the facility, however, this information was not included in the files reviewed.
References:
Florida Department of Environmental Protection, Biology Section, Division of Administrative and
Technical Services. Biological Assessment of Occidental Chemical Corporation, Hamilton County, NPDES HFL0000655, Sampled
August 1994. January 1995.
Florida Department of Environmental Protection. Letter from Leslee A. Williams to Vince Seibotd, FDEP. April 24,
1995.

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Premier Services Corporation:
"Ionic Imbalance in Discharge Causes Toxicity"
Waste and Material Manapment Practices; The company processes seawater to produce a magnesium
hydroxide (Mg(OH)2) precipitate that can be used as a pH-adjuster to precipitate heavy metals in
wastewater treatment.
At this facility, Mg(OH)2 is removed from seawater extracted from St. Joseph Bay and converted to
magnesium oxide. Other raw materials include sulfuric acid and dolomite. The pH of the seawater is
adjusted using concentrated sulfuric acid. It is pumped into an aeration tank to remove dissolved carbon
dioxide. The solution flows to a 300,000 gallon agitated reactor where it is reacted with lime. The
solution then flows to a thickener tank where solids are precipitated and settled. The solid Mg(OH)2 is
pumped through a series of three fresh water wash tanks to remove chlorides and salt impurities. The
"spent" seawater and the fresh water wash water are discharged into a 200 foot by 300 foot brackish
water barge basin on company property which is connected to the Gulf County Canal, a Class III Florida
water entering St. Joseph Bay. Class III waters are to be used for recreation and the propagation and
maintenance of healthy, well-balanced fish and wildlife populations (Ch. 17-3.161, FAC).
Under permit conditions, the facility is required to conduct annual 96-hour static-renewal toxicity
tests on the effluent. The tests originally were performed on the water in the mouth of the barge basin,
but now are performed on effluent from the end of the discharge pipe. Test results from 1992 to 1996
indicated toxic conditions for the test organisms, Mysidopsis bahia and Menidia bBryllina. The toxicity violates
Rules 62-302.530(62), FAC, 62-302.500(1)(d), FAC, and 62-4.244(3)(a), FAC.
Type of Impact/Media Affected: The discharged water had high turbidity, high pH, and an ionic imbalance.
The high pH and very high levels of calcium are thought to be responsible for the toxicity. In 1992 tests,
100 percent mortality of both test organisms occurred within 72 hours. A violation occurs when greater
than 50 percent mortality results during any test. In January and February 1993, acute toxicity of M. Bahia
was observed in pH-adjusted and unadjusted samples in routine and persistence tests. In March 1993,
acute toxicity was noted in M. Bahia in the pH-adjusted samples. In December 1994, acute toxicity was
noted in M. bahia and M. beryl/ina in the pH-adjusted effluent. In the pH unadjusted samples, the LC50 was
lower, at 73.7 percent and 79.8 percent effluent for Af. bahia and M.beryllina, respectively. In 1995, the
LC50 for M. Bahia was slightly lower in pH-adjusted samples, at 74.1 percent effluent. These test results
indicated toxicity due to pH, however, another toxic constituent was possible, as indicated by the
pH-adjusted test results where toxicity was relatively high. Test results from January 1996 on the raw,
undiluted effluent indicated toxicity to the test organisms due to a high pH (9.7). Tests using pH-adjusted
effluent (pH 7.9) indicated toxicity to M. bahia, but not to M. beryllina. These results suggest an additional
toxic constituent. Water quality tests on the effluent found elevated calcium levels, with calcium being
present at 370 percent of expected based on the water's salinity. The Florida Department of
Environmental Protection (FDEP) has observed similar toxicity due to ionic imbalances in the effluent of
reverse osmosis facilities.
A possible impact from the toxic discharge is a change in the macroinvertebrate community. At
one test site, quantitative measures of the macroinvertebrate community health indicated a decrease in
the pollution sensitive taxa. January 1996 tests indicated that the cause of toxicity is both the high pH
level, and an ionic imbalance. The ionic imbalance results because the level of calcium is increased five
times due to the addition of dolime (i.e., calcium), while the level of magnesium is reduced five times
due to the removal of Mg(OH)2.
Replatory ActionlResponse: The facility requested a variance for acute toxicity in their permit because no
technology is available for treating ionic imbalances. FDEP is unaware of any effluent guidelines for
magnesium extraction from seawater. However, because of the acute toxicity of the effluent on test
organisms, FDEP is drafting a Consent Order requiring the facility to develop an appropriate testing
protocol and to conduct tests to determine conclusively that the ionic imbalance and pH are the causes

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Page 106
of toxicity. If the ionic imbalance and pH are identified as the sources of toxicity, FDEP will request that
the facility alleviate these sources. This Consent Order was not included in the files searched, because it
is still being drafted, according to FDEP personnel.
References:
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96Hour Static-Renewal Bioassay Special Studies:
Manidia bervllina and Mvsidopsis bahia dH-adjusted and unadjusted outfall samples December8-12.1994. December 19, 1994.
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96Hour Static-Renewal bioassay Special Studies:
Menidia bervllina and Mvsidopsis bahia pH-adiusted outfall and influent samples January27-31.1993and Mvsidopsis bahia February 1-5,
1993. February 11,1993.
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 9&Hour Static-Renewal Bioassay Special Studies:
Mvsidopsis bahia oH-adiusted outfall sample March 25-29.1993. April 8, 1993.
Alvarez, Lehman, and Associates, Inc. FDER Biomonitoring Program 96-Hour Static-Renewal Bioassay Special Studies:
Mvsidopsis bahia oH-adiusted outfall samples November 28-December3.1995. December 14,1995.
Florida Department of Environmental Protection, Biology Section, Division of Administrative and
Technical Services, Biological Assessment of Premier Services Corporation, Gulf County, NPDES #FL0002607, January 1996.
June 1996.
Premier Services Corporation. Letter from Thomas F. Turpin to William A. Evans, FDEP. April 18,1996.
Wastewater Permit Application and Attachments for Premier Services Corporation (Facility IDS: 1023P01340). April 16, 1996.

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Riverview Chemical Complex:
"Acidic Discharge Kills Fish and Crabs"
Waste and Material Management Practices: The Riverview Chemical Complex maintains a gypsum field
(stack) to manage phosphogypsum generated from the operation of the phosphoric acid plants.
Approximately 90,000 tons of gypsum are deposited in the gypsum field each week. Gypsum is piped to
the stack as a slurry mixture, using a pumping system that includes a 100,000-gallon rubber-lined surge
tank, agitator, pumps, and valves. Water that seeps through the stack is collected in a perimeter drain,
which carries the seepage water to a sump, where it is pumped to a cooling pond.
On October 12,1993, stressed vegetation was found in a storm water ditch located west and
outside of the active gypsum field recycle system. This ditch discharges to Archie Creek, a Class III
water body. The cause of the stressed vegetation was a discharge of untreated wastewater from two,
three-foot diameter, manway access pipes that were unbolted with the covers removed. The access
pipes are connected to underground gypsum stack seepage collection conduits which convey process
water seepage to a lined cooling pond.
Type of Impact/Media Affected: Water quality samples collected at the outfall of the storm water ditch to the
Archie Creek Drainage Canal on October 12, showed pH levels as low as 5.79, fluoride levels as high as
29.9 mg/l, and ortho-phosphate levels as high as 59.1 mg/l. One week later, fluoride levels had dropped
to 1.5 mg/l, and phosphate to 4.1 mg/l. The water quality parameters observed on October 12 exceeded
surface water quality standards. A field survey of the South Archie Creek drainage canal recorded a total
of 110 dead fish and crabs.
Regulatory Action/Response: Upon discovery of the incident, the pipes were replaced and bolted. To prevent
future discharges to Archie Creek, the facility installed a concrete flow structure with a gate valve
activated by a conductivity meter in the stream. The facility also installed berms, a gypsum field critical
alarm system, and a camera surveillance system.
The Environmental Protection Commission of Hillsborough County issued a Warning Notice on
October 19,1993. The Florida Department of Environmental Protection issued a Warning Letter on
October 20,1993. A Consent Order was signed on December 20,1995. As part of the provisions of this
Consent Order, Cargill Fertilizer donated as an in-kind settlement, $37,500 to the Museum of Science
and Industry in Tampa to support a wetlands trail educational project.
References:
Cargill Fertilizer. Letter from Elton Curran to Sam Zamani, Florida Department of Environmental Regulation, Re: Warning Letter
H93-0032IW29SWD; Consent Order 994-3313. March 31, 1995.
Environmental Protection Commission of Hillsborough County. Warning Notice No. 15292. October 19,1993.
Florida Department of Environmental Protection. Memorandum from Lisa Carter to Vishwas Sadie, Industrial Waste
Enforcement/Compliance, Re: Cargill Fertilizer, Inc. - Hillsborough Co. Discharge Evaluation. February 23,1994.
Florida Department of Environmental Regulation. Consent Order 94-3313. The State of Florida Department of
Environmental Regulation v. Cargill Fertilizer, Inc. December 20, 1995.
Florida Department of Environmental Regulation. Warning Latter No.93-0032IW29SWD. October 20,1993.
Lewis Environmental Services, Inc. Field Survey of the Effects of a LowpH Water Discharge into South Archie Creek
Drainage Canal. Prepared for Cargill Fertilizer. Prepared November 1993, Revised December 23,1993.

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Lewis Environmental Services, Inc. Field Survey of the Effects of a LowpH Water Discharge into South Archie Creak
Drainage Canal. Report 2,1.5 Months After Discharge. Prepared for Cargill Fertilizer. December 1993.

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Bethlehem Steel Corporation Sparrows Point Facility:
"Elevated Chlorine Levels in Discharge to Nearby Water Bodies"
Waste and Material Management Practices: The Bethlehem Steel Sparrows Point facility is one of the largest
integrated steel mills in the U.S. It is located near the mouth of the Patapsco River in Maryland. In
addition to steel production, steel products, and shipbuilding operations, the facility includes electric
power generating stations, a railroad system, coke making facilities, and the Humphreys Creek
Treatment Plant. The coke making operation was shut down in 1991. The facility discharges 400 to 450
million gallons per day of wastewater from seven permitted major outfalls along with 40 other outfalls.
The discharges enter the Patapsco River, Bear Creek, and Old Road Bay which are Use I waters of the
state under COMAR 26.08.02.07.F(5).
The facility has discharged from several different outfalls from 1990 to 1992 total residual chlorine
over the non-detectable limit of less than 0.1 mg/l.
Type of Impact/Media Affected: During annual NPDES Compliance Monitoring Inspections from August 1990
to August 1992, total residual chlorine levels at Outfalls 012,013, 017, 018, and 032 were greater than
the less than 0.1 mg/l limit (Exhibit 1).
Exhibit 1
Total Reeidoal Chlorine Levele at Bethlehem Steel Outfalls
Outfall
Total Residual
Chlorine (mgfl)
Date
017
0.25
8/29/90
032
1.3
8/30/90
018
0.3
10/25/90
017
0.35
10/25/90
017
0.4
12/13/90
017
0.4
3/26/91
013
0.15
4/24/91
017
0.1
4/24/91
013
0.1
6/3/91
017
0.5
6/3/91
017
0.6
6/25/91
017
0.3
8/5/91
017
1.5
10/23/91
032
1.1
7/31/92
013
0.4
8/3/92
012
1.3
8/3/92
017
0.1
8/4/92
013
0.2
8/4/92
In addition, on August 3,1992, monitoring point 050 had total residual chlorine levels up to 0.3 mg/l. The
discharge from Outfall 012 had less than 0.1 mg/l on August 4,1992. The facility indicated that the
chlorine reading may have been due to residual bromine which is used in the cooling water system in the
caster building.
Regulatory Action/Response: Following the NPDES Compliance Monitoring Inspections of July and August
1992, a site complaint (SC-0-93-0014) was issued. The facility advised the operators of the salt water

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.'.'.'.'.'.'¦'.'¦T'TJT'jJTrr'xr
Page 110;
chlorination system to reduce the chlorine feed rate and to inspect the system to determine the cause of
the violation. The facility found that the flow rate meter on the chlorinator was stuck, indicating a false
chlorine feed rate. The system was immediately shut down and repaired.
An Administrative Order was issued by the Maryland Department of the Environment (MDE) to
Bethlehem Steel citing unauthorized chlorine discharges at Outfalls 012, 013, 017, 018, and 032 from
August 29,1990, to August 4,1992. Corrective actions included submitting to MDE a detailed plan for
corrective measures to ensure compliance, a schedule for implementation and completion of measures,
and a detailed plan and schedule of measures to ensure compliance with the chlorine limitations. A
payment of $50,000 was made by Bethlehem Steel as part of the Order.
In response to the Administrative Order, Bethlehem Steel described the difficulty of controlling
residual chlorine at outfalls because of the use of treated effluent from the Back River Sewage
Wastewater Station, potable water from the City, and brackish water from the bay. Bethlehem Steel
noted that the distribution system is not linear and water supply is not constant. In addition, the saltwater
required chlorination to prevent biological growth and the potable water is delivered chlorinated.
Bethlehem Steel proposed a one-year study to investigate the conversion of systems from one water to
another to stabilize the demands and chlorine usage, the use of chlorine substitutes such as bromine or
ozone, and the facility requirement at six outfalls for dechlorination units. MDE accepted the study
proposal and the explanation of the system but indicated that once the study was completed, a work plan
to eliminate residual chlorine was necessary. The study began in June 1993, and the first quarterly
report was submitted October 14,1993. The final report was submitted April 6,1994. The facility began
using gaseous chlorination at a reduced feed rate supplemented by liquid bromine during warmer
periods. In addition, chlorine destruct systems were installed at several outfalls. The facility had fully
complied with the Order on August 18,1994.
References
Bethlehem Steel Corporation. Letter from £ B. Hay to James Metz, Waste Management Administration, MDE, Re: NPDES
Permit MD0001201/79-DP-0064and SCO-93-OOI4. September 14,1992.
Bethlehem steel Corporation.	Letter from E.B. Hay to Jamas LHearn, MDE. April 20,1993.
Bethlehem Steel Corporation.	Letter from ErrollB. Hay to MDE. June 18,1993.
Bethlehem Steel Corporation.	Letter from ErrollB. Hay to James LHearn, MDE. July 9, 1993.
Bethlehem Steel Corporation.	Letter form ErrollB. Hay to James LHearn, MDE. August 18,1994.
Bethlehem Steel Corporation. Letter form ErrollB. Hay to James L Hearn, MDE with attached quarterly report. April 8,
1994.
Maryland Department of the Environment. Compliance Sampling Inspection. July 31 to September 22,1992.
Maryland Department of the Environment, Water Management Administration. Amended Complaint and Order in
the case of State of Maryland Department of the Environment v. Bethlehem Steel Corporation. AO-93-0071.
Maryland Department of the Environment, Water Management Administration. Complaint in the case of State of
Maryland Department of the Environment*. Bethlehem Steel Corporation. AO-93-0071.
Maryland Department of the Environment. Letter from James Hearn to E.B. Hay, Bethlehem Steel Corporation, Re:

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Administrative Order and Penalty A0-93-0071. June 21,1993.

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Maryland
Chemetals inc.:
"Toxic Effluents Released from Permitted Outfall to
Arundel Cove"
Waste and Material Management Practices: The Chemetals Inc. facility in Anne Arundel County, in addition to
roasting, acid leaching, precipitation, filtration, and oxidation operations, has a wastewater treatment
system including a neutralization system and settling ponds. Process wastewater, cooling tower
blowdown, and scrubber water from the plant are neutralized in a lime treatment system which is
continuously monitored for pH. Once neutralized, the water is released to a series of settling ponds and
then to Outfall 001. The second pond of the settling system includes a dechlorination system using
sulfur dioxide to dechlorinate the wastewater. The treated wastewater is discharged through Outfall 001
to Arundel Cove, which is a tributary to Curtis Creek. Curtis Creek is classified for water contact
recreation, and for fish, other aquatic life, and wildlife.
Periodically, from 1992 until 1996, bioassay toxicity tests of the Outfall 001 effluent indicated
toxicity to both the mysid and the minnow tested. The cause of the toxicity was thought to be residual
ammonia, manganese, or both. In addition, during an inspection in February 1992, an inspector noted
foaming in the wastewater effluent. During September 1992, Chemetals reported elevated levels of total
manganese in the effluent from Outfall 001 A. In February 1993, the monthly average manganese
effluent was 1.35 pounds per day above the NPDES permit limit. Chemetals claimed the daily maximum
limit was never exceeded and was not certain of the cause.
Type of Impact/Media Affected: The 48-hour definitive bioassays conducted from April 29 to May 1,1992,
indicated the effluent from Outfall 001 was acutely toxic to the mysid (JUysidopsis bahia) but not to the
sheepshead minnow {Cyprinodon variegatus), with the 48-hour LC50 for the mysid being 13.3 percent. The
48-hour daily renewal acute toxicity tests on M. bahia from June 1993 were performed on unaltered
effluent and on manganese stripped effluent to determine if an upgraded wastewater treatment plant
would provide non-toxic effluent. The manganese-stripped sample increased the LC50 from 21.1
percent to 57.0 percent. Although this indicated an improvement, it did not prove to Chemetals that
upgrading the treatment system to remove manganese was a proper solution. The 48-hour, daily
renewal, acute toxicity tests performed in March 1996 indicated that the effluent was toxic to M. bahia with
an LC50 of 74.0 percent effluent, but was not toxic to Palaamonatespugio. Tests from May 1996 indicated
that the effluent was toxic to M. bahia and to P.pugio with the LC50s being 62.0 percent and 67.6 percent
effluent, respectively. The effect of the toxic effluent on Arundel Cove was not documented in the files
available for review.
The first quarter analytical work on the wastewater discharge indicated elevated levels of residual
ammonia in wastewater generated from two plant production processes that operate during the months
of October to March. Residual ammonia may have been responsible for both the toxicity and the
foaming observed in February 1992. Previous aquatic toxicity tests did not indicate concerns with
ammonia content from these processes.
Regulatory Action/Response: The files available for review did not contain any Notices of Violation,
Complaints, or Consent Orders in relation to the toxic effluent. MDE and Chemetals, however, were
corresponding regularly on test results and possible changes to the facility to remedy the problem. An
analysis of flow rates and ammonia content was being conducted on one of the seasonal process to
determine treatment options to reduce aquatic toxicity and eliminate foaming concerns. The site
proposed and implemented an ammonia investigation plan and expected to resolve the ammonia

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problem by December 1993.
The elevated manganese levels in September 1992 were due to dredging of areas of the settling
ponds by an outside contractor hired by Chemetals to increase the retention time in the ponds. This
would increase the settling efficiencies in the ponds. The dredging, however, agitated the settled solids,
increasing the concentration of manganese in the outfall. The facility undertook preventative measures
and reactionary measures to ensure that stirred pond water is not discharged in the future. In addition,
Chemetals planned to reduce the loading of manganese solids to the lime treatment system in 1993 to
improve biomonitoring test results. This would be accomplished by directly removing manganese solids
from the filter in the Nitrate Plant instead of slurrying the materials, allowing them to settle in the ponds,
and later dredging the materials for sale to fertilizer manufacturers.
Chemetals indicated that the higher toxicity noted in May 1996 effluent may have been due to
higher concentrations of effluent. It was not clear from the information available whether the toxicity
levels in March and May 1996 toxicity tests was due to ammonia or another agent. Chemetals
mentioned that a 1:1 dilution would eliminate the toxicity and that this dilution could be incorporated into
their proposed wastewater treatment system. In August 1996, Chemetals was interviewing engineering
firms for the design of the new wastewater treatment system. There was no further information in the
files reviewed indicating the status of the new wastewater treatment system.
References:
Chemetals Inc.	Letter from Lawrence, T.J„ to M. Knott, MDE, Re: Biomonitoring Progress Update. August 30, 1996.
Chemetals Inc.	Letter from Myers, ATV to M. Knott, MDE, Re: Biotoxidty Improvement Action Plan. November 11,1992.
Chemetals Inc.	Letter to M. Knott, MDE. July 28,1993.
Chemetals Inc.	Letter from Lawrence, T. Jw to C. Coates, MDE. March 25,1993.
Chemetals Inc.	Letter from Myers, K* to M.Knott, MDE. October 28,1992.
Chemetals Inc.	Letter from Pratt, AT, to J. Richmond, Re: Industrial Discharge Inspection Report. April 16, 1992.
Maryland Institute for Agricultural and Natural Resources, Agricultural Experiment Station. Letter from

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.vv.w.'.v.'.v.v.'.
PageTlT
Fisher, D. toM. Knott, MDE. May 5, 1993.
Maryland Department of the Environment. Compliance Sampling Inspection of Chemetals Inc. April 26, 1993.
Maryland Institute for Agricultural and Natural Resources, Agricultural Experiment Station. Letter from
Fisher, D., to M. Knott, MDE. May 5,1991.

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Maryland
SCM Chemicals Hawkins Point Plant:
"Batch Attack Lagoon Contaminates Groundwater"
Waste and Material Management Practices: The SCM Chemicals Hawkins Point Plant manufactures titanium
dioxide from two processes: 1) a sulfate process where titanium ores are ground and digested in batch
attack vessels with sulfuric acid; and 2) a chloride process where titanium ore is chlorinated in the
presence of carbon to produce titanium tetrachloride, which is oxidized to produce titanium dioxide.
SCM produces about 70,000 tons per year of the sulfate processed pigment for sale to the paper
industry. The chloride processed pigment is used in paints, paper, and in powdered sugar. Acidic
wastewater is produced from both processes. Add wastes from the chloride process are sold or
neutralized with caustic and lime slurry. The solids from this process settle in a series of lagoons. Most
of the acid wastes from the sulfate process were stored in the Batch Attack lagoon until 1991 when the
site operators built tanks to receive the acid wastewater prior to treatment at the acid neutralization plant.
Currently, the Batch Attack Lagoon is used as a settling pond for batch attack scrubber wastewater.
According to a representative of Maryland Department of the Environment (MDE) Water Management
Administration, a pH probe measures the pH level of the wastewater as it enters the lagoon. When the
pH of the wastewater falls below 2, the wastewater is purposefully diverted from entering the lagoon,
thereby bypassing any treatment system, and is discharged directly to the Patapsco River. Usually, the
sulfate process wastewater is pumped from the lagoon and pH adjusted prior to discharge to the
Patapsco River via Outfall 001.
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-off,
cooling water, batch attack scrubber water, miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles C02 gas produced by SCM's acid
reactions. The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Dorr tank (thickener) drainage from both the sulfate and chloride
processes, as well as miscellaneous floor drainage. The effluent is treated with caustics and lime slurry in
a series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant.
In a November 29,1995, letter to SCM, MDE noted that groundwater quality data suggested that
the Batch Attack Lagoon was contaminating groundwater and possibly surface water. Monitoring wells
located to the north and south of the asphaltic slurry wall indicated that groundwater was extremely acidic
and contained elevated heavy metals. According to MDE, the source of the contamination is the sulfate
process wastes disposed in the lagoon prior to 1991. The facility operated the lagoon under a RCRA
permit prior to 1988. In 1988, SCM personnel asked that its permit application be withdrawn due to its
Bevill exempt status.
MDE Water Management Administration personnel also indicated that in a recent meeting, SCM
personnel had stated that very infrequently a spill or other incident causes the pH of the sulfate process
wastewater to fall below 2, in which case the wastewater is diverted from entering the lagoon, thereby
by-passing the treatment system, and is discharged directly to the Patapsco River. In the past year, a
by-pass of the Batch Attack Lagoon has occurred once for a period of approximately 10 minutes,
according to MDE personnel. In a January, 1997 meeting, a MDE representative expressed concern to
SCM personnel that characteristically hazardous waste was being discharged to surface water. The
facility representative assured MDE that these excursions occur very infrequently.
Type of Impact/Media Affectedb Arsenic, cadmium, chromium, and lead are present in groundwater at levels
above Federal Maximum Contaminant Levels (MCLs). The specific contaminant levels were not

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indicated in the files available for review. The location of nearby drinking water wells and the specific
impact to human health or the environment were not available in the reviewed files.
Regulatory ActionlResponse: The Batch Attack Lagoon was never clean-closed due to the Bevill-exempt
status of its wastestream. In a November 23,1995 letter to SCM, MDE noted that the hydraulic
performance of the slurry wall had not been adequately assessed. MDE asked SCM to verify the
direction of groundwater flow within and outside the slurry wall. MDE recommended that the facility
install additional piezometers along the northern boundary of the slurry wall. MDE also suggested that
additional remedial measures may be required to contain contaminated groundwater from discharging
into the Patapsco River. No response from SCM or further action on the part of MDE was indicated in
the files available for review.
With regard to the possible characteristically hazardous wastewater releases to the Patapsco River,
no further response or action on the part of MDE was indicated in the files available for review.
References:
Leizear, Jim, Hazardous Waste Enforcement Division, Maryland Department of the Environment.
Personal communication. February 3,1997.
McGillen, John, Water Management Administration, Maryland Department of the Environment. Personal
communication. February 3,1997.
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals, Incorporated. May 14,
1990.
Maryland Department of the Environment. Letter from Margaret M. Chauncey, Hazardous Waste Enforcement Division, to
Sean Smith, SCM Chemicals-Americas. November 29,1995.
SCM Chemicals. Letter from J.F. Bent Hawkins Point Plant to John A. Veil, Industrial Discharge Program, Maryland Department
of the Environment. July 24, 1990.

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¦WWM^WAWWWWIMWUWWJWUWWWWWIWWUWWM^
I __	Page 117
SCM Chemicals Hawkins Point Plant:
"Chlorine Released to Air During Process Malfunction"
Waste and Material Management Practices: The SCM Chemicals Hawkins Point Plant manufactures titanium
dioxide from two processes: 1) a.sulfate process where titanium ores are ground and digested in batch
attack vessels with sulfuric acid; and 2) a chloride process where titanium ore is chlorinated in the
presence of carbon to produce titanium tetrachloride (TiCI4), which is oxidized to produce titanium
dioxide. SCM produces about 70,000 tons per year of the sulfate processed pigment for sale to the
paper industry. The chloride processed pigment is used in paints, paper, and in powdered sugar. Acidic
wastewater is produced from both processes. Most of the acid wastes from the sulfate process are
stored in a lagoon and treated in an acid neutralization plant. Acid wastes from the chloride process are
sold or neutralized with caustic and lime slurry. The solids from this process settle in a series of lagoons.
The chloride plant is equipped with a venturi scrubber for collection of TiCI4 emissions. Additional
scrubbers at the chloride plant include the Peabody scrubber stack and the ferrous chloride scrubber.
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-off,
cooling water, batch attack scrubber water, miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles C02 gas produced by SCM's acid
reactions. The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Doit tank (thickener) drainage from both the sulfate and chloride
processes, as well as miscellaneous floor drains. The effluent is treated with caustics and lime slurry in a
series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant.
On November 1,1993, chlorine gas (CI2) was released to the air due to a malfunction in the
chlorination process. The malfunction allowed unreacted chlorine gas to exit the chlorination process
and enter the residual gas stream. The Ferrous Chloride Scrubber was operating and scrubbed all but 78
pounds of the chlorine, which were released to the atmosphere.
Type of ImpactfMedia Affected: The chlorine release occurred for approximately 44 minutes. Chorine is
designated as extremely hazardous under the SARA hazard designation. According to the facility, there
were no known or expected health risks associated with the release.
Regulatory ActionfResponse: The facility notified all regulatory agencies required. The facility shut off the
process flows and discontinued productions. Additional information on facility and regulatory responses
to this release were not indicated in the available files.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals, Incorporated. May 14,
1990.
SCM Chemicals. Letter from John F. Bent to Pam Phillips, Maryland State SARA, Emergency Response Commission, Re: Follow-up
Report of en Emergency Release Notification. November 8,1993.

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PageTlF8
SCM Chemicals Hawkins Point Plant:
"Multiple Discharges of Highly Acidic Wastewater
into the Patapsco River"
Waste and Material Management Practices:
The SCM Chemicals Hawkins Point Plant manufactures titanium dioxide from two processes: 1) a
sulfate process where titanium ores are ground and digested in batch attack vessels with sulfuric acid;
and 2) a chloride process where titanium ore is chlorinated in the presence of carbon to produce titanium
tetrachloride, which is oxidized to produce titanium dioxide. SCM produces about 70,000 tons per year
of the sulfate processed pigment for sale to the paper industry. The chloride processed pigment is used
in paints, paper, and in powdered sugar. Acidic wastewaters are produced from both processes. Most of
the acid wastes from the sulfate process are stored in a lagoon and treated in an acid neutralization
plant. Acid wastes from the chloride process are sold or neutralized with caustic and lime slurry. The
solids from this process settle in a series of lagoons.
SCM has three permitted outfalls to the Patapsco River. Outfall 001 consists of storm water run-off,
cooling water, batch attack scrubber water, miscellaneous floor drainage from within the plant, and
wastewater from a co-located Airco plant, which treats and bottles C02 gas produced by SCM's acid
reactions. The effluent from Outfall 002 consists of process wastewater from the chloride process plant,
cooling water, storm water drainage, Dorr tank (thickener) drainage from both the sulfate and chloride
processes, as well as miscellaneous floor drains. The effluent is treated with caustics and lime slurry in a
series of ponds prior to discharge. Outfall 003 receives effluent from the acid neutralization plant. The
acid neutralization plant receives waste acid from the sulfate process. This waste is stored in a lagoon
prior to treatment. Gypsum, a by-product of the neutralization process, is sold to farmers or U.S.
Gypsum. Any unsold gypsum is landfilled. It was not clear from the reviewed files whether the gypsum
is landfilled on-site or shipped off-site.
On February 3,1992, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH below 2 for 15 continuous minutes through Outfall 001 into the Patapsco River.
Approximately 90,000 gallons of acidic wastewater were released. The excursion was caused by the
sudden failure of a processing unit in the sulfate manufacturing plant. A leak in the processing unit
occurred, which permitted acidified feed stock to mix with process wastewater and flow through Outfall
001. Process instrumentation detected the leak immediately and the process unit was shut down. The
acidified feedstock continued to drain from the unit until the feedstock level dropped below the area of
the leak.
On June 30,1993, the SCM Hawkins Point Plant violated its NPDES permit by discharging effluent
with a pH below 2 for 11 continuous minutes through Outfall 001 into the Patapsco River. Approximately
80,000 gallons of acidic wastewater were released. The cause of the excursion was identical to the
February 3,1992 release.
On November 6,1993, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH below 2 for 13 continuous minutes through Outfall 001 into the Patapsco. River.
Approximately 57,200 gallons of acidic wastewater were released. The excursion was caused by the
failure of a level controller to actuate an automatic shut-off valve. The process vessel overflowed onto
the building floor, out a door, and into a storm drain, which carried the solution through the 001 treatment
station. When the foreman was notified of the spill, the pump filling the vessel was shut down. The
acidic material on the floor was contained and neutralized.
On January 19,1994, the SCM Hawkins Point Plant violated its NPDES permit by discharging
effluent with a pH level between 4 and 6 for 100 continuous minutes through Outfall 002 into the
Patapsco River. The excursion occurred when caustic treatment lines in the wastewater treatment
system froze due to extremely cold weather. The plant's environmental technician increased the caustic

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addition at the upstream 002 neutralization plant in an attempt to increase the pH of the settling basin.
The caustic lines were eventually thawed and used to balance the pH level of the discharge.
Type of Impact/Media Affected: According to the plant manager, no adverse impact to the Patapsco River
was detected for any of the aforementioned excursions. Based on a visual inspection of the river, the
plant manager believes that the effluent was completely neutralized within 25 yards of the outfall.
Regulatory Action/Response: Each pH excursion was reported verbally and in writing to the Maryland
Department of the Environment (MDE). In each case, additional caustic was introduced to the
wastewater treatment system to reduce the acidity and minimize the length of the excursion. Both the
February 1992 and the June 1993 excursion reports indicated identical steps being taken to avoid a
reoccurrence: a new maintenance schedule was instituted so that all process units will be inspected
routinely every 120 days. The plant manager reviewed the standard operating procedure of radio
communication between the shift operations foreman and the environmental shift technician to assure an
expeditious response in the event of a future spill.
After the November 1993 incident, the overflow line from the process vessel was extended to a
containment area that leads to a neutralization plant. Also, an alarm was installed in the overflow line.
In 1994, after the caustic lines were thawed to permit treatment at Outfall 002, additional monitoring
was continued through the cold weather period.
Responses and actions taken by MDE were not included in the file available for review.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals, Incorporated. May 14,
1990.
SCM Chemicals. Letter from John F. Bent, Hawkins Point Plant, to Rick Collins, Hazardous and Solid Waste Management,
Maryland Department of the Environment February 10, 1992.
SCM Chemicals. Letter from John F. Bent Hawkins Point Plant, to Rick Collins, Hazardous and Solid Waste Management,
Maryland Department of the Environment. July 2,1993.
SCM Chemicals. Letter from John F. Bent, Hawkins Point Plant, to Rick Collins, Hazardous and Solid Waste Management,
Maryland Department of the Environment November 10,1993.
SCM Chemicals. Latter from John F.Bent Hawkins Point Plant to Mike Huether, Waste Management Inspection and Compliance
Division, Maryland Department of the Environment. January 24,1994.

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SCM Chemicals Hawkins Point Plant:
"Multiple Releases of Titanium Tetrachloride to Air"
Waste and Material Management Practices:
The SCM Chemicals Hawkins Point Plant manufactures titanium dioxide from two processes: 1) a
sulfate process where titanium ores are ground and digested in batch attack vessels with sulfuric acid;
and 2) a chloride process where titanium ore is chlorinated in the presence of carbon to produce titanium
tetrachloride(TiCI4), which is oxidized to produce titanium dioxide. SCM produces about 70,000 tons per
year of the sulfate processed pigment for sale to the paper industry. The chloride processed pigment is
used in paints, paper, and in powdered sugar. Acidic wastewater is produced from both processes. Most
of the acid wastes from the sulfate process are stored in a lagoon and treated in an acid neutralization
plant. Acid wastes from the chloride process are sold or neutralized with caustic and lime slurry. The
solids from this process settle in a series of lagoons. The chloride plant is equipped with a venturi
scrubber for collection of TiCI4 emissions. Additional scrubbers at the chloride plant include the
Peabody scrubber stack and the ferrous chloride scrubber.
On November 5,1991, a seepage below the crude titanium tetrachloride tank was discovered. The
titanium tetrachloride was fuming, causing a release to the atmosphere. From discovery of the leak until
the tank was repaired spanned more than 27 hours. The volume of titanium tetrachloride released was
not indicated in the files reviewed.
On July 2,1993, titanium tetrachloride was spilled into a containment area during the replacement
of a level measuring device on a titanium tetrachloride treatment reactor. Approximately four pounds of
titanium tetrachloride were released to the atmosphere.
On May 29,1994, a titanium tetrachloride release occurred when a hole developed in the process
duct work of the chlorination area, allowing 25 pounds of titanium tetrachloride to be released to the
atmosphere. The release occurred over a sixteen minute period.
Type of Impact/Media Affected: Titanium tetrachloride is designated as extremely hazardous under SARA.
The information in the reviewed files on the release in November 1991 did not indicate whether there
was an environmental or human health impact. The 1993 and 1994 releases were not associated with
any known or anticipated health risks, according to the facility.
Regulatory Action/Reeponse: In response to the seepage from the crude titanium tetrachloride tank in
November 1991, the facility used a HAZMAT foam cart to suppress fuming. The maintenance scrubber
system also was used to remove fumes from the area and to scrub the fumes prior to release to the
atmosphere. The titanium tetrachloride was pumped from the tank, and an area of concrete below the
tank was removed to access the leak. The tank was repaired using a small metal saddle covered by a
large rubber patch and another larger metal saddle patch. Both the Baltimore City Fire Department and
the State of Maryland Emergency Response Team were notified and were present at the plant. No
information on corrective actions or enforcement actions was present in the files reviewed.
In response to the 1993 release, the pump transferring titanium tetrachloride to the treatment
reactor was shut off. HAZMAT foam was applied to the spill in the containment area to stop the release.
The facility contacted all the regulatory agencies required. No additional information on facility or
regulatory actions was present in the files reviewed.
In response to the 1994 release, the process flows were shut off and production was discontinued.
The facility notified all regulatory agencies required. No additional information on facility or regulatory
actions was present in the files reviewed.

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References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Chemicals, Incorporated. May 14,
1990.
SCM Chemicals. Letter from John F. Bent to Richard Collins, MDE. November 18, 1991.
SCM Chemicals. Letter from John F. Bent to Pam Phillips, Maryland State SARA, Emergency Response Commission. July 21,
1993.
SCM Chemicals. Letter from Ronald B. Root to Pam Phillips, Maryland State SARA, Emergency Response Commission. June 2,
1994.

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SCM Chemicals St. Helena Plant:
"Ammonia-Contaminated Effluent Causes Toxicity"
Waste and Mats rial Management Practices:
The SCM Chemicals St. Helena Plant manufactures color pigments from cadmium. Sulfuric acid and
nitric acid are used to reduce cadmium to a cadmium sulfate liquor. From the reviewed files, it was not
clear whether the facility's raw materials include cadmium ore or cadmium metal. The pigment plant
manufactures two categories of pigment: pures and lithopones. Ammonium is generated in the liquor
attack operation, where cadmium sulfate is purified for use in the striking operation. Striking is a process
that produces a filterable slurry, which is further processed into pigments. Ammonium sulfate is an
unavoidable by-product of these processes and is separated from the cadmium sulfide precipitate
following striking. Ammonium carbonate is a by-product of certain red lithopone pigments and may
represent 35 to 75 percent of the entire ammonia burden from the plant, according to the plant manager.
All pigment process wastewater is collected in scavenger tanks and treated with ferrous sulfide. After
settling, the wastewater is pumped to the scavenger presses and is then discharged through Outfall 001
to Colgate Creek. A turbidity monitoring system stops and recirculates any discharge not properly
treated.
This facility also includes an Amorphous Silica Plant, which manufactures silica gel. The
wastewater from the silica production is discharged through Outfall 002 to Colgate Creek. The Silica
Plant does not contribute to Outfall 001.
Prior to 1990, Maryland Department of the Environment (MDE) determined that effluent from
Outfall 001 failed toxicity tests. Ammonia was determined to be the cause of both acute and chronic
toxicity. Detailed analysis from the toxicity tests was not available in the files reviewed.
Type of Impact/Media AffectBit The specific impact to aquatic life in Colgate Creek was not available in the
reviewed files.
Regulatory Action/Response: MDE required SCM to prepare a plan and schedule for implementing measures
to eliminate acute toxicity and reduce chronic toxicity to acceptable levels. In 1990, SCM submitted a
plan to MDE outlining process changes for red lithopone pigments and an effluent treatment system.
The proposed effluent treatment system changes included segregating the striking process filtrate, which
contains ammonium sulfate, from other plant wastewaters. The ammonia wastewater would be
processed through an ammonia stripping column and commingled with all other plant wastewater. The
facility also planned to install a diffuser for all wastewater. The facility manager estimated that the
proposed changes would eliminate the acute toxicity of Outfall 001 and reduce ammonia discharges to a
maximum of 19.8 ppm at a pH of 6.6. Subsequently, the plant decided to cease all discharges from
Outfall 001 to Colgate Creek. Since 1993, all effluent from Outfall 001 has been discharged to a publicly
owned treatment works. MDE considers the toxicity reduction evaluation complete for Outfall 001.
References:
Maryland Department of the Environment. Compliance Sampling Inspection atSCMGIidco Organics Corporation. May 8,
1990.
Maryland Department of the Environment. Letter from MehrinH. Knott Biomonhoring Division, to Michael P. Shaughness,
SCM Chemicals. September, 16,1993.
SCM Chemicals. Letter from Michael P. Shaughness, Colors end Silica Business, to MehrinH. Knott Compliance and Biomonhoring
Division. Maryland Department of the Environment. September 7,1993.
SCM Chemicals. Letter from Robert M. Mohr, PI„ Colors and Silica Business, toMelvinH. Knott Compliance and Biomonhoring

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Division, Maryland Department of the Environment February 9, 1990.

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SCM Chemicals St. Helena Plant:
"Multiple Discharges of Cadmium-Contaminated Effluent into Colgate Creek"
Waste and Material Management Practices: The SCM Chemicals St. Helena Plant manufactures red and yellow
color pigments from cadmium. Sulfuric acid and nitric acid to reduce cadmium to a cadmium sulfate
liquor. From the reviewed files, it was not clear whether the facility's raw materials include cadmium ore
or cadmium metal. Wastewater from the color pigment plant is discharged through Outfall 001 to
Colgate Creek.
Process wastewater is sampled for soluble cadmium prior to filtration to determine if treatment is
necessary. If treatment is needed, the plant operator performs the required treatment, and resamples
and analyzes the wastewater. Treatment is repeated if necessary. Filtration does not begin until the
plant lab determines that soluble cadmium is at an acceptably low level. During filtration, the filter
operator samples the filtrate for cadmium, and this sample is held as a "retainer sample."
The facility also includes an Amorphous Silica Plant, which manufactures silica gel. The
wastewater from the silica production is discharged through Outfall 002 and is not the source of cadmium
exceedances.
On January 31,1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 1.569 pounds of total cadmium. The permitted daily maximum quantity for cadmium is 0.49
pounds. A strike batch was approved for filtration containing only 0.12 ppm soluble cadmium. When the
plant operator learned that Outfall 001 had exceeded its daily limit for cadmium, the retainer sample was
analyzed. The retainer sample contained 99 ppm soluble cadmium. The cause of the high-cadmium
content filtrate was operator error. An operator did not fully close the strike tank (reaction tank) bottom
outlet valve, resulting in raw materials entering the wastewater filtrate process.
On November 5,1992, SCM again violated its NPDES permit by discharging effluent containing
1.32 pounds of total cadmium. This violation was caused by one of two scenarios at the plant's red
treatment collection system. Concentrated acid was added to the plant's red treatment collection system
through routine draining and cleaning. The acid reduced the pH of the wastewater in the collection
system to 5.4 where the relatively low pH could cause cadmium carbonates and cadmium hydroxides in
the red treatment system scavenger tank and filter press to become water soluble. Another possible
cause of the cadmium exceedance was determined to be an accidental opening of the manifold drain
valve, which could be opened to the red treatment system or to the metals recovery tank. The manifold
pipe holds approximately 1 gallon of ionic cadmium liquor from the metals recovery tank. A release of
only 1 quart of cadmium liquor into the red treatment system would account for the amount of cadmium
released.

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Page 126
Type of ImpactlMedia Affected: The specific impact to aquatic life in Colgate Creek from the January 31,
1990, release was not available in the reviewed files.
According to the SCM environmental engineer, there was no threat to human health or the
environment from the November 5,1992 release. The estuary pH is naturally buffered above the point
where cadmium is soluble in water and the tidal flow in Colgate Creek is 20 million gallons per day
(mgd). The cadmium concentration in the receiving water on November 5,1992, was 7.9 ppb. EPA's
marine acute criteria for cadmium is 43 ppb, and the marine chronic criteria for cadmium is 9.3 ppb. The
human health criteria for cadmium is 170 ppb.
Regulatory Action/Response: SCM personnel verbally reported the 1990 exceedance to Maryland Department
of the Environment (MDE) within 24 hours. On February 5,1990, SCM forwarded a written report to
MDE, describing the incident and probable cause. SCM's Maintenance and Engineering Manager stated
that all operators would be instructed on the correct procedures for charging raw materials into the strike
tank. Any response or actions taken by MDE were not documented in the files available for review.
In 1992, the release exceeded the CERCLA reportable quantity of 1 pound for cadmium
compounds and was reported to state, federal, and local agencies. From the reviewed files, there was
no conclusion as to which of the aforementioned scenarios actually caused the exceedance. To prevent
a recurrence, the plant engineer indicated to MDE that SCM would modify the metals recovery tank
manifold valves and post warning signs against acid usage in the red treatment system. The correct
procedures required to prevent a recurrence would be reviewed with production and maintenance
personnel. Responses of and actions taken by MDE were not available in the files reviewed.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organiss Corporation. May 8,
1990.
SCM Chemicals. Latter from Peter J. Cullati, Colors and Silica Business, to John Beaslay, Industrial Discharge Enforcement
Division, Maryland Department of the Environment. February 5,1990.
SCM Chemicals. Letter from John B. Essers, Colors and Silica Business, toJohnBeasley, Industrial Discharge Enforcement
Division, Maryland Department of Via Environment. November 13, 1992.

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Page 127
SCM Chemicals St. Helena Plant:
"Multiple Discharges of Zinc-Contaminated Effluent
into Colgate Creek"
Waste and Material Management Practices: The SCM Chemicals St. Helena Plant uses sulfuric acid and nitric
acid are used to reduce cadmium to a cadmium sulfate liquor. From the reviewed files, it was not clear
whether the facility's raw materials include cadmium ore or cadmium metal. Certain elements are added
to the cadmium sulfate liquor in the strike tank (reaction tank), including zinc sulfate, which produce
yellow pigments. After leaving the strike tanks, the pigment slurry is filtered, dried, calcined, refiltered,
dried, blended, and milled into the finished product. The facility also includes an Amorphous Silica Plant,
which manufactures silica gel. The silica plant associated with this facility does not discharge
wastewater through Outfall 001.
Process wastewater is sampled for zinc prior to filtration to determine if treatment is necessary. If
treatment is needed, the plant operator performs the required treatment, then resamples and analyzes
the wastewater. Treatment is repeated if necessary. Filtration does not begin until the plant lab
determines that zinc and other metals are at an acceptably low level. During filtration, the filter operator
samples the filtrate, and this sample is held as a "retainer sample." Wastewater from the color pigment
plant is discharged to Colgate Creek through Outfall 001.
On June 1,1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 0.14 pounds of total zinc. The permitted daily maximum discharge quantity for zinc is 0.11
pounds. The source of this exceedance was determined to be a recently installed floor scrubbing
machine. The machine picked up zinc sulfate from the processing area floor. The cleaning and
maintenance operator emptied the floor scrubber wastewater into the wrong tank, by-passing the site's
treatment system.
On April 15,1992, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 0.156 pounds of total zinc. The 1992 release was due to a miscalculation by the SCM
laboratory analyst. The mathematical error caused the analyst to incorrectly approve a batch of
wastewater with elevated levels of zinc for discharge through Outfall 001.
On April 6,1993, the SCM St. Helena Plant again violated its NPDES permit by discharging effluent
containing 0.124 pounds of zinc. On April 7,1993, operators checked all equipment related to the
pigment process and the wastewater treatment system and found no malfunctions. On April 8, the site
laboratory began sampling the discharge hourly and isolated the problem in the red pigment process.
Wastewater from this process was leaching zinc from the filter cake in the wastewater filter press.
Type of Impact/Media AffectBifc The specific impact to aquatic life from the 1990 and 1992 incidents was not
available in the reviewed files. The permitted daily maximum quantity for zinc is 0.11 pounds.
According to the plant manager there was no threat to human health or the environment from the 1993
release. The tidal flow in Colgate Creek is 20 million gallons per day (mgd). The zinc concentration at
Outfall 001 was 18 ppb. EPA's marine acute criteria for zinc is 95 ppb, and the marine chronic criteria
for zinc is 86 ppb.
Regulatory ActionfResponse: SCM personnel verbally reported the exceedance to MDE on April 12,1993.
On April 19,1993, SCM forwarded a letter to MDE describing the incident and probable cause. SCM's
plant manager instructed the plant supervisor and all operators to remove the filter cake from the press
daily. This should reduce the build-up of zinc compounds in the press. The operators also will adjust the
pH specifications on batches to minimize the amount of soluble zinc present. Correct procedures for
handling zinc compounds were reviewed with all operators.
Following each NPDES permit violation, the facility notified the Maryland Department of

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Page 128
Environment (MDE). Responses and actions taken by MDE were not included in the files available for
review.
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics Corporation. May 8,
1990.
SCM Chemicals. Letter from John B. Essars, SCM St. Helena Plant to Sharon £ Talley, Industrial Discharge Enforcement Division.
Maryland Department of the Environment April 23, 1992.
SCM Chemicals. Inter-Office Memo from Leonard J. Ulicny to John Essars. April 20,1992.
SCM Chemicals. Letter from John B. Essars, Colors & Silica, to Jams IV. Metz, Industrial Discharge Enforcement Division,
Maryland Department of the Environment. May 26,1992.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to John Beasley, IndustrialDischarge Enforcement Division,
Maryland Department of the Environment June 8, 1990.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to James IV. Metz, Industrial Discharge Enforcement
Division, Maryland Department of the Environment July 26,1990.

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WWMWtJJJWAWM
Page 129 i
SCM Chemicals St. Helena Plant:
"Multiple Turbid Discharges Enter Colgate Creek"
Waste and Material Management Practices: The SCM Chemicals St. Helena Plant, located in Baltimore,
Maryland, produces fine particle silica gel, reacting sodium silicate with sulfuric acid. The silica gel is
washed with hot water and aged in a dilute ammonia solution. Wastewater from this process consists of
water from filtration and washing operations. The wastewater is collected in sumps where it is
neutralized. The neutralized wastewater is then filtered through several screens. The filtered solids are
primarily sand and are non-hazardous. After passing through a heat exchanger, the filtered wastewater is
discharged through Outfall 002 to Colgate Creek.
On March 9,1990, the SCM St. Helena Plant violated its NPDES permit by discharging effluent
containing 109.57 pounds of total suspended solids (TSS). The permitted daily maximum quantity for
TSS is 98 pounds. According to an SCM manager, the source of this exceedance may have been a
leaking gasket on the gel tank door. The faulty gasket would have allowed sodium silicate to enter the
sumps where wastewater is adjusted for pH.
On February 19,1993, the SCM St. Helena Plant again violated its NPDES permit by discharging
effluent containing 157.5 pounds of TSS. The solids were identified as sand through process knowledge
and analysis. According to the site engineer, the exceedance was caused by one or both of the
following: 1) the solids removal screen was uniformly worn, thus allowing micron size silica solids
through the weave of the screen; and/or 2) the start-up operations on the morning of February 18,1993,
followed a record-setting nighttime freeze. Thermal contraction of the equipment and discharge piping
system during the night, followed by thermal expansion from the warm process wastewater, could cause
residue on the inside of the piping system to dislodge, thereby increasing the TSS levels of the
discharge.
Typ8 of ImpactfMedia Affecte± The specific impact to aquatic life from the 1990 incident was not available in
the reviewed files. The permitted daily maximum quantity for TSS is 98 pounds. According to the plant
manager there was no threat to human health or the environment from the 1993 release. Sand does not
have a marine criteria, fresh water criteria, or human health criteria. The State of Maryland does not
have a water quality-based criteria for total suspended solids. The Maryland turbidity criteria is 150
Nephelometric Turbidity Units (NTU). The 1993 effluent composite sample had a turbidity of 7 NTU.
Regulatory ActionlResponse: SCM personnel verbally reported the March 9,1990 exceedance to Maryland
Department of the Environment (MDE) on March 12,1990. On March 15,1990, SCM foiwarded a letter
to MDE describing the incident and probable cause. Once aware of the TSS exceedance at Outfall 002,
the plant operator stopped the gasket leak with a clamp and diverted the effluent flow to holding ponds.
The effluent tank also was drained to the holding ponds. All equipment was cleaned to remove any silica
gel. The faulty gasket was replaced. The silica-bearing effluent was reacted with acid to produce a gel.
Most of this gel was captured by the filters, however, some of it passed through the filter, causing a
higher than noimal TSS discharge to Colgate Creek. The plant manager noted that this minor gasket
leak may not explain the entire problem. The site manager planned to conduct tests to determine if
certain impurities in the silicate interfere with proper crystallization. If changes in the process do not
reduce TSS, then the site will add an additional treatment step to improve the filter's efficiency. No
further information was available in the reviewed files.
After the February 19,1993 incident, which was reported verbally and in writing to MDE, SCM
operators replaced the screen on the solids removal equipment. The plant engineer also indicated that
operators will inspect the piping system when weather or shutdown schedules suggest a potential for
thermal contraction and expansion.

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130
References:
Maryland Department of the Environment. Compliance Sampling Inspection at SCM Glidco Organics Corporation. May 8,
1990.
SCM Chemicals. Letter from Peter J. Cullati, Colors & Silica Business, to John Beasley, IndustrialBischarge Enforcement Division,
Maryland Department of the Environment. March 15,1990.
SCM Chemicals. Letter from John B. Essars, Colors & Silica Business, to John Beasley, Industrial Discharge Enforcement Division,
Maryland Department of the Environment. February 25, 1993.

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Page 131
USMX, Inc., Alligator Ridge Mine:
Spills of Process Solutions to Soil Surfaces
Waste and Materials Management Practices: Operations at the Alligator Ridge Mine consist of open-pit mining
and heap leach cyanidation. Gold recovery is accomplished by carbon adsorption, carton stripping, and
electrowinning.
The facility consists of ore pits, leach pits, leach pads (phases I and II), process solution ponds, a
leachate processing facility, a crushing plant, and a tailings impoundment. Phase I pads (B through L)
consist of compacted clay liners with drainage supplied by a system of PVC pipes. Phase II pads (M, N,
and O) were constructed of six inches of compacted clay covered with a 40-mil HDPE liner.
A single pregnant pond exists at the facility lined with a single layer of 60-nil HDPE on top of a 12 inch
compacted clay liner. A french drain is located in the lowest part of the pond and runs out to a leak
detection sump. A single barren solution pond is located near the process plant. This pond was relined
in 1988 with 60-mil HDPE.
The facility is capable of diverting runoff resulting from a 100-year, 24-hour storm event.
A total of five spill events occurred during 1990 to 1992 resulting in approximately 6,600 gallons of
process solution containing sodium cyanide and 5,000 gallons of muratic acid being released onto
surrounding soils. The majority of spill were the result of equipment failures, such as split lines, fractured
fittings, and cracked pipes. Operator error, as well as freezing weather conditions were also cited as
contributing factors in a number of the spills.
Type of Impact/Media Affected: In January of 1990, a third spill resulted in 4,500 gallons of process solution
being released. In this case, turning on the pregnant solution pump overpressurized a frozen line and
caused a blowout, which sent some of the solution into a roadside ditch. On consecutive days, March 27
and again on March 28,1990 spills occurred at the Alligator Ridge Mine. In the first case, an air bubble
caused 300 gallons of process solution to be released from an extracted flow meter under repair near
barren solution pumps. On the following day, freezing conditions and over-pressurization of a line
caused a cracked pipe/flange weld to rupture resulting in the release of nearly 1,800 gallons of process
solution onto a roadway. In February of 1991, a small spill occurred at the mine resulting in 1.43 pounds
sodium cyanide being spilled. The final spill occurred in May of 1992. A fractured fitting on a tank
resulted in release of 5,000 gallons of muratic acid. The spill resulted in a plume approximately 500 feet
long.
Regulatory Action/Responses: In March 1990 and February 1991 spills involving sodium cyanide process
solution, hydrogen peroxide was utilized to neutralize areas impacted. In the largest spill of 4,500
gallons, the spill was contained in a drainage ditch where cold temperatures froze the solution. Lack of
adequate maneuvering room for equipment precluded transport of the material back onto the heap leach
pad for re-leaching. The mine conducted follow-up sampling to monitor neutralization success.
Remediation in the spill involving muratic acid consisted of containment of the leaking tank followed by
neutralization of the acid by soda ash and caustic. Sampling performed following cleanup indicated that
the soil pH within 1000 ft of the spill was above 6.9. In all cases the appropriate regulatory agencies
were notified soon after spill detection.
References:
Alligator Ridge Mine. Cyanide Discharge Report. January 2,1990.
Alligator Ridge Mine. Record of Communication Regarding Cyanide Solution Leak. January 4,1990.
Alligator Ridge Mine.	Memo Regarding January 2,1990 Spill. January 10,1990.

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Alligator Ridge Mine. Memo Regarding Spill on January 2,1990. January 23,1990.
Alligator Ridge Mine. Cyanide Discharge Report. March 27,1990.
Alligator Ridge Mine. Cyanide discharge Report. March 28,1990.
Nevada Division of Environmental Protection (NDEP). Record of Communication with Alligator Ridge
Mine. March 29,1990
Alligator Ridge Mine. Memo to Kathy Sertic Regarding Spills on March 27 and 28,1990. April 3,1990.
NDEP. Spill Report Form. February 14,1991.
NDEP. Spill Report Form. May 6,1992.
USMX. Memo to NDEP Regarding Cleanup of Muratic Acid Spill on May 6,1992. May 27,1992.
Tom Card, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding USMX, Inc.,
Alligator Ridge Mine. September 4,1992.

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The Aurora Partnership Auora Gold Project
Notice of Violation and Multiple Spills
Wasta and Material Management Practices: The project consists of open pit mining and cyanide heap leach
recovery processes. Ore from the pit is hauled to a crushing and agglomeration area and then placed on
the leach pad. The pad rests on a 40 mil PVC liner that covers a prepared subbase, compacted 95% to
prevent leakage. The collection pipes rest between the liner and pad and direct flow to the HDPE-lined
collection channels. The channels flow to the pregnant solution pond, that is lined with a 60 mil HDPE
liner over a prepared subbase. Two layers of geotextile were placed on the prepared subbase to create
a percolation zone to the sump, located at the lowest comer of the pond. The sump is monitored for
fluids. If a leak develops, the fluid can be pumped to an overflow pond until the leak is repaired.
Enforcement action. On June 27,1995, NDEP issued a Finding of Alleged Violation and an Order to
Aurora. The FOAV and Order were apparently based on findings of an inspection on April 10,1995.
Neither the inspection report nor the FOAV and Order were located in the files. The information
presented here was taken from a letter from NDEP to Aurora on October 5,1995; a Bureau of Mining
Regulation and Reclamation Inter-office memorandum dated January 3,1996; and Aurora's written
response to the FOAV and Order, dated March 1,1996.
In early 1995, ponding on the heap (reported by Aurora to be the result of heavy precipitation) caused the
front of the heap to wash out and move process fluids and heap materials beyond the toe of the heap.
The amounts were unspecified in available materials. Remediation began with moving material back to
containment and undertaking unspecified detoxification of uncontained residual materials. Aurora also
worked to regrade the heap and to install new piping and tubes. Most importantly, Aurora undertook
efforts to clear solution ditches that are impeded or blocked by ore and fines; clearing had to be by
hand-shoveling to avoid damage to liners. Finally, Aurora had to develop and implement a monitoring
and maintenance plan.
The FOAV also addressed leakage of solution from carbon-in-leach piping; Aurora reported that up to
319 gallons of solution containing 0.29 pound of cyanide "may have been released from containment.''
Beyond repairing the piping, Aurora had to extend the concrete containment area.
Finally, the FOAV addressed add drainage from some materials in the heap stockpiles and from the
chemical storage area, the berms for which were constructed with acid-generating materials. Aurora
regraded the stockpiles to prevent ponding and compacted them to reduce infiltration; they also
constructed perimeter ditches to capture runoff, and these lead to sumps, where water is monitored and,
if necessary, neutralized before discharge to an "event pond" or used as makeup water. The January
1996 memorandum cited above identifies some areas where Aurora had yet to come into compliance
with the Order, among them the analysis of CIL-area contaminated soil and the clearing of solution
ditches. A Show Cause hearing on the FOAV and Order was scheduled for February 1996. Records of
the hearing were not found in the files.
The facility has reported several releases between 1992 and 1996. These releases result from
equipment failures at the facility. Failures include blown pipe fittings as a result of freezing conditions
and an accident involving a piece of mobile equipment.
March 6,1995. The facility had a spill of 500 - 700 gallons of cyanide leach solution at a concentration of
50 ppm. A drip line froze and the resulting pressure caused the rupture of a pipe. Facility personnel
channeled the solution back to the pregnant solution pond. They also treated any contaminated soil with
calcium hypochlorite.
July 19,1994. The facility had a spill of 50 gallons of cyanide at a concentration of 50 ppm. The cause of
the spill was a rupture in one of the dripline feed pipes, resulting in material being washed down from the
heap. The material collected in the lower containment area of the pad. A small amount of solution and
fine suspended solids escaped over the containment berm. Facility personnel immediately treated the

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area with calcium hypochlorite to neutralize the cyanide. The contamination reached a depth of only a
few inches and constituted about 600 pounds of soil. This material was shoveled up and removed to a
plastic lined area.
January 11,1994. 200 gallons of sodium cyanide solution were spilled when a pipe fitting ruptured near
pad 1. Facility personnel neutralized the spill, excavated contaminated soil and moved it to a
containment area behind Pad #1.
June 3,1993. The facility had spilled of 6,400 gallons of denatured alcohol in a chemical storage area (the
alcohol is used as a strip solution). The spill was caused when a bulk storage tank was struck by a piece
of mobile equipment. This knocked a fitting loose, damaging a valve, and resulted in the discharge of
the denatured alcohol. Facility personnel removed any potential ignition sources from the area as
denatured alcohol's main hazard is ignitability. Free standing alcohol was pumped back into appropriate
containers. The impacted area was then allowed to dry and was then flushed with 4000 gallons of fresh
water. Any residual alcohol was allowed to evaporate.
The damaged valve was repaired to prevent additional leakage. Additional protective berms were
installed to prevent any further collisions with the storage tanks.
January 16,1992. The facility had a release of 1,000 gallons of solution with a WAD cyanide concentration
of 155 mg/l. The spill was a result of the combination of a small leak in the leachate ditch liner and an
increase in the operating level of the solution due to snow and ice accumulation. The solution
accumulated under the ditch liner in a localized area. Facility personnel continually pumped the leakage
back into the solution circuit. The area under the liner was treated with calcium hypochlorite for cyanide
destruction.
References:
Steve Rosse. Fact Sheet - The Aurora Partnership, Aurora Gold Project. March 8,1994.
The Aurora Partnership. Written Spill Report. March 6,1994.
The Aurora Partnership. Written Spill Report. July 26,1994.
The Aurora Partnership. Written Spill Report. January 11,1994.
The Aurora Partnership. Written Spill Report. June 15,1993.

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Placer Dome U.S. Inc.'s Bald Mountain Mine:
Spills of Process Solution to Soil Surfaces and Leak in Primary Line
Waste and Materials Managament Practices:
Operations conducted at the facility include open pit gold mining and heap leaching. Bald Mountain
Mine facility consists of No. 1 and No. 2 process leach pads, associated process ponds, process
buildings, crusher building, open pit mines, and waste rock dumps. The three pregnant solution ponds,
barren solution pond, and settling pond in the No. 1 process area possess a leak detection system
between a 60 mil HDPE primary liner and a six inch clay/soil secondary liner. Each pond has an
independent leak detection sump filled with clear gravel. Any leakage from the primary liner
gravity-flows between the liners to the sump where it is removed through a leak detection port. The
pregnant solution pond, barren solution pond, and settling pond at No. 2 process area consist of a 60 mil
HDPE primary liner and a leak collection/detection system above a 6 inch compacted secondaiy liner.
Pond leak detection systems report to a common external sump inside the process building.
Both process areas are designed to contain 25-year/24-hour storm event flows. The facilities are
required to be designed, constructed, operated and closed without discharge or release in excess of
standards established in regulations except during meteorological events exceeding the design storm
event.
Between 1991 and 1995 three spills at the facility released process solution containing varying
concentrations of cyanide to the surrounding soils. The causes of the spills were traced to faulty or loose
valves located near the process building and settling/barren ponds and operator error/improper
installation of couplings.
January 6,1991. 5,000 gallons of sodium cyanide solution containing 4 pounds of cyanide were spilled due
to a loose check valve; a maintenance operator had failed to tighten the bolts. The spill affected 50
square yards of soil to a depth of 4-8 inches. About half of the solution was pumped back into the
system. The remainder froze in place and was to be removed for placement on the heap. Follow up soil
sampling confirmed low cyanide levels.
March 22,1993 until unknown date. The mine repotted that about 6 gallons per minute of pregnant solution
was being pumped out of the sump. The cause was unknown at the time, pending drawdown of the pond
and presumably an inspection of the primary line. No further information was in the files (a notation in
the file indicated that a report was to be prepared, but that was not available).
June 24,1995. 3,000 gallons of sodium cyanide solution were spilled when a coupling came off a pipe -
improper installation was the cause. No further information was available.
November 14,1995. 500 gallons of solution containing 0.23 pounds of cyanide were spilled as a result of
faulty valves on barren solution lines. Soil was removed to a depth of one foot below 'stained depth."
Regulatory Action/Responses: NDEP noted the report indicates in the files that the facility repaired all causes
of the reported spills (faulty valves, lines, couplings). Remedial action consisted of soil sampling and
removal in all cases except one. In this case, involving a spill of process solution at a rate of 6 gallons
per minute, the cause of the spill was not available. The initial spill report indicated that the pond would
need to be drawn down before the case could be established. Remedial action consisted of evacuating
the sump until it cavitates and restarting.
In the largest spill, involving 5,000 gallons of process solution, 50% of the spill was pumped back into the
system. Calcium hypochlorite was spread on the remaining spill as a neutralizing agent. The ground at
the time of the incident was frozen and the remaining frozen solution was place on top of the heap leach.

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Page 136
In all cases, appropriate regulatory agencies were notified immediately.
References:
Nevada Division of Environmental Protection. Spill Report Form. January 7,1991
Bald Mountain Mine. Spill Incident Report. January 15,1991.
Bald Mountain Mine. Memo to NDEP regarding spill on January 6,1991. March 27,1991
Bob Carlson, Nevada Division of Environmental Protection. Fact Sheet regarding Placer Dome U.S. Inc,
Bald Mountain Mine, August 1991.
NDEP.	Complaint/Spill Report Form. February 16,1993
NDEP.	Spill/Release Record. February 23,1993
Bald Mountain Mine. Memo regarding gasoline spill discovered on February 13,1993. February 24,
1993.
NDEP.	Spill Report Form. March, 29,1993.
NDEP.	Complaint/Spill Report Form. June 28,1995.
NDEP.	Spill/Release Record. January 16,1996

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Page 137
Barrick Goldstrike Mines, Inc.
Barrick Goldstrike Project and Meikle Mine
Waste and Material Management Practices: The Barrick Goldstrike Mine Project primarily consists of the AA
and phase I ponds, phases I thru IDA leach pads, tailings impoundment and seepage collection pond,
milling and processing facilities, open-pits and waste dumps. The ore processed at Goldstrike is
excavated from the Meikle Mine. The project also includes the Post, Bazza, West Bazza, and Long Lac
Pits. Sulfidic material does exist and could result in acid drainage. The facilities within this project were
constructed, and are operated without any discharge or release in excess of those standards established
in regulations.
On August 30,1996 a release of 3 pounds mercury was discovered at the wheel motor storage area. It
was assumed that instrumentation containing mercury was previously stored in the area and was the
source of the release.
On August 18,1996, 4,250 gallons of reclaim water was released from Mill #2 during an unscheduled
shutdown of Mill #1. The valves on top of Mill #1 's reclaim water tanks failed to close causing the sumps
at Mill #2 to become overwhelmed, resulting in a loss of containment.
On August 9,1996 approximately 1,500 pounds of ammonia vapor was released from the refrigeration
building through the building's ventilation system. The release was caused by the failure of a Bi-Lok type
fitting on an oil tube at one of the refrigeration machines.
On February 27,1996 2,000 gallons of diluted NaCN (86.4% cyanide) solution was released due to pump
failure a the mill site.
On February 22,1996 1,000 gallons of Bio-Leach water (pH of 2.61) overflowed due to a transfer line
failure.
On January 15,1991 approximately 200 gallons of concentrated sodium cyanide solution was released
when a weld on a one inch diameter HDPE pipeline failed. This pipeline is part of a system which
delivers a concentrated sodium cyanide solution from the storage tank to the ADR facility. It was
estimated that 394 pounds of sodium cyanide was released.
Regulatory ActionjResponse: In response to the August 30,1996 mercury release, less than one cubic yard of
soil was excavated and removed. Surficial mercury was remediated using a mercury vacuum.
In response to the August 18,1996 reclaim water release, overexcavation of impacted soils were
relocated to the AA heap leach pad. The excavated area was treated with hypochlorite.
In response to the August 9,1996 release of ammonia vapor, the equipment in the immediate area of
the release was washed down with water to absorb any residual ammonia, as well as a degreasing agent
and water were used to remove a film of oil from the equipment and floor. Additional protective
measures and modifications were made to ensure that another release would not occur.
In response to the February 27,1996 cyanide solution release, the soils were excavated and put into the
milling circuit.
In response to the February 22,1996 Bio-Leach water release, the affected soils were excavated and
placed in the hep leach pad. The transfer line was repaired and placed back on line.
In response to the January 15,1991 release of sodium cyanide, the solution was pumped into the barren
solution pond, the affected soil was placed onto the leach pad, and the affected area was treated with
hypochlorite solution.

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Page 138
References:
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Crocket, Nevada Office of Emergency Management. 5
September 1996.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 30 August 1996.
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dan Tecca, NDEP. 26 August 1996.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 18 August 96.
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Crockett, NDEP. 16 August 1996.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 9 August 1996
Barrick Goldstrike Mines, Inc.. Letter to Mr. Quint Aninao, NDEP. 1 May 1996
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 19 April 1996.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 28 February 1996.
Barrick Goldstrike Mines, Inc.. Letter to Mr. Dave Emme, NDEP. 15 January 1996.
Barrick Goldstrike Mines, Inc.. Fact Sheet (pursuant to NAC 445.24302). January 1993.
State of Nevada, Division of Environmental Protection. Spill/Release Record. 17 December 1991.
State of Nevada, Division of Environmental Protection. Complaint/Spill Report Form. 24 September
1991.
Barrick Goldstrike Mines, Inc.. Letter to Ms. Kathy Sertic, NDEP. 25 January 1991.

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Battle Mountain Gold Company
Battle Mountain Mining Operations
Waste and Material Management Practices; Operations conducted at this facility include; open-pit mining and
milling of the Fortitude deposit; the Reona Project beneficiation operations; and ore mining from the
South Canyon, Bonanza and Sunshine open-pits. Ore mined from these mines is heap leached and
precious metals are recovered at the beneficiation plant (carbon columns). The loaded carbon is refined
at the existing Fortitude milling facility with conventional stripping, electrowinning and further refinement.
In general, the Battle Mountain Mine Company (BMMC) facility was designed, constructed, operated, and
will be closed without any release or discharge from the fluid management systems.
On June 21,1995 a strapping connection on the tailings pipeline broke, spilling approximately 3,000
gallons of spent gold plant solution onto the adjoining roadway. An area of soil approximately 10 feet
wide by 400 feet long was exposed to the spilled material.
On June 19,1995 a strapping connection on the tailings pipeline broke, spilling approximately 2,000
gallons of spent gold plant solution onto the adjoining roadway. An area of soil approximately 5 feet wide
by 200 feet long was exposed to the spilled material.
On August 18,1994 an inspection was conducted by NDEP on the BMMC facility. A leak in the tailings
line was observed at the upper end of Copper Canyon below the refinery, where previous hydrocarbon
contaminated soil had been removed. Also, the pump at the barren solution pond was observed leaking
and ponding. The leak was not on containment and was not netted.
Regulatory Action/Response: In response to the June 21 and June 19,1995 spills, exposed soils were cleaned
up with a motor patrol and front-end loader and transported to the tailings impoundment. A drainage
ditch adjacent to the pipeline was constructed to divert flow from a damaged pipeline back into the
facility. All strap connections were
replaced on the pipeline, and a down-gradient collection pond was constructed to collect any spent
solution in the future.
In response to the August 18,1994 inspection by NDEP, BMMC repaired the leaking pipeline and sent a
soil sample out for analysis. The pump packing gland leak was repaired and the location was netted.
References:
Battle Mountain Gold Company. Fact Sheet (pursuant to Nevada Administrative Coda 445J4302J. 29 June 1995
Battle Mountain Gold Company. Hazardous Substance Release Investigation. 21 June 1995
Battle Mountain Gold Company. Hazardous Substance Release Investigation. 19 June 1995
Battle Mountain Gold Company. Letter to Mr. Dan Tecca, NDEP. Concerning August 18,1994Inspection. 27
December 1994

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Kinross Mining Company, Candelaria Mine:
Process Releases to Soil Surfaces
Waste and Materials Management Practices: Operations at the facility include gold and silver production
utilizing heap leaching of ore and the Merrill-Crowe process to recover precious metals. Facilities consist
of two heap leach pads (1 & 2), barren and pregnant solution ponds, lined solution ditches, a primary
crusher, and a Merrill-Crowe Plant.
Leach Pad 1 consists of 12 cells. The first five and a half cells are lined with 18 inches of compacted
clay. The remainder of cells are lined with 80-mil HDPE plastic over a four-inch compacted clay base.
Leak detection is provided by piezometers which are located near the pad.
Four pregnant solution ponds are located on site, each of which possess leak detection systems. Leak
detection pipes are monitored weekly for the presence of liquid volumes indicative of a leak. In the case
of pregnant ponds 1 & 2 detection of fluid accumulations in excess of 4 gal per pond per day may be
indicative of a leak in the pond's primary liner. For pregnant ponds 3 & 4 quantities of liquid in excess of
28.5 gal per pond per day for seven consecutive days may indicate a leak.
The ponds have a total combined capacity designed to contain precipitation and runoff from leach pad 1
resulting from a 25-year, 24 hour storm event. They are also designed to handle solution build-up from a
24-hour cessation of pumping resulting from a power outage.
Type of Impact/Media Affected: A total of two spills were reported at the Candelaria Mine in 1995-96. The
first spill occurred in December of 1995 and involved this release of 2,000 gallons of process solution
containing 6.4 lbs of sodium cyanide. The cause of the release was identified as a sump pump failure at
the Merrill-Crowe plant. The spill affected soil resources covering Yi an acre. The second spill occurred
in May of 1996 and involved the release of 200,00 gallons of process solution containing 1125 lbs of
sodium . Changing temperatures caused a 12 -inch main header line to burst. The solution flowed into a
fill area covering 1/4 of an acre.
Regulatory ActionjResponsee: Remediation efforts for the smaller spill involved excavating contaminated soil
and its placement upon the leach pile for re-leaching of the sodium cyanide. Candelaria Mine pledged to
construct an overflow port in the refinery wall to allow future spills to drain directly into process solution
circuit floor drains. Regarding the large spill, the barren pumps were shut down immediately upon
detection of the leak. The solution was contained and 180,000 gallons 1015 lbs of sodium cyanide) were
pumped back into the process system. Contaminated soil containing 110 lbs of sodium cyanide was
excavated and place on top of the leach pad. Records indicated that soil excavation would continue until
soil sampling indicates the concentration of cyanide is below 0.2 ppm.
References:
Kinross, Candelaria Mining Company. Facility Operating Plan. January, 1996.
Kinross, Candelaria Mining Company. Internal Memo Regarding December 25,1995 Spill. December
27,1995
Nevada Division of Environmental Protection. Record of Communication Regarding December 25,1995
Spill. December 27,1995.
Kinross, Candelaria Mining Company. Memo to Nevada Division of Environmental Protection Regarding
December 25 Spill, January 2,1996.
Nevada Division of Environmental Protection (NDEP). Complaint/Spill Report Form. May 3,1996.

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Kinross, Candelaria Mining Company. Internal Correspondence Regarding May 2,1996 Spill. May 6,
1996.
Kinross, Candelaria Mining Company. Memo to NDEP regarding May 2,1996 Spill. May 9,1996.

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Page 142
Coeur Rochester, Inc. Mine:
Process Releases to Soil Surfaces
Waste and Materials Management Practices: Operations conducted at the facility include production of gold and
silver. The operations consist of an open-pit mine with ore crushing and sizing for heap leach operations.
Gold and silver are complexed and mobilized within the heap leach system by a weak cyanide solution
and recovered using the Merril-Crowe zinc precipitate process.
Heap leach pads are of the valley fill design. Existing State I and Stage II pads consist of a compacted
sub-base and an HDPE liner above. An intermediate leak detection material is present in both pads.
Leakage rates from the pads must be calculated, rather than measured, since water from below the heap
leach pads gathered by french drains also reports to the same leak collection sumps. Leachate is
collected as pregnant solution and stored in a collection area within each pad. Stage I pregnant solution
can be routed to either the process plant or the stage II pad. Stage II pregnant solution can be routed to
the process plant or back to the pad if the solution grade is too low. A state IV heap leach pad is
planned, consisting of an 80-mil HDPE primary synthetic liner on a compacted sub-base.
The facility is designed to contain without discharge all direct precipitation resulting from a 100-year,
24-hour storm event. A series of stormwater ditches routes flows away from the pad.
Type of Impact/Media: Two spills have been reported at the mine facility since 1994. The first reported spill
occurred on February 18,1994. As a result of a power outage, 450 tons of ore containing process
solution was displaced from the leach pad. From 1.97 to 9.861 lbs of cyanide were washed out with the
ore. The second spill occurred on March 6,1996. Freezing overnight temperatures caused a line in the
leach pad to rupture. Consequently, 5,500 gallons of sodium cyanide process solution escaped the heap
leach pads primary containment system. 4,500 gallons of the process solution mixed with 35,000 gallons
of fresh water from snowmelt. The remaining solution mixed with an unknown amount of snowmelt.
Available information indicated that no surface or groundwater was impacted by the second spill. No
information indicating water quality impacts was available for the first spill.
Regulatory Action/Responses: Remedial action in the February of 1994 spill involved the placement of ore
containing cyanide back upon the protected heap leach pad. In the March of 1996 spill, the 4,500
gallons of solution was recovered by vacuum truck as it mixed with the snow melt. The escaped solution
was neutralized with hydrogen peroxide. Clean soil was used to soak up remaining solution and all
materials, including excavated impacted soil was placed upon the leach pile. As a result of the second
spill Coeur Rochester, Inc. pledged to undertake a number of additional measures. First, all diversion
ditches would be place a minimum of 75 feet from the nearest process solution application line. Second,
all itches would be enlarged to ensure containment. Third, french drains would be constructed along the
leach pad access road.. Finally, the amount of hydrogen peroxide available for future remediation
efforts would be increase to 200 gallons.
References:
Mahmood Azad, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding Coeur
Rochester, Inc Mine. January 20,1993.
Coeur d'Alene Mines Corporation. Memo Regarding February 18,1994 Spill. February 18,1994.
NDEP. Complaint/Spill Report Form. February 18,1994.
NDEP. Complaint/Spill Report Form. March 6,1996.

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Page 143

Coeur Rochester Group. Memo to NDEP Regarding March 6,1996 Spill. March 19,1996

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Cortez Gold Mines:
Process Releases to Surrounding Soils
Waste and Materials Management Practices: Operations at the Cortez Gold Mines consist of open pit mining of
ore, processing of ore by carbon-in-leach and conventional heap leach cyanidation. Precious metal
recovery is accomplished by carbon adsorption and electrowinning. Facilities include 3 heap leach pads,
7 tailings impoundments, 2 pregnant ponds, 1 barren solution pond 1 pumpback pond, 1 water storage
reservoir, 1 scale pond, a circulating fluid bed roaster, and a processing plant.
The heap leach pads are constructed of compacted clay overlain with six inches of gravel for drainage of
process fluids. Process fluids are drained through either 60-mil HDPE or 40-mil hypalon-lined ditches
and flow to either pregnant pond 2 or 3. Both ditches possess compacted clay secondary containment.
All solution ponds are constructed of 18 inches of compacted clay-silt with a 60 mil-HDPE primary liner.
Only pregnant pond 2 and the pumpback pond possess leak detection. The leak detection system
consists of a four-inch perforated pipe buried in a clay -lined trench in the center of each pond. Gravel
covers the pipe for drainage. The pipe eventually leads to a reclaim tower from which visual inspection
of leaks is performed.
Twenty-seven spills involving cyanide-containing process solutions occurred between July, 1992 and
December, 1994 at Cortez. The majority of spills were caused by equipment failures or operator error.
Type of Impact/Media Affected: During the period, two spills were identified as resulting in more than ten lbs
of cyanide being released to surrounding soils. In July, 1992 a ruptured line to the leach pad resulted in
50,000 gal of barren solution being sprayed across a road and collecting in a 100' x 40' gully. Twenty lbs
of cyanide were released. In November, 1994 a grader hit and ruptured a hose at an inactive
impoundment area releasing 140,000 gal of process solution and 50 lbs of sodium cyanide. Other
noteworthy spills occurring during the period include 330,912 lbs of slurry with a concentration of 2.8 mg/l
WAD CN- at the #2 thickener in February, 1994 and 256,192 gal of toe seepage solution with a
concentration of 0.042 mg/l WAD CN- at tailings impoundment 6 in October, 1994. The remaining spills
involved a total of between 225 and 100,000 gallons of roaster calcines, barren solution, pregnant
solution, tailings material, reclaim solution, and cyanide containing groundwater.
Regulatory Action/Responses: Remediation in the 50,000 gal spill consisted of standing water in the gully
being pumped to the pregnant pond. All contaminated material was moved to the leach pad. Sampling
conducted after material removal showed a WAD cyanide concentration below 0.25 ppm. The 140,000
gal spill flowed into an impoundment area. It was neutralized with calcium hypochlorite and pumped into
nearby holding ponds. Information concerning remediation efforts was available for eight of the
remaining spills. Actions taken included immediate shutdown of the spill source, neutralization of soil
with calcium hypochlorite, and in two cases, removal of contaminated material to tailings impoundments.
The Nevada Department of Wildlife notified Cortez Gold Mine on January 31,1992 that one of the
tailings impoundments at the mine was not in compliance the Department's Industrial Artificial Pond
Permit # 3582 due to a WAD cyanide concentration higher than that considered lethal to wildlife. Cortez
was further informed by the Bureau of Land Management of the actions necessary to be in compliance,
including an immediate reduction in the concentrations of cyanide discharged into the tailings ponds to
non-toxic levels. On April 12,1992 the Nevada Dept. Of Wildlife informed the Cortez Mine that as a
result of sampling the tailings impoundment was found to be in compliance.

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References:
Dean Mierau, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding Cortez Gold
Mines. January, 1991.
Nevada Department of Wildlife. Notice of Noncompliance with Industrial Artificial Pond Permit #3582.
January 31,1992.
Bureau of Land Management. Letter to Cortez Gold Mine Regarding Noncompliance with Artificial Pond
Permit #3582. February 12,1992.
Nevada Department of Wildlife. Notice of Compliance with Industrial Artificial Pond Permit #3582. April
13,1992.
NDEP. Spill Report Form. July 22,1992.
Cortex Gold Mines. Memo to NDEP Regarding Soil Samples From July 21,1992 Spill. August 10,
1992.
Cortex Gold Mines. Spill/Release Record. October 4,1993.

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Page T46|
Cortex Gold Mines. Spill/Release Record. October 16,1993.
Cortex Gold Mines. Spill/Release Record. October 23,1993.
Cortex Gold Mines. Spill/Release Record. October 28,1993.
Cortex Gold Mines. Spill/Release Record. November 30,1993.
Cortex Gold Mines. Spill/Release Record. December 3,1993.
Cortex Gold Mines. Spill/Release Record. December 12,1993.
Cortex Gold Mines. Water Pollution Control Permit NEV0023-1994 Annual Report, Annual Spill and
Release Record. 1994.
NDEP. Complaint/Spill Report Form. November 18,1994.
Cortex Gold Mines. Memo to NDEP Regarding November 18,1994 Spill. November 22,1994.
Cortex Gold Mines. Memo to NDEP Regarding October 29,1995 Spill, October 30,1995.
Cortex Gold Mines. Spill/Discharge Report. October 30,1995

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Page 147
Hycroft Resources and Development, Inc., Crofoot Project:
Spills of Process Solutions
Waste and Material Management Practices: Operations conducted at the facility include open pit mining,
conventional cyanide leaching, and precious metal recovery via zinc precipitation. Lime is added to
crushed ore prior to placement on one of the three clay-lined leach pads. Because annual evaporation in
the region is greater than annual precipitation, the project operates under the condition that no waste
water discharges will occur.
Incident No. 1: On December 4,1994, the facility reported a spill of approximately 30 gallons (or 100
pounds) of liquid sodium cyanide with a concentration of approximately 30 percent cyanide. The spill
was the result of a mechanical failure on a delivery truck.
Remedial ActionfResponse: The chemical supplier's (Cyanco) response team treated the spill area with
hydrogen peroxide and sodium hypochlorite. Soil samples were also taken for analysis.
Incident No. 2: The facility experienced problems associated with electrical power interruptions
compounded by record sub-zero temperatures. During the hours of 6 p.m. to midnight on December 20,
1990, sub-zero temperatures (near-20 F), combined with two separate power interruptions by Sierra
Pacific Power, resulted in several frozen lines on the leachpads. As a result, four header system failures
on Pad 1 and one header system failure on Pad 2 occurred. These failures resulted in isolated
occurrences of heap saturation and resultant blow-outs once power resumed. The blow-outs on Pad 1
did not result in any discharges of solution; however, the blow-out on Pad 2 discharged 1.7 pounds of
sodium cyanide contained in 5,000 gallons of solution into a man-made 100-year storm drainage ditch
between Pad 1 and Pad 2.
Remedial ActionfResponse: The discharge as a result of the blow-out on Pad 2 immediately froze along the
ditch where it flowed. Approximately 200 pounds of calcium hypochlorite were spread over the frozen
spill. Of the 1.7 pounds of cyanide estimated to be contained in the spill, more than 90 percent was
estimated to be contained in ice and not in contact with the soil.
The facility reported the December 20,1990, spill to the Nevada Department of Environmental
Protection on December 21,1990. It was reported as a less-than-reportable (Federal standard) spill;
NDEP concurred the spill was not a permit violation.
Incident No. 3: The freezing leach lines discussed in Incident No. 2 resulted in a gradual raising of solution
storage pond levels to the extent that an estimated total of 300,000 gallons containing 100-150 pounds of
sodium cyanide flowed from the low-preg pond to an earthlined containment dike. Two separate flows
occurred - one on December 24,1990 (estimated 228,000 gallons) and the other on December 27-28,
1990 (estimated 72,000 gallons). These flows contained 76 pounds and 24 pounds of cyanide,
respectively.
Remedial ActionfResponse: The facility arranged for a contractor to remove the frozen spill and contaminated
soil. It also evaluated increasing the lined solution storage area to better handle a recurrence.
Both the December 24 and 27,1990, flows occurred within the built facility boundary. As such, Hycroft
responded as stated in its approved emergency response plan and mitigated as outlined in its water
pollution control permit. The company concluded that no permit violation had occurred. Other reports of
these events were made to the Nevada Division of Emergency Management by telephone on December
28,1990, and by written reports dated December 31,1990, and to the National Response Center by
telephone on January 2,1991.

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Page 148
References:
Memo Regarding Spills of 12/20/90, Hycroft Crofoot Mine.
Spill Report, 12/4/94, Crofoot Mine. Nevada BMRR.
Fact Sheet: Hycroft Resources and Development, Inc., Crofoot Project. Permit No. NEV60013.

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Independence Mining Company Inc., Jerritt Canyon Gold Project
Waste and Material Management Practices: The facility consists of three ore bodies, heap leach pads, an
autogenous/ball mill and crusher, an ore roaster carbon in leach circuit, and a carbon column recovery
circuit.
Tailings are disposed of in an on-site storage pond. There are no springs or wells within the tailings pond
area. The water balance in the pond is controlled by evaporation. There is one small intermittent stream
that flows during the spring season for approximately 2 months. The drainage basin is nearly two square
miles in size and is located to the west of the tailings pond. At the conclusion of the mines life, the water
in the tailings pond will be allowed to evaporate completely, and the tailings area will be covered with
topsoil and seeded. The tailings pond will ultimately contain approximately 10 million tons of solids.
Water for the project is supplied from deep wells. This water is piped to a 600,000 gallon water storage
tank at the mill site. Process water, fire protection water, boiler feed water and domestic water is
provided from this tank. For freeze protection, all the water lines were buried or heat traced. A 5,000
gallon-per-day sewage treatment plant is also located at the mill site. Effluent from the wastewater plant
is piped to the tailing disposal pond. In the mill, all process water and leach liquors will be enclosed in
steel tanks. The tanks were designed such that if leakage occurs, the spilled material flows by gravity in
a ditch to the tailings pond. A 2,500 gallon-per-day sewage disposal plant is located at the mining facility.
The effluent from this unit is piped to a leach field.
On May 26,1996,1,000 gallons of process slurry flowed out of the chlorination building after a tank
valve was inadvertently left open during maintenance operations. The slurry flowed out of the east doors
and into the milk of lime containment area. The slurry contained approximately 0.03% (3.2 lbs.) of
sodium hypochlorite.
On January 11,1996IMCI experienced a power bump at the mill resulting in the overflow of a heap
leach carbon column. The power bump disabled the pump at the end of the heap leach carbon column
train, while the feed pump remained operating. Barren solution overflowed the last carbon column in the
train and flowed out of the building into the driveway area, and into a ditch that drains to the tailings line
drainage pond. Approximately 2,500 gallons of barren solution flowed onto the ground and into the ditch.
The solution contained approximately one pound of cyanide.
On August 21,1995 the south chlorination tank #2 ruptured, resulting in approximately 2,000 gallons of
slurry exiting the east doors of the chlorination building and flowing onto the ground. The tank failure
was attributed to corrosion. The slurry contained 15 pounds of sodium hypochlorite.
On July 11,1995 IMCI experienced a rupture in the south tailings slurry line. The rupture occurred at a
fatigued joint in the pipeline, approximately 100 yards west of the tailings line drainage pond and 50
yards north of the tailings dam. An estimated 2,400 gallons of tailings slurry was discharged to the road
and surrounding ground surface. Less than 10 pounds of cyanide was involved in this spill.
On July 13,1990 chlorine liquid under pressure was released in a gaseous state. The release consisted
of 85
pounds of chlorine and occurred when a 1.25 inch vacuum drain down line developed a hole due to
corrosion.
A green cloud formed and lasted for less than one minute. The release did not leave the mill site and did
not enter any waterway.
Regulatory Action/Response: In response to the May 26,1996 spill, earthen berms were immediately
constructed to contain the slurry. The slurry and affected soils were excavated and placed back into the

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wet mill process. Soil samples were collected from the spill area and sent out for analyses.
In response to the January 11,1996 spill, personnel immediately shut down the heap leach carbon
column feed pump to prevent further release of solution. Ponded solution was vacuumed and
transported to the tailings pond for disposal. Soils were collected in the vicinity of the spill and analyzed
for cyanide. Low j^/els of cyanide, ranging from 0.3 ppm to 4.66 ppm were detected in the soil samples.
The Nevada Division of Environmental Protection determined that it was unlikely that cyanide was able
to penetrate below the top inch of soil since the ground was frozen at the time of the spill.
In response to the August 21,1995 spill, IMCI personnel constructed a berm to contain the spill. The
tank was repaired and placed back into service on August 22,1995. Most of the slurry was removed and
placed back into the chlorination circuit.
In response to the July 11,1995 spill, IMCI personnel shut of the tailings pipeline. The slurry was
removed and placed in the tailings pond. Residual slurry found outside the tailings line drainage pond
was removed and placed in the tailings pond.
In response to the July 13,1990 release of chlorine gas, IMCI contacted NDEP. No further information
was available concerning this mishap.
References:
Independence Mining Company Inc.. Letter to Mr. Joe Guinn, Department of Emergency Management. In
Reference to the July 13,1990 Chlorine Release. 18 July 1990
Independence Mining Company Inc.. Letter to Mr. Doug Zimmerman, NDEP Bureau of Mining
Regulation and Reclamation. In Reference to the July 11,1995spiH. 21 July 1995
Independence Mining Company Inc.. Letter to Mr. Dave Gaskin, NDEP Bureau of Mining Regulation and
Reclamation. In Reference to January 11,1996spill. 19 January 1996
Independence Mining Company Inc.. Letter to Mr. Doug Zimmerman, NDEP Bureau of Mining
Regulation and
Reclamation. In Reference to August21,1995spill. 31 August 1995

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Independence Mining Company Inc.. Letter to Mr. Dan Tecca, NDEP Bureau of Mining Regulation and
Reclamation. In Reference to May26,1996spill. 3 June 1996
Freeport Gold Company. Letter to Mr. Wendal McCurry, NDEP. Reference to wastewater plans. 3 June 1980.
Freeport Gold Company. Letter to Mrs. Christine Thiel, NDEP. Reference to groundwater permitting issues. 28 May
1980

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Kennametal Inc., Falcon Nevada:
Spill of Process Solution to Soil Surface
Waste and Material Management Practices: The site is used for the production of tungsten carbide crystals,
tungsten scrap reclaim mixed blends and tungsten carbide bit recovery. The production of tungsten is
the primary function at this facility. Tungsten carbide crystals are produced by an exothermic reaction or
by the thermit process. This consists of constructing a kiln, preparing a charge material, making
aluminum bags for the charge material, reacting the thermit and after the thermit has cooled and the
crystal mass growth has occurred, and separating the crystal mass from the slag. The iron residues are
then removed through an acid leaching process. Tabling and screening cleans and sizes the particles. A
powder mill operation produces metallurgical powders as part of the operation.
An onsite waste water management facility was constructed in 1992.
On November 12,1991, the facility released between 2 and 4,000 gallons of 93.6% sulfuric acid to the
environment. This was the result of overfilling a 15,000 gallon sulfuric acid tank that was not properly
vented into a secondary containment enclosure.
Type of Impact/Media Affected: Between 2 and 4,000 gallons of 93.6 sulfuric acid were spilled when a 15,000
gallon sulfuric acid tank was overfilled. There were no impacts to waters of the state, wildlife or public
health.
Regulatory Action/Response: The release site was covered with a light layer of hydrated lime and the area
was cordoned off. Additional hydrated lime was placed on the remaining damp spots. The vent line on
the sulfuric acid tank was modified to discharge overflow to secondary containment.
Facility personnel used a backhoe to turn contaminated soil over. The soil was tested for acidity, and
where appropriate, was neutralized with lime. Deeper soil was removed and neutralized. Disturbed soil
was finally smoothed over with a front endloader.
References:
Kennametal Inc.
Kennametal Inc.
Fourth Quarter Report. January 10,1992.
Written Spill Report. November 27,1991.

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Santa Fe Pacific Gold Corporation's Lone Tree Mine:
Process Solution Releases
Waste and Material Management Practices; opearations at the site include an open pit mine, waste rock dumps,
heap leach pads, a carbon in pulp mill, a flotation mill, processing facilities, associated tailings disposal
facility and ancillary mill and mine buildings. All existing mining and processing operations at the site are
permitted through the Nevada Division of environmental Protection, Bureau of Mining Regulation and
Reclamation under Water Pollution Control Permit NEV90058.
The facility has had several releases to the environment between 1990 and 1996. These releases were
the results of mechanical failures and operator error.
Incident #1 On September 7,1993, the facility released approximately 5000 gallons of barren leach
solution containing 8.3 pounds of sodium cyanide. The release occurred at the heap leach pad when an
8 inch header line broke.
Type of Impact/Media Affecte± Approximately 5000 gallons of solution were spilled at a concentration .4
lbs/ton , resulting in an estimated release of 8.3 pounds of NaCN.
Regulatory Action/Response: The facility excavated approximately 130 cubic yards of contaminated soil The
soil was then transported to the heap leach pad.
Incident #2: On April 21,1995, the facility released approximately 36,000 gallons of barren leach solution
containing 17.4 pounds of cyanide. The release occurred at the Phase lll/IV heap leach area when
hugger fitting on a 4 inch barren solution pipe came apart.
Type of ImpactfNIedia Affected: Approximately 36,000 gallons of solution were spilled resulting in an
estimated release of 8.3 pounds of NaCN.
Regulatory Action/Response: The pipes were shut off, and catch basins were built to retain the released
solution. Approximately 17,000 gallons of solution were returned to the pads from the catch basin.
Scrapers removed the contaminated soil.
Incident #3: On November 26,1994, the facility released 10-30,000 gallons of process solution at an
approximate concentration of 0.288 g/L, resulting in between 24 and 72 pounds of sodium cyanide
solution. The release occurred at the heap leach access road when hugger fitting on a 12 inch line in a
ditch froze and blew its coupling. This allowed the sodium cyanide solution to spray outside the lined
area.
Type of ImpactlMBdie Affecte± Approximately 10-30,000gallons of solution were spilled resulting in an
estimated release of 24-72 pounds of NaCN.
Regulatory ActionfResponse: The contaminated soil was excavated and removed to the Sonoma Leach Pad.
The coupling was replace and the damaged ends of the pipe were repaired.
Incident #4: On November 28 1994, the facility released approximately 5,000 gallons of tailings slurry,
resulting in the release of 1.47 pounds of cyanide solution. The release occurred at the tailings delivery
line when a contractor punctured the tailings line with the blade of a motor grader
Type of Impact/Media Affected: Approximately 5,000gallons of tailings slurry were spilled resulting in an

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Page 154
estimated release of 1.47 pounds of NaCN.
Regulatory Action/Response: Approximately 200 yards of contaminated soil was excavated and removed to
the tailings impoundment. The damaged area of the line was repaired.
References:
.SFPGC. Lone Tree Mine Acid Mine Drainage Mitigation Plan (page 1-1). September 27,1993.
SFPGC. Written Spill Report. Septembers, 1993.
SFPGC. Written Spill Report. May 1,1995.
SFPGC. Written Spill Report. December 6,1994.
SFPGC. Written Spill Report. December 6,1994.

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Western States Minerals Corporation, Northumberland Project
Initiated Clean-Up Efforts
Waste and Material Management Practices; This project consists of open pit mining with ore processing by
conventional heap leach cyanidation as well as precious metal recovery by carbon adsorption. The
facility is required to operate and close with no discharges or releases except for extraordinary
meteorological or stochastic events.
The project maintains four discrete but interconnected leach pads covering approximately 42.4 acres.
The subbase for leach pads 1,2, and 3 consists of compacted native soils. A leak detection and
collection system consisting of a pipe network was installed beneath those portions of the 60 mil HDPE
primary liner where process fluids accumulate on top of the pad. Leach pad 4 was constructed on a
prepared subbase consisting of 12 inches of imported, low permeability soil. The primary liner is 60 mil
HDPE and is underlain by leak detection strips on 15 foot centers. There are three process ponds on site
lined by compacted native soils. This layer is overlain by 20 mil PVC on which geotextile is installed,
extending up the pond side slopes. The primary liner for ail three ponds is 40 mil HDPE.
On December 3,1991, a gravity flow return line connecting leach pad 2 to the pregnant solution pond
failed. Approximately 115,500 gallons of pregnant solution was lost with a total of 0.386 pounds of
cyanide released. On December 17,1991, another broken pipe was discovered near the barren pond. It
was determined that approximately 12,000 gallons of pregnant solution was spilled, containing 0.160
pounds of cyanide. Both of the December spills were believed to have been caused by the cold
temperatures, splitting the pipes and joints. On January 9,1991, as a result of snow removal efforts, a
raw water well was compromised. 13,500 pounds of raw water was released containing 0.0605 pounds
of cyanide.
Type of Impact/Media Affected: Large quantities of raw water and pregnant solution have spilled on the
Northumberland project, with most occurring in 1991. The combined total spilled in 1991 and the early
portion of 1992 is 141,000 gallons. The estimated total cyanide released as a result of these spills is
0.611 pounds.
Regnlatory Action/Response: In August of 1991, a U.S. Forest Service (USFS) District Ranger ordered
WSMC to remove contaminated soil from diesel and oil spills by mid-November of the same year.
WSMC followed these orders and disposed of the soil properly. As a result of the August field review
and the supposed failure by WSMC to report cyanide spills exceeding the quantities that require a report
to NDEP, USFS called the National Response Center (NRC).
On September 3,1991, USFS ordered WSMC that any wood, plastic, metal barrels, or sludge in the
make-up pond, not be removed until a disposal method was agreed upon by all responsible agencies.
On September 17,1991, a site visit was conducted by USFS and the Nevada Department of
Environmental Protection (NDEP) Bureau of Waste
Management. Information gathered at the time of the visit indicated that WSMC may be in violation of
various State and Federal Regulations. As a result, WSMC was ordered by NDEP to "Cease and Desist"
from the discharge or disposal of hazardous waste or pollutants to the environment, and from on-site
storage of such hazardous waste for greater than 90-days; by October 14,1991 submit a letter of intent
to assess and
remediate violations; submit by November 8,1991 a detailed Site Assessment Plan for review and
approval; begin such Site Assessment within 30 days of approval of the Site Assessment Plan; submit a
Site Assessment Report which details the assessment results and findings; submit a Site Remediation
Plan; and begin site remediation within 30 days of approval of a Site Remediation Plan.
On October 2,1991 WSMC was ordered by the NDEP Bureau of Mining Regulation and Reclamation to

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Page 156
make various repairs to leach pad ditches, liners, berms; remove material overtopping leach pad berms;
make modifications to leak detection pipes and sumps; remove, place on containment, and sample all
material in the make-up water pond; and evaluate the area of potential contamination where solution
pipes converge near the barren ponds.
NDEP contacted WSMC on January 7,1992 in response to the three successive spills in late 1991 and
early 1992. It was questioned by NDEP as to whether WSMC was adequately managing their system.
NDEP requested that any additional spills, regardless of the quantity of cyanide released, be reported in
the future.
Regulatory Action/Responses: WSMC responded to both NDEP's Bureau of Waste Management and Bureau
of Mining Regulation and Reclamation promptly. WSMC completed the aforementioned actions, and
has established and maintained a cooperative relationship for the overall benefit of the general public
and the various governmental and regulatory agencies.
References:
Western States Minerals Corporation, Letter to Mr. Thomas J. Fronapfel, P.E. Bureau Chief for Nevada
Division of Environmental Protection. Response to section IIIA of the Order dated October 11991.15 November 1991.
Western States Minerals Corporation. Facility Fact Sheet (pursuant to NAC 445.148). April 1989.
Western States Minerals Corporation. Facility Fact Sheet (pursuant to NAC 445.148). July 1990.
Western States Minerals Corporation. A Comprehensive Synopsis of Affairs Relating to Environmental Issues at Western
States Minerals Corporation's Northumberland Mine, Nye County, Nevada. 9 February 1992.
Western States Minerals Corporation. Letter to Mr. Mike Lucchesi, Environmental Engineer, NDEP.
Northumberland Mine Environmental Progress Report, USFS Issues. 7 July 1992.
State of Nevada, Division of Environmental Protection. Letter to Mr. Dwight Crossland, Western States
Minerals Corporation. Findings of Alleged Violation and Order issued pursuant to Nevada Revised Statutes 445.317end445.324.
2 October 1991.

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BHP Copper, Magma Nevada Mining Company:
Process Releases to Surface Waters and Soils
Waste and Materials Management Practices: Magma Nevada Mining Company took control of all mining
operations in the Robinson District in 1991. The project has three main components including:
conventional open-pit mining, milling and flotation of sulfide ore, and leaching of mixed oxide and sulfide
ore. Magma has constructed new facilities including a concentrator for recovery of copper,
molybdenum, gold, and silver, as well as a two-phase concentrator circuit tailings impoundment and
associated collection ponds. The site includes open pit mines, waste rock dumps, a copper heap leach
pad, and associated pregnant intermediate and raffinate leach solution ponds.
In the milling operations, conventional copper flotation technology is used in the concentrator circuit to
process 35,000 to 45,000 tons of ore daily. The mill process water pond receives both well water and
reclaim water from the tailings impoundment. The pond has primary and secondary 60-mil HDPE
synthetic liners, a leak detection/collection system, a leak collection sump, and an eight inch diameter
PVC evacuation pipe. Changes have been incorporated into pond design to prevent unauthorized
discharge(s) during 25 year, 24 hour storm events.
The copper leaching operation consists of a three-phase leach pad constructed of an 80-mil VLDPE
primary liner underlain by a six-inch leak detection layer of granular material. Perforated pipes have
been placed within the detection layer beneath all pregnant solution collection pipes and channels and on
the upstream side of cell separation berms. Cell seepage is routed to separate external sumps. Three
process solution ponds with 80-mil HDPE primary liners and 60-mil HDPE secondary liners have been
constructed. Geonet or similar material between the liners will provide a flow path to the pond leak
detection sump.
BHP Copper/Magma Nevada Mining Company experienced eight reported spills during 1996. Most of
these spills involved copper flotation tailing solution and reclaim water releases do to equipment failures.
One spill involved release of sodium cyanide process solution due to equipment failure.
Type af Impact/Madia Affected: The five spills resulting in releases of copper flotation tailings had spill
volumes ranging from from 1,500 gal to 66,000 gal. Four of these spills resulted in contamination of
relatively small areas of soil. The largest spill resulted in contamination of a downstream drainage bed
for 2.3 miles with an average flow path width of 3 ft. Two spills resulted in a combined release of 76,000
gal of reclaim water. The last spill reported involved release of 2,000 gal of sodium cyanide process
solution onto a nearby roadway and soils. A total of 0.01 lbs of CN was released.
Regulatory ActionfResponses: The Nevada Division of Environmental Protect (NDEP) found that BHP Copper
was in violation of Nevada Revised Statutes 445A.465 which state that "Injection of fluids through well or
discharge of a pollutant without a permit is prohibited." for release of 66,000 gallons of copper flotation
tailings on February 12,1996. The spill was contained within check dams, the cyclones shut down , and
the tailings diverted to an overflow channel inside the impoundment. BHP Copper contacted the BLM to
identify appropriate remediation efforts. State records indicate that a remediation action plan was
submitted and approved by the NDEP. Furthermore, In August of 1996 the NDEP notified BHP Copper
that it was in violation of its Water Pollution Control Permit due to increased levels of Total Dissolve
Solids and pH. BHP Copper presented an analysis of options for addressing levels of TDS and pH to the
NDEP. Remediation measures taken for the remaining spills involved flow stoppage, removal of
contaminated soil and excess solution, recycling of materials back into the process, and repair of faulty
equipment.
References:
Nevada Division of Environmental Protection (NDEP). Fact Sheet regarding BHP Copper, Magma

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Page i 58J
Nevada Mining Company, Robinson Mining Limited Partnership. March 15,1993.
Magma Nevada Mining Company. Spill/Release Record. February 12,1996.
NDEP. Inspection Follow-up Report. February 16,1996.
NDEP. Complaint/Spill Report Form. March 21,1996.
Magma Nevada Mining Company. Follow-up Summary Regarding March 20,1996 Spill. March 25,
1996.
BHP. Follow-up Summary Regarding April 21,1996 Spill. April 22,1996
NDEP. Complaint/Spill Report Form. April 22,1996
NDEP. Finding of Alleged Violation and Order. May 2,1996.
NDEP. Complaint/Spill Report Form. May 10,1996.
NDEP. Complaint/Spill Report Form. May 17,1996.
NDEP. Complaint/Spill Report Form. May 29,1996.
BHP. Spill/Release Record Regarding May 27,1996 Spill. May 29,1996.
NDEP. Complaint/Spill Report Form. June 7,1996.
BHP. Follow-up Summary Regarding June 6,1996 Spill. June 11,1996
NDEP. Complaint/Spill Report Form. June 24,1996.
Interscience Technology. Report Regarding Options for Lowering TDS and pH Levels at BHP Copper.
August 2,1996.
NDEP. Finding of Alleged Violation and Order. August 20,1996.
BHP. Summary of Actions and Research taken by BHP Nevada Mining Company. August 21,1996.

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Round Mountain Gold Corporation, Smoky Valley Common Operation:
Process Releases to Soil Surfaces
Waste and Materials Management Practices: The facility consists of an open pit mine, waste rock dumps, leach
residue dumps, reusable, asphalt-lined heap leach pads, and existing dedicated pad, a new dedicated
facility, process and storm event ponds, processing facilities, and a permanent placer plant.
The facility is divided into north and south areas; each possessing two leach pads. The north area leach
pads are constructed with a five inch layer of asphaltic concrete above a rubberized membrane followed
by a two inch layer of hydraulic asphaltic concrete. The asphalt liner systems are situated on top of
scarified and recompacted native soils. The pads do not possess leak detection systems, but are
visually inspected following off-loading of spent ore. The north area possesses barren, leak, and
pregnant sumps and one event pond, all of which are lined with an asphalt-rubber membrane above
compacted native soils. No leak detection system exists, but a down-gradient vadose monitoring well
has been installed to monitor groundwater quality.
The south area possesses two reusable leach pads constructed of seven inches of asphaltic concrete.
Solution collection pipes that run the lentgh of the pads are provided for leak detection. The southern
solution pond has a primary liner of 40-mil HDPE and a secondary liner of 30-mil PVC. Barren and
evaporation ponds in the south are double-lined and possess leak detection systems. Twenty-five year,
24-hour storm even flows from the southern pad are captured by a storm event pond. The Round
Mountain mine possesses an older dedicated pad with associated ponds. A newer dedicated pond is
being constructed in phases.
Three spills involving between 4,515 and 7,015 gallons of cyanide solution occurred at the Round
Mountain mine in the period of 1992-94. Two of the spills resulted from problems with either the
operation of a leach pad or flawed repairs to the leach pad. The third spill was a result of a equipment
failure and operator error.
Type of Impact/Media Affected: On March 18 1992, inadequate percolation in a section of the leach pad
caused ponding of leaching solution on top of the pad. A portion of the ponded solution overflowed into
the collection ditch where a plug subsequently formed. As a result of the plug the ditch overflowed
releasing 2,000 gal of cyanide solution in a run 200 ft south of the pad. On March 24,1992, between
2,500 and 5,000 gal of process solution containing between 11.5 and 22.9 lbs of sodium cyanide spilled
contaminating soil and a road bed. The solution leaked through the leach pad berms following operator
and management error in repairs to reshape the leach lines. The last spill occurred in October of 1994
and involved 15 gallons of liquid cyanide solution containing 45 lbs of dry cyanide. The spill resulted
when a gasket on an overfilled delivery truck burst.
Regulatory Action/Responses: Remediation efforts for each spill event involved removal of contaminated soil
and placement of the soil on top of the leach pad for re-leaching. In the first spill, 75 lbs of calcium
hypochlorite was used to neutralize the soil prior to soil removal. Remediation in the second spill event
involved neutralization of remaining cyanide with calcium Hypochlorite. The plugged ditch was cleaned
to allow for free-flow of solution. In addition, the solution application rate in the area of low percolation
was reduced to prevent further ponding of solution. Regarding the third spill, 15 cubic yards of soil was
recycled on top of the leach pad.
References:
Round Mountain Gold Corporation, Smoky Valley Common Operation. Letter to NDEP Regarding March

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18,1992 Spill. March 23,1992.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Letter to NDEP Regarding March
24,1992 Spill. March 26,1992.
Bob Carson, Nevada Division of Environmental Protection (NDEP). Fact Sheet Regarding USMX, Inc.,
Alligator Ridge Mine. May 1994.
NDEP. Complaint/Spill Report Form. October 10,1994.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Hazardous Materials Release
Follow-up Report. October 12,1994.
NDEP. Complaint/Spill Report Form. October 13,1994.
Round Mountain Gold Corporation, Smoky Valley Common Operation. Memo to NDEP Regarding
October 7,1994 Spill. October 13,1994.

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Nevada Gold Mining, Inc, Sleeper Project:
Spills of Process Solution to Soil Surfaces
Waste and Materials Management Practices:
Operations conducted at the facility include gold production using open pit mining and heap leaching of
gold ore. Sleeper Project consists of two active pits, a mill/process plant, two tailings impoundments, a
seepage collection pont, waste/overburden dumps, three pregnant ponds, a barren pond, two overflow
ponds, heap leach phases l-IV and two proposed phases (V and VI).
Existing heap leach pad (phases I & II) consists of 60-mil HDPE primary liner on a compacted layer of
natural silty sand. The phase I leach pad includes an electronic leak detection system embedded in the
silty sand. Phase II leach pad has possesses no leak detection. The Pad 2 and 3, phase III & IV leach
pads, consist of 6-mil HDPE primary liner on four inches of compacted lay above eight inches of
compacted natural silty sand. Phase III & IV leach pads include electronic leak detection systems.
Containment for the pregnant, overflow, and barren ponds for phases I, II, II, & IV consists of a 60-mil
HDPE primary liner, one foot of compacted clay, a four-inch sand layer between embankment liners, and
four- and six- inch gravel layers (lower and upper, respectively) between layers. The leak detection
systems consist of a six-inch diameter pipe located between the primary and secondary liners.
Two tailings impoundments have of a one-foot clay liner situated below one foot of sand. Seepage from
the impoundments flows to the seepage pond via a network of four-inch perforated pipes. The seepage
pond is lined with of 60-mil HDPE primary and secondary liners. Any leakage from primary containment
flows via a gundnet between the liners to a sand filled leak detection sump.
Facilities are designed to contain 25-year/24-hour storm event flows. The facilities are required to be
designed, constructed, operated and closed without discharge or release in excess of standards
established in regulations except during meteorological events exceeding the design storm event.
Three spills occurred at the facility during 1995 and 1996. As a result of broken pipes and ruptured
pumps, a total of 45,089 gallons of process barren solution containing sodium cyanide (NaCN) was
released into the surrounding soils.
Type of ImpactjMedia Affecte± In June of 1995, 748 gallons of barren solution containing 0.75 lbs NaCN was
released when a hose connection failed, soaking 100 square feet of soil to a depth of one inch. This spill
was followed a month later by a release of 27,540 gallons of solution and 4.6 lbs of sodium cyanide into
surrounding soils. In this case, a feeder pipe broke off the main header pipe. The third spill occurred in
August of 1996 when a barren solution discharge pump ruptured. It resulted in 16,801 gallons of barren
solution being discharged containing 5.8 lbs of NaCN. None of the spills resulted in contamination of
surface or groundwater.
Regulatory Action/Responses: The facility repaired all causes of the reported spills (broken feeder pipes, split
discharge hose, and ruptured pumps). In all cases, the source of flow was immediately shut down upon
leak detection and the faulty equipment repaired. In the two largest spills, contaminated soils was
removed and put on top of the leach pad. Soil samples were taken to determine the necessity of further
remediation efforts. Samples from the July, 1995 spill indicated that no residual soil had cyanide over
0.2 mg/l; no data were available for the August 1996 spill. The smaller spill, the soil was treated by
photodegradation and left in place pending soil analysis to determine if the remaining concentration
warranted further remediation efforts. In all cases, appropriate regulatory agencies were notified soon
after leak detection.
References:

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— 				"		---¦—¦¦
Page 162 i
Bob Carlson, Nevada Division of Environmental Protection (NDEP). Fact Sheet regarding Nevada Gold
Mining, Inc., Sleeper Project. December 19,1990.
Sleeper Mine. Spill/Release Record. June 5,1995.
NDEP. Complaint/Spill Report Form. June 6,1995.
Nevada Gold Mining, Inc. Memo To Duty Officer, Nevada Division of Emergency Management,
Regarding June 4,1995 Spill. June 6,1995
NDEP. Complaint/Spill Report Form. July 10,1995.
Sleeper Mine, Record of Communication with NDEP Regarding July 10,1995 Spill. July 10,1995
Sleeper Mine. Spill/Release Record. July 10,1995.
Nevada Gold Mining, Inc. Memo to Duty Officer, Nevada Division of Emergency Management,
Regarding July 10,1995 Spill. July 19,1995.
Sleeper Mine, Record of Communication with NDEP Regarding Spill Clean Up Analysis Results. August
3,1995
NDEP. Complaint/Spill Report Form. August 13,1996.
Sleeper Mine. Spill/Release Record. August 15,1996.
Nevada Gold Mining, Inc. Memo to Bureau of Mining Regulation and Reclamation Regarding August 13,
1996 Spill. August 22,1996.

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WirWWSIWCTITOITO]
Pap 163|
Wind Mountain Mining's Wind Mountain Project:
Spills of Process Solution to Soil Surfaces
Waste and Material Management Practices:
The facility extracted ore from an open pit mine. The ore is processed by conventional heap leach
cyanidation with precious metal recovery by zinc precipitation. Mining ceased in January 1992, die to
depletion of reserves. Residual leaching is continuing.
Ore from the mine is crushed and loaded onto the heap leach pad. Buffered sodium cyanide is pumped
from the barren pond and sprayed on the heap. The leachate is collected in a perforated pipe network
on top of the pad liner. A valve system allows the solution to be sent to the pregnant, countercurrent or
barren pond. These ponds are double lined with HDPE primary liner and compacted clay secondary
liner. The liners are separated by a one-foot layer of sand that drains any fluids to a sump. All three
ponds have leak detection system.
The leach pad, solution ponds and recovery facility is surrounded by a runoff diversion system. The
diversion system retention ponds are designed to contain the operating volume of over 6 million gallons
of process water plus the cumulative runoff from a 25-year, 24-hour storm event.
The facility has reported one spill of sodium cyanide between 1990 and 1996. The release occurred as a
result of operator error. On October 18,1991, an unauthorized release of sodium cyanide occurred when
a valve directing barren solution to a cyanide mix tank was inadvertently left open. A bin of cyanide
briquettes was dumped into the mixing tank. The tank was then filled, and (with the combined barren
solution) overflowed the containment area.
Type of Impact/Media Affected Approximately 1000 gallons of solution were spilled at a concentration 27
lbs/ton , resulting in an estimated release of 112 pounds of NaCN. The soil did not absorb much of the
solution due to the clayey nature of the soil and the slope around the mix tank and solution ponds.
Regulatory Action/Response: The facility excavated the soil to a depth of 12 to 18 inches. The soil was then
transported to the heaps. And, a solution of calcium hypochlorite was applied to the excavated spill
areas. After testing for, and finding the presence of WAD Cyanide, Calcium hypochlorite was reapplied
to the spill area.
References:
Dean Mierau. Fact Sheet. March 1990.
Wind Mountain Mining, Inc. Written Spill Report. November 5,1991.

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			Page 164
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Phelps Dodge's Chino Branch:
Multiple Tailings Spills
Wastes and Material Management Practices: Operations conducted at the Chino Mine include an open pit
copper and molybdenum mining; dump leaching of ore; beneficiation via crushing, regrinding and froth
flotation; refining; and smelting. The ore is extracted from the pit, processed in a ball mill; and
separated in a five stage crushing/screening plant. The copper and molybdenum are concentrated in a
froth flotation mill using raconite and pine oil as flotation re-agents. The concentrator yields a product
that is 21 percent copper, 32 percent iron, and 0.5 percent molybdenum.
In addition to the crushing/flotation circuit, Chino employs a dump leach/solvent
extraction-electrowinning (SX-EW) circuit for the extraction of copper, molybdenum, gold and silver. The
SX-EW plant began operations in 1988 with an annual operating capacity of 45,000 standard tons (st)
electrowon copper. Production in 1991 was 55,200 st. Chino also operates a smelter onsite, with an
annual capacity of 550,000 st; and an acid plant producing 550,000 st annually.
The mine, mill, and waste treatment complex is located in the Whitewater Creek watershed near Hurley,
NM. The creek has been diverted around the complex, but experiences flows during precipitation
events.
During 1990 and 1991, Chino experienced two major releases to the environment. On November 22,
1990,1440 gallons of raffinate escaped from the raffinate pond. The leak was determined to have been
caused by several small tears in the pond liner. On August 12,1991, 3,200 gallons of tailings were
released into Whitewater Creek when a tailings pipeline ruptured. In 1993, 208 tons and 91,500 gallons
of tailings in six separate incidents were accidentally released to Whitewater Creek. In each instance,
degraded pipes ruptured, releasing a mix of tailings and tailings water to the Creek. Similar releases in
1994,1995, and 1996 resulted in an additional 140,000 gallons of tailings being released to Whitewater
Creek.
In August of 1994, elevated levels of copper and low pH were observed in monitoring well SWIX-2
(located near the SX-EW plant). Inspection of the SX-EW circuit revealed a small fracture in a sump
used to pump spent electrolyte from the plant to the raffinate pond. The crack had allowed small
amounts of raffinate to escape on a periodic basis.
Type of Impact/Media Affected: The numerous tailings spills impacted surface waters and the creekbed of
Whitewater Creek. Impacts included: elevated TDS and metals in surface water (when present in the
stream).
Where the spent electrolyte leaked from the SW-EX circuit, the solution penetrated the soil and migrated
along the bedrock surface and eventually entered the Old Tin Can Mine workings (where SWIX-2 is
located.
Regulatory Action/Responses: In the case of each of the tailings spills, Chino personnel addressed the release
in a similar manner. First, all pumps feeding the ruptured pipeline were shut down. Second, emergency
berms were erected to contain the spill and/or prevent the fluid fraction from reaching Whitewater creek.
Crews vacuumed the water and removed it to the tailings pond. The tailings, impacted surface soils, and
creekbed were excavated and placed atop the tailngs pile. The New Mexico Environmental Department
issued a Notice of Violation for the 8/12/91 release of 3,200 gallons of tailngs to Whitewater Creek.
The Corrective Action Report (approved by the NMED) indicated that remediation of the spent electrolyte
plume detected by SWIX-2 was accomplished by conducting repairs to the damaged sump. Monitoring
of well SWIX-2 indicated a return to normal parameters with 6 months of the effective date of the repair
to the sump.

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References:
Milovich, D., Manager, Chino Mines Co. November 28,. 1990. Letter to S. Carey, NMED Re: November
19,1990 Tailings Spiii. Chino Mines Co., Hurley, NM.
Milovich, D., Manager, Chino Mines Co. August 16,. 1991. Letter to S. Carey, NMED Re: August 12,
1991 Tailings Spill. Chino Mines Co., Hurley, NM.
Milovich, D., Manager, Chino Mines Co. September 25,1991. Letter to S. Carey, NMED Re: Corrective
Actions Taken in Response to August 12,1991 Tailings Spill. Chino Mines Co., Hurley, NM.
Caiy, S., Acting Chief, NMED, Groundwater Protection Bureau. September 6,1991. Notice of Violation:
Discharge Permit - 213, Chino Mine. NMED, Santa Fe, NM.
Milovich, D., Manager, Chino Mines Co. October 4,1991. Letter to S. Carey, NMED Re: Response to
Notice of Violation Issued Septembers, 1991. Chino Mines Co., Hurley, NM.
Milovich, D., Manager, Phelps Dodge Chino Branch. August 10,1992. Letter to S. Carey, NMED Re:
August 4,1992 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Cary, S., Acting Chief, NMED, Groundwater Protection Bureau. September 2,1992. Approval of
Corrective Action Report Re: August 4,1992 Tailings Spill. NMED, Santa Fe, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. August 4,1994. Letter to Dale Doremus, NMED Re:
Anomalous Readings in SWIX-2 Monitoring Well. Phelps Dodge Chino Branch, Hurley, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. November 28,1994. Letter to Dale Doremus, NMED
Re: Anomalous Readings in SWIX-2 Monitoring Well. Phelps Dodge Chino Branch, Hurley, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. January 9,1995. Letter to Karen McCormack,
NMED Re: January 2,1995 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. April 16,1996. Letter to Marchell Schuman, NMED
Re: April 11,1996 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Brock, W. Manager, Phelps Dodge Chino Branch. August 5,1996. Letter to Marchell Schuman, NMED
Re: July 26,1996 Tailings Spill. Phelps Dodge Chino Branch, Hurley, NM.
Cobre Mining Co/s Continental Mine:
Multiple Tailings Spills and Seeps
WastBs and Material Management Practices: the facility operates an underground copper mine, grinding mill,
and a flotation mill for copper recovery. Tailings are pumped via pipeline to a tailings impoundment.
During 1995 and 1996, five separate releases were reported. These releases included 6,000 gallons of
mill process water; 80,000 gallons of sediment pond water 2,000 gallons of tailings; 30 - 50,000 gallons
mill slurry discharge; and a spill of between 17,500 and 52,500 gallons of water and tailings. In each of
these instances, equipment failure or human error caused the solution to escape from the waste
management system and enter Hanover Creek.
In 1996, four seeps were detected at the facility. Three seeps at the magnetite pond were discovered
during a compliance inspection by New Mexico State personnel. The source of the liquids causing the
seeps was determined to be a broken valve in an old feed line, and seepage from under the main tailings
pond, located directly up gradient from the magnetite pond. The total flow for the three seeps was less

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than 3 gallons per minute.
An acid seep from the west wasterock dump was discovered in July of 1996. This seep had a flow of 10
gallons per minute, and a pH of 3.5 (exceeding both surface water and groundwater standards). The
seep was discharging into Blackhom Gulch and Hanover Creek. The cause of the seep was determined
to be unusually high volume precipitation events.
Type of ImpactfMedia Affeete± the five tailings and process water spills resulted in short term impacts to
Hanover Creek. Total dissolved solids, and turbidity increased, and the tailings coated the creek bed.
The 17,500 - 52,500 gallon release included residue from an alcohol based frother and a hydrocarbon
based collector. This spill also exceeded permittable levels of cadmium, lead, total nitrogen, and sulfate.
The seep with a pH of 3.5 from the waste rock pile contributed highly acidic water to Hanover Creek.
Regulatory Action/Responaes: For each of the five spills, new equipment was added, and berms, and
emergency spill catchment areas were constructed to prevent the same spill from recurring again.
Tailings solids and impacted soils were collected via front end loader and by hand and placed on the
tailings pile.
Remediation for the three seeps identified in the magnetite pond included construction of a lined
containment pond and pumpback system and the installation of a monitoring well to determine if the
underlying aquifer was impacted.
The remedial effort for the ARD seep discovered in the waste rock pile consisted of constructing a
containment area and gravity feeding the ARD to the make up water tanks via a 2" pipe.
References:
Rempes, Charles, Manager, Continental Mine. May 15,1995. Letter to Dale Doremus, NMED Re: Mill
Process Solution Spill of May 9,1995. Cobre Mining Co., Hanover, NM.
Rempes, Charles, Manager, Continental Mine. October 30,1995. Letter to Dale Doremus, NMED Re:
Mill Process Solution Spill of October 23,1995. Cobre Mining Co., Hanover, NM.
Rempes, Charles, Manager, Continental Mine. January 29,1996. Letter to Dale Doremus, NMED Re:
Previously Unidentified Seeps from the Magnetite Tailings Pond. Cobre Mining Co., Hanover, NM.
Leavitt, Mary, Chief, Groundwater Quality Bureau, NMED. April 15,1996. Letter to Cobre Mining Co.
Responding to Corrective Action Plans. New Mexico Department Of Environment, Santa Fe, NM.
King, Glenn, Manager, Continental Mine. June 26„ 1996. Letter to Marchell Schuman, NMED Re:
Overflow of Seep Containment Facility of June 14,1996. Cobre Mining Co., Hanover, NM.
Leavitt, Mary, Chief, Groundwater Quality Bureau, NMED. August 30,1996. Corrective Action Report,
DP-181: Discharge of Low pH Seep In Upper Buckhom Gulch. New Mexico Department Of
Environment, Santa Fe, NM.
Bokich, John, Manager, Continental Mine. November 14„ 1996. Letter to Marchell Schuman, NMED
Re: Corrective Action Report of Slurry Line Incident, November 14,1996. Cobre Mining Co., Hanover,
NM.

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¦MJWWWmWWMMJW.
Page 167;
Ortiz Project IV:
Remediation of Groundwater Contamination and Acid Rock Drainage
Wastes and Material Managflineiit Practices: The facility is an open pit gold mine with old underground and
open pit workings and an abandoned mill. LAC Minerals (formerly in partnership with Pegasus Gold) is
planning to commence production at the mine using heap leaching for gold extraction. Permits to begin
operations have not been issued pending resolution of the acid rock drainage (ARD) problems at the site.
Goldfields, Inc. operated the Cunningham Mill and Mine, and the Delores mine in the 1980s. After
suspending operations, the site was taken over by a partnership of Pegasus Gold and LAC Minerals.
The new mine was named the Ortiz Project and encompasses the old workings.
A 45 acre spent ore pile has contaminated the groundwater with nitrate and cyanide. Pegasus/LAC was
issued a permit to begin pumping groundwater near the base of the spent ore pile. The contaminated
groundwater was treated by land application. A constructed wetland was installed and operated on a
pilot scale basis from October of 1991 to June of 1993. Remediation of the spent ore pile involved
recontouring for positive drainage; discing lime into the pile, installing a cap to prevent infiltration of
oxygen and water; and revegetation. The permit to operate the land application system required
Pegasus/LAC to continue to operate the system for two years after monitoring indicated that the
contaminant levels in the groundwater had been reduced to permitable levels.
In October of 1992, Pegasus/LAC received permission to begin remediation of the waste rock pile, which
until that time was producing ARD. Remediation of the waste rock pile included installing drainage
diversions capable of handling a 100 year - 24 hour storm event around the pile; recontouring; adding
drainage benches; and capping to prevent infiltration.
In order to treat the ARD then being generated in the waste rock pile, an ARD treatment system was
installed. This system was composed of a cutoff trench to intercept the ARD at the toe of the pile; a
pump-back system to remove the ARD to a treatment facility (located on top of the waste rock pile); a
lime silo for treating the ARD, and a series of unlined evaporation trenches installed on the top of the
pile. Two monitoring wells were installed down gradient of the pile to monitor groundwater quality.
In October of 1996, LAC Minerals (who took over the site after Pegasus left in late 1992) received
permission to modify its ARD treatment plan. The modifications included adding a new, lined ARD
collection pond; replacing the treatment system with a new system down gradient in Delores Gulch;
constructing sludge de-watering cells as part of the leachate treatment system; and constructing a
half-acre evaporation pond to provide final containment and elimination of the ARD.
References:
Summary of Technical Testimony, Public Hearing on the Pegasus Gold Project IV, by Robert Garcia,
P.E., Environmental Engineer. September 28,1992.
New Mexico Environment Department. October 19,1992. Proposed Findings of Fact, In The Matter of
the Application of Pegasus Gold Corp. For Renewal/Modification of Discharge Plan #55. Submitted
Before the Secretary of the Environment for the State of New Mexico.
Boteilho, Leonard, Project Manager, Ortiz Project IV. October 8,1996. Application of LAC Minerals for
Third Modification of DP-55. LAC Minerals, Santa Fe, NM.

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Molycorp's Questa Mine:
Multiple Tailings Spills
Wastes and Material Management Practices: Operations conducted at the facility include underground mining of
molybdenum ore and beneficiation by crushing, grinding and concentrating prior to shipment to an
off-site refiner.
Mill capacity at Questa is 15,000 tons per day. Three stage crushing is followed by screening for single
stage rougher flotation, using cyclones for classification. Regrinding, cleaning, and recleaning stages are
then employed to increase the flotation concentrate to a marketable grade. The concentrate is then
filtered, dried, and packed for shipment.
Tailings from the concentrator are pumped to a tailings impoundment located 8.5 miles from the mill
building. The pipeline is constantly patrolled by Molycorp personnel to prevent pollution of a recreation
area. Three sources of wastewater (mine decant water, tailings decant water, and seepage from the
tailings dam) are discharged to the Red River under a NPDES permit. The mine has not received a
permit to discharge from the State of New Mexico. Sampling data submitted by Molycorp indicate the
discharge is within the parameters of the NPDES permit. Molycorp suspended mining/milling operations
at Questa in January 1992, citing a saturated world market and depressed molydenum prices. Questa
resumed operations in June of 1996.
The Questa mine experienced five tailings spills in 1990 and three spills in 1991. All spills resulted from
ruptures in the 8.5 mile tailings pipeline. Releases ranged from 22,500 gallons to 1,000 gallons.
Reasons for the releases included ruptured pipes due to normal wear and a puncture of the pipeline
during routine maintenance operations. Tailings solids and water were contained by a series of
emergency sumps and berms. In several instances, tailings flowed outside the bermed areas, impacting
irrigation ditches and private property bordering the mine site. In once instance, tailings covered
approximately one half acre of an alfalfa field to a depth of one half inch.
Remediation of these spills involved mechanical and hand cleanup of tailings solids, which were then
deposited in the tailings pond. Inspection reports submitted by New Mexico Groundwater Protection and
Remediation staff indicate that the spill sites were remediated promptly.
On May 21,1991,139 tons of tailings were spilled when a pressure surge separated the tailings pipeline
at a coupling. The tailings entered an irrigation ditch, and flowed into an anroyo that feeds the Red River.
Before emergency berms were constructed, an estimated 25 gallons of tailings water entered the River.
Type of Impact/Media Affected: The numerous tailings spills reported in 1990 and 1991 resulted in short term
impacts to surrounding soils. The spill of 139 tons of tailings resulted in a release of tailings decant water
to the Red River that contained 11 times the permitted 500 parts per billion limit for silver.
Regulatory Action/Responses: The mine repaired all ruptures to the tailings pipeline and instituted containment
and cleanup efforts upon discovery of the spills. Cleanup efforts included removing tailings with
front-end loaders, dump trucks, and shovel and wheel barrow. Tailings were deposited in the tailings
pond. No mention of the water fraction of the spilled tailings is made in the initial spill reports or
cleanup/remedial action plans other than to document the extent to which the water flowed (in
conjunction with the tailings).
The US EPA levied a fine of $20,000 in response to the release of 25 gallons of tailings water to the Red
River. The fine was based on the elevated level of silver in the sample taken (11 times the 500 ppb
permitted level).

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References:
Dupree, J. And R. Eveleth. 1993. The Mineral Industry of New Mexico, in Minerals Yearbook Volume II,
Area Reports: Domestic. United States Department of the Interior, Bureau of Mines. Pg. 375.
Shoemaker, D. May 1,1990. Letter to M. Saladen, Surface Water Section, NMEID Re: April 30,1990
Tailings Spill. Molycorp, Inc.
Saladen, M. May 17,1990. Molycorp Inc., Questa Mine Tailings Spill Follow-up Inspection Report.
NMEID.
Shoemaker, D. November 21,1990. Letter to M. Saladen, Surface Water Section, NMEID Re:
November 20,1990 Tailings Spill. Molycorp, Inc.
Shoemaker, D. March 26,1991. Letter to M. Saladen, Surface Water Section, NMEID Re: March 26,
1991 Tailings Spill. Molycorp, Inc.
Shoemaker, D. May 22,1991. Letter to M. Saladen, Surface Water Section, NMEID Re: May 21,1991
Tailings Spill. Molycorp, Inc.
Shoemaker, D. June 3,1991. Letter to M. Saladen, Surface Water Section, NMEID Re: Detailed
Follow-up Letter Regarding the May 21,1991 Tailings Spill. Molycorp, Inc.
Weiss, N.L., Editor. 1985. SME Mineral Processing Handbook, Volume 2: Molybdenum. Society of
Mining Engineers. New York, NY. Pg. 16-4.

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Page 170
Reading Alloys, Inc.:
"Contaminated Storm Water Released to Ground Water"
Waste and Material Management Practicea:
Reading Alloys, Inc. produces ferrous and non-ferrous master alloys using the themite process. The
facility consists of five processing buildings utilizing several processes in the manufacture of master
alloys: initial formulation of raw material; charging of aluminothermic reactors; smelting; cool down and
slag removal; master alloy preparation; and weighing and packaging for shipment. The facility uses
water from an unnamed tributary as non-contact cooling water. The water is pumped from the tributary
to the facility's upper pond (DP101) and is used to cool furnaces prior to being returned to the upper pond
and discharged to Spring Creek. The facility also has two lower ponds which receive some flow from the
unnamed tributary. All sanitary-use water is discharged to a septic tank/drainfield on the facility property.
The facility also produces vanadium oxide that is used for the production of vanadium master
alloys. Petroleum ash is used as the feedstock material in this process. Other materials used in the
production of vanadium oxide include small amounts of nitric acid, ammonia, caustic soda or potash,
potassium nitrate, and sodium sulfide. The facility uses a bunker storage system for storage of
vanadium ash. The .bunker has a leachate collection system which collects run-off and directs it to a
settling basin and then to six steel tanks where it is used as feed water.
The facility's excess storm water run-off which contacts slag in the slag-storage pits near the
meltlines to discharge to a drainfield via storm sewers. The storm water in the drainfield infiltrated
ground water.
Typo of Impact/Media Affected: The discharge of storm water to the subsurface is a violation of the
Pennsylvania Clean Streams Law and Chapters 101 and 97 of the Pennsylvania Department of
Environmental Protection's Rules and Regulations. The storm water contained elevated levels of iron
(143 ifa/l, secondary MCL 0.03 ifo/l), lead (116 ifa/l, action level 0.015 ifo/1), hexavalent chromium
(10 i^g/l), total chromium (50 ifo/l, MCL 0.1 ifo/l), aluminum (585 ifc/l, secondary MCL 0.05-0.2 t^g/l), and
zinc (16 i^g/l, secondary MCL 5 ife/l). The storm water was highly acidic with a pH level of 2.9.
Regulatory ActionJReeponse: The Pennsylvania Department of Environmental Resources (PADER) issued a
Notice of Violation to Reading Alloys on June 25,1990, for the Injection of storm water into the
subsurface. The Notice required the facility operator to adequately remediate the ground water and to
initiate a ground water testing program in the vicinity of the storm water disposal area to identify private
water supply wells affected by the contamination. The Notice also required Reading Alloys to hire a
hydrogeologist to supervise the testing and to submit a work plan describing the scope and methods of a
hydrogeologic study to determine the extent and impact of soil and ground water contamination. The
work plan was required to include a corrective action schedule. The Department of Environmental
Resources also indicated that the storm water must be redirected to surface water and be included as
part of the facility's NPDES permit. Plans to address the storm water have been submitted with the
facility's permit application.
References:
Pennsylvania Department of Environmental Resources. Notice of Violation. June 25,1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. February 1,
1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. June 6,1990.
Reading Alloys, Inc. Preparedness, Prevention and Contingency Plan. September 1988.

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iiiiimarnianMiWTiiM'iaiiiMMii
Page 171

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Page 1721
Reading Alloys, Inc.:
"90,000 to 100,000 Gallons of Process Water
Contaminates Soil"
Waste and Material Management Practices:
Reading Alloys, Inc. produces ferrous and non-ferrous master alloys using the themite process. The
facility consists of five processing buildings utilizing several processes in the manufacture of master
alloys: initial formulation of raw materials; charging of aluminothermic reactors; smelting; cool down and
slag removal; master alloy preparation; and weighing and packaging for shipment. The facility uses
water from an unnamed tributary as non-contact cooling water. The water is pumped from the tributary
to the facility's upper pond (DP101) and is used to cool furnaces prior to being returned to the upper pond
and discharged to Spring Creek. The facility also has two lower ponds which receive some flow from the
unnamed tributary. All sanitary-use water is discharged to a septic tank/drainfield on the facility property.
The facility also produces vanadium oxide that is used for the production of vanadium master
alloys. Petroleum ash is used as the feedstock material in this process. Other materials used in the
production of vanadium oxide include small amounts of nitric acid, ammonia, caustic soda or potash,
potassium nitrate and sodium sulfide. The facility uses a bunker storage system for storage of vanadium
ash. The bunker has a leachate collection system which collects run-off and directs it to a settling basin
and then to six steel tanks where it is used as feed water. Excess storm water run-off contacts slag in
the slag storage pits near the meltlines. This storm water run-off is directed to a drainfield via storm
sewers.
On August 29,1991, leakage from a process tank was detected. It is estimated that
approximately 90,000 to 100,000 gallons of process water was released to the surrounding area. The
leakage was most likely caused by the settling of the process tank, as evidenced by significant soil
settling in the contaminated area following the leakage. Facility representatives report that the settling
process pulled the sections of the tank apart, thus causing the release.
Type of Impact/Media Affecte± Approximately 90,000 to 100,000 gallons of treated bunker leachate were
released to the surrounding areas of the process tank. The released process water contained dissolved
salts, consisting primarily of potassium and sodium. Sampling results taken on September 3,1991, from
the liquor and surrounding soil showed concentrations of barium (0.2-0.5 ppm), cadmium
(0.01-0.05 ppm), calcium (244-2,520 ppm), chloride (480 ppm-liquor only), chromium (0.02-0.20 ppm),
copper (0.02-0.05 ppm), lead (0.005-0.012 ppm), magnesium (45-486 ppm), nickel (0.04-1.52 ppm),
potassium (19.6-13,600 ppm), sodium (1,520-4,000 ppm), vanadium (0.1-18.2 ppm), and zinc
(0.07-0.76 ppm). No downgradient water sources are located within the vicinity of the above-ground
process tanks.
Regulatory Action/Response: As soon as the leak was detected on August 29, 1991, Reading Alloys began
corrective measures and notified the appropriate regulatory agencies. The facility pumped the remaining
water from the leaking tank into another processing tank as well as a million-gallon holding tank. The
facility planned to pressure test, or hydraulically test, the process tanks when full to avoid future leakage.
References:
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. February 1,
1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. June 6,1990.

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Reading Alloys, Inc. Memorandum regarding a leakage of process water from a process tank. September 17, 1991.
Reading Alloys, Inc. Preparedness, Prevention and Contingency Han. September 1988.

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Page 174;
Shenango, Inc. Coke and Iron:
"Multiple Oil Releases Contaminate Soil and Surface Water"
Waste and Material Management Practices:
Shenango Coke and Iron consists of three divisions, the Coke Plant Division, the Blast Furnace Division,
and the Steam and Power Division. Process wastewater and non-contact cooling water are generated in
each of the three divisions. In addition, approximately 7,000 gallons of tar decanter sludge and 10,000
gallons of degreaser sludges, spent solvents, ignitable product residues, and desulfurization wastes are
generated annually. Wastewater, other than non-contact cooling water, is generated in volumes from 19
to 24 million gallons per day and is treated prior to discharge through Outfall 001 into the main channel
of the Ohio River. The desulfurization waste are not generated on a continuous basis; however, these
wastes are stored in a sump capable of holding 6,400 gallons. The desulfurization waste is a liquid and
is periodically pumped from the sump to a tanker truck for off-site shipment. Tar decanter sludge is solid
and nearly insoluble in water. The tar decanter sludge is recycled back into the coking process. The
various sludges and spent solvents are stored in 55-gallon drums in an on-site hazardous waste storage
area to await off-site shipment. The process wastewater generated in the Byproducts Recovery Plant is
treated in a physical/chemical treatment facility, and discharged to the main channel of the Ohio River.
The Steam and Power Division wastewater is discharged from Outfall 002 to the back channel of the
Ohio River. Between 1990 and 1996, Shenango Coke and Iron has had 14 recorded oil releases or spills
to the Ohio River.
Type of ImpactfMedia Affected: The oil releases occurred through a variety of outfalls. All oil releases either
spilled into the Ohio River or onto the ground. Elevated levels of other contaminants were found in the
water with the oil including chloride, chromium, copper, phenols, organic carbon, lead, and zinc.
Information on each occurrence is as follows:
Date of Spill
Amount of Spill
Description of Spill
Cams of Spill
July 31, 1990
Unknown
Oil sheen on river outside
Outfall 003 and on ground
outside of oil/water separator
Unknown
August 16, 1990
Unknown
Oil sheen on river
Unknown
May 2, 1990
20-50 gallons
Oil sheen on river outside
Outfall 001
Unknown
August 30, 1991.
Under 5 gallons
Spotty oil sheen on river
outside Outfall 001; heavier
sheen observed downstream;
Hot oil package boiled over
during startup of unit, some
oil entered drain and was
discharged to Ohio River
June 22, 1992
Unknown
Oil sheen on river outside
Outfall 001; wind blowing
upstream toward West View
Water intake
Process water from coking
operations; leak in riser pipe
at coolers sprayed water/oil
over a large area; entered
discharge system
October 13, 1992
Not noted
Oil on ground near steam
pipe
Leak in steam pipe
April 8, 1993
3-4 feet wide
Light/spotty oil sheen on
riverbank downstream from
Outfall 001
Unknown
December 31, 1993
50 gallons
Wash oil spilled onto ground
which migrated to the river
through a storm sewer; oil
sheen outside Outfall 001
Spill occurred while loading
railcan transfer was left
unattended at which time an
overflow occurred
January 11, 1994
1-1,500 gallons
Wash oil spilled onto ground
and migrated to the river
Spill occurred while loading a
truck; truck pulled away
before transfer was complete

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January 18, 1994
1.5 miles x 1,000 feet
Oil sheen on river; black in
color with heavy rainbow in
places
Unknown
May 4, 1995
10 gallons
Wash oil spilled into river
through Outfall 001
Intercepting sump's (water/oil
separator) oil compartments
overfilled due to operator
error; oil contaminated water
compartment processed
through wastewater
treatment plant; discharged
to river
July 18, 1995
Unknown
Oil sheen on river outside
Outfall 001; heavy oil
accumulation around the
permanently stationed
containment boom near the
shoreline
A valve used to drain water
that accumulates in gas
holder oil was left open;
water and oil drained into
sump and siphoned for
treatment in the wastewater
treatment plant; discharged
to river
August 27, 1995
150-200 feet x 3/4 mile .
Oil sheen on river outside
Outfall 001 and around left
descending bank above
Emsworth Lock & Dam
Unknown
September 25,1996
12x20 feet
Wash oil spill from Outfall
001
Unknown

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Regulatory Action/Response: The Pennsylvania Department of Environmental Resources has conducted
multiple investigations, during which it discovered several oil discharges or releases. U.S.
Environmental Protection Agency, Region III issued three memoranda to Shenango regarding violations
of Section 311(b)(3) of the Federal Water Pollution Control Act on accidental oil releases occurring on
May 2,1991, August 30,1991, and May 4,1995. Shenango was required to complete an incident
questionnaire for each violation. In all cases that noted corrective actions, Shenango attempted to
identify the source, eliminate the release, and contain contamination with a containment boom. In some
cases, the facility installed additional booms or used vacuum trucks.
References:
Bureau of Waste Management. Cover letter and Potential Hazardous Waste Site Preliminary and Assessment. March 27,
1986.
Bureau of Waste Management, Hazardous Sites Cleanup Program. Site Inspection of Shenango lnc„ Coke and Iron
PA# 501.
Pennsylvania Department of Environmental Resources. General Inspection Report (Non-NPDES). August 27,
1995.
Pennsylvania Department of Environmental Resources. Incident Notification. January 18,1994.
Pennsylvania Department of Environmental Resources. Incident Notification. August 27,1995.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. July 31,1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. August 16,1990.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. August 30,1991.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. June 22,1992.
Pennsylvania Department of Environmental Resources. NPDES Compliance Inspection Report. October 13,
1992.
Pennsylvania Department of Environmental Resources. NPDES CompHence Inspection Report. April 8,1993.
Pennsylvania Department of Environmental Resources. NPDES Compliance Ins/action Report. January 11,
1994.
Pennsylvania Department of Environmental Resources. Spill/Pollution Incident Report. June 22,1992.
Pennsylvania Department of Environmental Resources. Telephone Incident Report. January 18,1994.
Pennsylvania Department of Environmental Resources. Telephone Incident Report. September 25,1996.
Pennsylvania Department of Environmental Resources. Telephone Notification Report. December 21,
1993.
Pennsylvania Department of Environmental Resources. Telephone Notification Report. January 11,1994.
Shenango Incorporated. Cover letter and Duestionnaire regarding oil discharge on May 2,1991. May 29,1991.
Shenango Incorporated. Cover letter andQuestionnaire regarding oildischarge on August30,1991. October 9,1991.
Shenango Incorporated. Memorandum regarding accidental release of wash oil on May 4,1995. May 22,1995.

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Shenango Incorporated. Memorandum regarding accidental release of wash oil on May 4,1995. June 12,1995.
Shenango Incorporated. Memorandum regarding discharge of oil on December31,1993. January 11,1994.
Shenango Incorporated. Memorandum regarding light oil discharge on January 11,1994. January 13,1994.
Shenango Incorporated. Memorandum regarding oil sheen of river on April8,1993. January 14, 1994.
Shenango Incorporated. Memorandum regarding oil spill on July 18,1995. August 29,1995.
U.S. Environmental Protection Agency, Region III. Memorandum regarding violation of Section 311(b)(3) of the Federal
Water Pollution Control Act on May 2,1991. May 21,1991.
U.S. Environmental Protection Agency, Region III. Memorandum regarding violation of Section 311(b)(3) of the Federel
Water Pollution Control Act on August30,1991. September 24,1991.
U.S. Environmental Protection Agency, Region III. Memorandum regarding violation ofSection 311(b)(3) of the Federal
Water Pollution Control Act on May4,1995. May 24,1995.

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Zinc Corporation of America Monaca Latex Facility:
"Effluent Limits Exceeded"
Waste and Material Management Practices: Zinc Corporation of America's (ZCA) Monaca Latex Facility is an
electrothermic zinc smelter. The smelter processes zinc-containing concentrates and secondary
materials (recycled zinc scrap) to produce zinc metal slabs, granules and ingots, zinc oxide, zinc dust,
zinc sulfate, and sulfuric acid. A coal power plant is also operated on the site to provide energy for use
in the smelter. The three basic operations at the smelter are roasting, sintering, and smelting. The
manufacture of sulfuric acid and zinc sulfate are integral coproduct operations. The smelting process
begins with the zinc concentrate which is dried in a rotary kiln before going by conveyor belt to the
roaster. The function of the roaster is to oxidize the concentrate to convert the zinc from sulfide to
calcine. The sintering process converts the fine dust-like calcine into a hard, porous material suitable for
the electrothermic furnaces. An electrothermic furnace converts the zinc to zinc metal. Both zinc oxide
and zinc dust are produced from refined zinc vapor, which is generated in the production units. A
wastewater treatment plant serves the smelter and discharges to the Ohio River. Due to the dynamic
operating conditions of the smelter processes, the wastewater treatment plant handles a variety of
influent conditions. The wastewater treatment plant also treats contact rain water from an area of
approximately 60 acres. The wastewater treatment plant has a capacity of 900 gallons per minute
(gpm), however, normal daily flows are in the range of 300 to 600 gpm. The five basic steps in the
treatment plant's operations are flow equalization, precipitation, flocculation, sedimentation, and sand
filtration. Outfall 101 is the sole discharge from the wastewater treatment facility.
ZCA exceeded its effluent limits for copper during three months between November 1991 and
January 1992; and exceeded its effluent limits for zinc during the nine months between January 1992
and March 1993. All exceedances were from Outfall 101 to the Ohio River.
Type of Impact/Media Affected: Copper and zinc exceedances are shown in the table below:
Contaminant
Monitoring Date
Exceedance Level
AvgJMai.
(mgfl)
NPDES Permit Limit
AvgJMax.
(tnfld)
Cu
November 1991
December 1991
January 1992
0.97/1.47
0.62/
0.63/
0.61/1.25
Zn
January 1992
May 1992
July 1992
August 1992
October 1992
December 1992
January 1993
February 1993
March 1993
0.85/1.18
0.51/-
1.5/2.19
0.45/-
0.52/1.23
0.91/1.17
0.96/1.47
0.72/-
0.57/1.36
0.42/1.02
In addition, zinc discharges exceeded the contaminant mass NPDES permit limits during July
1992. The exceedance was 8.4 lb/day average and 13.4 lb/day maximum; the NPDES permits limits are
4.2 lb/day average and 10.2 lb/day maximum. Zinc exceedances were due to process upsets because of
pH problems in a process clarifier. Overflow of the clarifier discharges to the treatment plant. When the
pH of this circuit decreases, the solubility of zinc increases. The reason for the copper exceedances
remains unclear. During early 1991, ZCA experienced unexplained copper elevation in the discharge.
During this exceedance, ZCA requested permission to use a chemical additive called Metclearto treat
the elevated discharge, however, by the time permission was granted the copper elevation ceased.
Upon the reoccurrence of the copper elevations in January 1992, ZCA began conducting tests of the

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effects of Metclear which have proved inconclusive because of the copper elevations sporadic nature.
The facility hired a contractor, Aqua Terra, Inc., to explore alternative options. All exceedances are
violations of Sections 301 and 307 of the Pennsylvania Clean Streams Law.
Replatory Action/Response: The Pennsylvania Department of Environmental Resources issued a Notice of
Violation regarding the copper releases and two of the zinc releases on April 3,1992. In response to the
Notice of Violation, ZCA submitted a letter outlining the releases, their causes, and subsequent
corrective measures. ZCA used a chemical additive, Metclear, to remove the copper at the treatment
plant. The copper releases ceased without further corrective actions. To correct the zinc releases, ZCA
modified the wastewater treatment plant by raising the operating pH of the clarifier from 8.8 to 9.2.
Additional exceedances, however, were noted after implementation of this corrective measure. On July
22,1993, PADER issued a Consent Assessment of Civil Penalty concerning zinc exceedances for the
period of January 1992 to March 1993. The consent assessment required ZCA to pay a penalty of
$17,000 to the Commonwealth of Pennsylvania Clean Water Fund.
References:
Pennsylvania Department of Environmental Resources. Consent Assessment of Civil Penalty. July 22,1993.
Pennsylvania Department of Environmental Resources. Notice of Violation. April 3,1992.
Zinc Corporation of America. Commitment to Performance.
Zinc Corporation of America. Memorandum regarding response to Notice of Violation Dated 3 April 1992. April 21, 1992
Zinc Corporation of America. Unknown tide.

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Page 180
Chemetals, Inc. Manganese Dioxide Plant:
"High Manganese-Content Wastewater Spills
into the Tennessee River"
Waste and Material Management Practices: The plant's process wastewater undergoes lime precipitation to
remove metals and is then pH-adjusted. All storm flow from the industrialized area plus storm flow from
20 wooded and grassland acres surrounding the industrialized area is captured, stored, and treated
on-site with the process wastewater. The remaining non-industrial area (449 acres) storm flow drainage
enters the Tennessee River/Kentucky Reservoir along approximately 1.5 miles of shoreline. Since
receipt of the initial NPDES permit in 1991, the site treated an increased volume of storm flow
(approximately 75,000 gallons per day) through the Chemetals treatment system. The increased volume
of storm flow has affected the treatment operations. The facility is finding it increasingly difficult to
optimize system throughput and to maintain adequate storm surge capacity, while meeting permit
limitations for manganese and total suspended solids (TSS). Modifications, such as adding aeration to
the reaction tanks, have improved the capability of the treatment system to some extent.
According to the site's permit rationale, permit violations occurred in seven months over a
three-year period. The site has a history of violations and near violations that appear to be related to
large rainfall events in which run-off overflows a diversion dam, carrying manganese to the outfall at the
Tennessee River.
On March 10 and 11,1996, a break in a pipe conveying high manganese-content process
wastewater and slurried process residues to the storage basin resulted in discharges of effluent
containing manganese and suspended solids. On March 10,1996, Chemetals violated its NPDES permit
by discharging effluent containing 553.6 pounds of manganese and 411.4 pounds of suspended solids.
The following day, March 11,1995, Chemetals was again in violation of its permit, discharging 120.2
pounds of manganese and 259.0 pounds of suspended solids. The permitted daily maximum quantities
for the site are 14.1 pounds for manganese and 98 pounds for suspended solids.
Type of Impact/Media Affected: The facility operator estimated that approximately 673.9 pounds of soluble
manganese and 670.4 pounds of suspended solids discharged into the Tennessee River during a
five-hour period. At average flow conditions for March, the spill would increase the soluble manganese
concentration in the total river flow by 0.0125 parts per million (ppm) and the soluble solids concentration
by 0.0124 ppm.
The Tennessee River/Kentucky Reservoir stream use classification includes 1) fish and aquatic
life, 2) livestock watering and wildlife, 3) irrigation, 4) recreation, 5) domestic water supply, 6) industrial
water supply, and 7) navigation. The Tennessee River/Kentucky Reservoir supports a commercial
shellfish industry, making toxicity to bottom dwelling organisms a concern.
Regulatory Action/Response: Upon detection of the pipeline break, effluent treatment operations were shut
down. The facility operator indicated that wastewater and storm flow would be contained in existing
surge capacity until repairs and cleanup were completed.
The site used a back hoe to remove the settled process residue and approximately one foot of
wet earth from the bottom of the discharge ditch. The mud was placed in the process residue storage
basin for disposal. The material removed from the discharge ditch was replaced with crushed limestone.
Immediately following the pipeline break, Chemetals indicated to TDEC that it was in the process
of replacing the piping that conveys process wastewater and slurried process residue. The piping system
will be moved to a location that will ensure that any future spills are contained within the plant drainage
system. TDEC responses were not documented in the files reviewed.

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References:
Chemetals. Internal Memorandum from HJ) Robinson to J J. Chapman and CI. Cunningham. March 13, 1996.
Chemetals. Letter from CI. Cunningham to Donald Ey, Tennessee Department of Environment and Conservation. March 14,
1996.
Chemetals. Letter from CI. Cunningham to Thomas £ Roehm, Tennessee Department of Environment end Conservation. August
15, 1996.
State of Tennessee NPDES Permit, Chemetals, Inc. Issued September30,1991.
Tennessee Department of Environment and Conservation. Memorandum from Tom Yates to files. April 7,1992.

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Page 182
Cyprus Foote Mineral Company Butyllithium Plant:
"High Turbidity Wastewater Discharges to Creek"
Waste and Malarial Management Practices: The plant discharges boiler blowdown, washdown water,
non-contact cooling water, drum and filter wash, and storm water run-off to the Indian Creek Embayment
of the Tennessee River via an unnamed channel. Concentrated flocculent from the solvent recovery
process is pumped through a catch basin return line to a wastewater settling pond. The catch basin and
settling pond also receive storm water run-off.
The plant's NPDES permitted discharge exceeded the daily maximum concentration for total
suspended solids (TSS) on September 22,1990. A similar exceedance occurred in September 1989.
The source of the high turbidity wastewater appears to be local clay washing into the catch basin,
compounded by heavy rainfall. Correspondence from April to July, 1990, between Cyprus Foote Mineral
and Tennessee Department of Environment and Conservation (TDEC) indicated that the source of solids
in the site's pond water was of concern.
Type of Impact/Media Affecte± On September 22,1990, wastewater high in TSS discharged to the Indian
Creek Embayment of the Tennessee River.
Regulatory ActionlReitpoiise: The exceedance occurred on a day after a heavy rainfall event. The release
was reported in the monthly Discharge Monitoring Report submitted to TDEC. TDEC issued a Notice of
Violation to Cyprus Foote Mineral. TDEC requested that Foote Mineral provide the Agency with
information detailing proposed corrective measures to bring the discharge into compliance.
The plant changed its method of adding flocculent to the wastewater pond. The plant now dilutes
the flocculent with water, dropping the solids out of suspension more rapidly. The plant also is managing
the pond level to eliminate an immediate discharge following a heavy rainfall event. Cyprus Foote
Mineral provided documentation supporting its belief that the source of suspended solids in the plant's
discharge is not related to plant operations, but is local clay washed into the catch basin. In the month
following the 1990 exceedance, Cyprus Foote Mineral also compacted and spread gravel over a large
area of the plant to minimize clay washing into the catch basin.
References:
Cyprus Foote Mineral. Letter from John B. Emerson to Robert J. McKee, Tennessee Department of Environment and
Conservation. July 6,1990.
Foote Mineral Company. Memorandum from HA Grady to J.B. Einsrson. April 11,1990.
Foots Mineral Company NPDES Discharge Monitoring Report. October 10,1989.
Stateof Tennessee NPDES Permit, Foote Mineral Company. Issued August 31, 1988.
Tennessee Department of Environment and Conservation. Notice of Violation Letter from Sims Crownover to John
Einerson, Foots Mineral Company. November 14, 1989.

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umiuttiaaau
Page 183
DuPont New Johnsonville Titanium Plant:
"Landfill Contaminates Ground Water"
Waste and Material Management Practices: The Front Hollow landfill is an on-site permitted landfill that
receives a mixture of powerhouse ash, coke and ore solids, and non-biological wastewater treatment
sludge. The ground water monitoring system consists of one upgradient and two downgradient wells.
Type of Impact/Media Affected: Ground water had elevated levels of iron (21.5 mg/l) and manganese (0.63)
in 1990 through 1992 annual sampling events. These samples were taken from the old ground water
monitoring system that has since been replaced by wells that more adequately reflect the uppermost
aquifer system. The Tennessee Department of Environment and Conservation (TDEC) notes that iron
and manganese are most likely naturally occurring constituents of the local ground water.
In 1996, the Front Hollow monitoring wells exhibited exceedances for several metals, including
beryllium (14 ppb), chromium (320 ppb), lead (100 ppb), mercury (7.1 ppb), and nickel (120 ppb). Each
of these metals were sampled at levels exceeding Federal drinking water standards. The upgradient well
exhibited measurable levels of these contaminants, but not as high as the levels sampled in the
downgradient wells. Some metals may occur at elevated levels as part of the natural geochemistry of
the local subsurface rocks. The downgradient wells also exhibited elevated levels of chloride (333 ppm).
TDEC notes that some of the elevated constituents, especially chloride, could be attributed to a
sedimentation pond located in close proximity to one of the downgradient wells.
Regolatory Action Response: DuPont indicated to TDEC that it plans to modify the sedimentation pond to
eliminate infiltration into the subsurface through the bottom of the pond. TDEC notes that further
monitoring events and statistical analyses are needed to verify the source of contamination. TDEC
acknowledges that it would be unusual for beryllium and chromium to be present as naturally occurring
constituents at the measured levels.
References:
DuPont. Letter from Scott L. Goodman to Joe H. Walkup, Tennessee Department of Environment and Conservation. January 3,
1992.
DuPont. Letter from Scott L. Goodman to Wayne Harbin, Tennessee Department of Environment and Conservation. January 7,
1993.
DuPont New Johnsonville Plant Ground Water Monitoring Program at Front Hollow and East Hollow Landfills. December, 1994.
Tennessee Department of Environment and Conservation. Internal memorandum fromJl. Fottrellto GlenPugh et. el.
August 7,1996.
Tennessee Department of Environment and Conservation. Letter from Alan Spear to Scott L. Goodman, DuPont.

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" —¦ ¦ —-—	
Page 184
January 21,1993.
Tennessee Department of Environment and Conservation. Trip Report from JL Fottrell to Glen Pugh et. aU TDEC.
August 19,1996.

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Page 185
DuPont New Johnsonville Titanium Plant:
"Low pH Wastewater Discharges to River"
Waste and Material Management Practices: The site discharges process wastewater, finishing non-contact
cooling water, storm water run-off, and RPO non-contact cooling water through a NPDES permitted
outfall to the Tennessee River. The site's sewage treatment plant was taken out of service in April 1995.
On April 27,1995, the caustic valve at the intake to the settling basin opened to provide pH
control. The pH cell did not respond to the changing pH level and allowed the caustic valve to remain
open, which resulted in high pH wastewater in the settling basin. Two and one half hours after the
release, an alarm sounded on the settling basin outlet pH cell, indicating high pH. The operators
manually closed the inlet caustic valve and added sulfuric acid to the settling basin outlet. The addition
of acid continued through the night. The next morning the site operators ceased adding sulfuric acid.
For several hours, the outfall pH appeared to be returning to a normal level, then the "C" pond pH
dropped below 6.0, indicating that the wastewater had an excess of sulfuric acid. The low pH of the "C"
pond caused the pH to reach a low of 4.3.
The facility had a few NPDES permit violations from 1988 to 1993. In each instance, DuPont
submitted an explanation of the cause of the violations and a plan of action to correct the problem.
There was one violation of the toxicity limit, which was caused by introduction of chlorine into the intake
water to control mussels. In general, the Tennessee Department of Environment and Conservation
(TDEC) Water Pollution Control Division believes that Dupont operates its treatment system
satisfactorily.
Type of Impact/Media Affecte± Wastewater with a pH of 4.3 was discharged to the Tennessee River. The
outfall pH dropped below the permitted limit of 6.0 for approximately 4.5 hours. According to site
personnel, there was no environmental damage associated with this release.
Regulatory Action Response: All caustic valves have been reset to alarm at 90 percent output. The agitator
at the settling basin outlet has been modified to ensure better mixing during sulfuric acid addition. The
site is testing the efficacy of using C02 as a replacement for sulfuric acid. TDEC responses were not
documented in the reviewed files.
References:
DuPont. Letter from Scott L. Goodman and JM Edenffeld to DonaldJ. Ey, Tennessee Department of Environment and Conservation.
May 15,1995.
EJ. DuPont Db Nemours end Company, Inc. NPDES Modified Permit. Issued May 31,1995.
EJ. DuPont Da Nemours and Company, Inc. NPDES Permit Issued May 31,1994.
Tennessee Department of Environment and Conservation. Letter from Donald J. Ey to Scott L Goodman, DuPont.
August 1,1994.

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.. —.

Page186
ICI Specialists Phosphorus Plant:
"Sodium Hydrosulfide Spill Causes Second Fish Kill"
Waste and Material Management Practices: Phosphate minerals, found in the form of clay and sand, occur
throughout the central region of Tennessee. Phosphate ore is shipped by truck to the Mt. Pleasant
facility. Hazardous wastes generated from production are stored on-site in a hazardous waste storage
tank and at the solid waste/hazardous waste drum storage area at the east plant. The drum storage area
is comprised of a concrete pad with diking that is sloped to contain spills. Drums are placed on pallets
and stacked. The facility disposes of its hazardous waste off-site and uses deep well injection for its
non-hazardous liquid waste. The facility pretreats acidic wastewater, adjusting the pH level prior to
discharge to the publicly owned treatment works. Water from the south lagoon is discharged to Big
Bigby Creek through a NPDES outfall. The source of the water entering the lagoon Is unclear from the
files available for review.
On October 31,1992, a spill of sodium hydrosulfide occurred during the loading of a railroad
tanker car that had a faulty valve. The spill flowed into a trench system, which flows to the spill
catchment basin before being immediately discharged to the creek. The spill catchment basin is
equipped with a sensor that diverts water or effluent from the outfall to a compartment when the pH of
the outfall is below 6 or above 9. The sensor failed to work properly during this incident. Processing
areas of the plant are within a containment area, which prevents wastes or spills from entering Big Bigby
Creek. This railroad tanker car was loaded outside of the containment area.
Type of Impact/Media Affected: The spill and subsequent discharge of sodium hydrosulfide through the site's
permitted outfall resulted in a fish kill in Big Bigby Creek. This release was the second chemical spill
resulting in a fish kill during a four month period at the plant.

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Regulatory Action Response: The incident was reported by the plant manager to the Water Pollution Control
Division of Tennessee Department of Environment and Conservation (TDEC) on November 3,1992.
TDEC issued a Notice of Non-Compliance asking the facility operator to develop containment provisions
for all areas where chemical transfers occur. The operator was asked by TDEC to submit a written
containment and cleanup plan for future spills.
References:
ICI Specialties. Emergency Response Report. November 3, 1992.
Stauffer Chemical Company, Phosphorus Products Division, Mt. Pleasant, T ennessee. Furnace Plant History.
TDEC received file on April 8,1993.
Tennessee Department of Environment and Conservation. Letter from Joe £. Ho/tend, Jr. to Stanley Streker, ICI
Specialists. December 30,1992.
Tennessee Department of Environment and Conservation, Division of Solid and Hazardous Waste.
Compliance Evaluation Inspection Report Undated.

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Savage Zinc, Inc. Clarksville Plant:
"Heavy Metals-Contaminated Wastewater
Enters Cumberland River"
Waste and Material Management Practices; The basic plant processes include 1) roasting the zinc sulfide
concentrate to produce a zinc oxide, 2) dissolving zinc oxide in sulfuric acid to produce a zinc sulfate
solution, 3) purifying the zinc sulfate solution to remove undesirable constituents, 4) electrowinning zinc
metal from the purified solution, and 5) alloying and casting zinc metal into marketable size ingots. The
site generates lead residue and miscellaneous tailings, reported as characteristically hazardous. This
waste is handled on-site and has a partial exemption, which provides that it does not have to be counted
in determining generator classification. Savage Zinc is a conditionally exempt small quantity generator
of hazardous waste. Small amounts of isopropyl ether and carton tetrachloride waste are generated by
the facility and disposed of off-site.
The site has several permitted NPDES outfalls for treated process and domestic wastewater
(Outfall 001), water treatment plant wastewater (Outfall 002), and steam condensate, non-process
wastewater and storm water run-off (Outfall 003). Outfall 003 discharges storm water that comes in
contact with the manufacturing portion of the plant. Run-off from this area is either discharged into a
tributary of the Cumberland River at Mile 121.1 or pumped to two on-site surface impoundments for
treatment in the metals recovery process. Only when there is a significant rainfall event is the overflow
from this outfall discharged without treatment. The effluent samples collected at Outfall 003 have been
historically high in lead, cadmium, and zinc. If high storm water flows are encountered, the pumps are
turned off.
A zinc-contaminated discharge occurred on July 17,1993. This discharge violated the site's
NPDES permitted daily limit of 15 pounds for zinc. The discharge to the Cumberland River at Mile 122
resulted due to a malfunctioning pH meter in the first reactor tank, part of the metal recovery plant's lime
and precipitation process. The metals recovery process neutralizes and removes metals from a low pH
solution. Efficient precipitation of zinc is pH dependent. While the pH meter in this tank was being
repaired, the pH level in the rest of the metals recovery process began to drop. According to site
personnel, while operations personnel were repairing the malfunctioning pH meter in the first reactor
tank, insufficient attention was paid to the pH level in the second reactor tank. The decrease in pH
resulted in an elevated level of zinc being discharged through Outfall 001 before being diverted to one of
two on-site surface impoundments.
Type of ImpactfMedia Affected: In February 1996, the U.S. Geological Survey (USGS) sampled water quality
in the Cumberland River and forwarded the results to the Tennessee Department of Environment and
Conservation (TDEC). At Mile 124, 2.9 miles downstream from the Savage Zinc outfall, the USGS noted
zinc concentrations at 558 ug/l. No further analysis of this finding was evident in the files reviewed.
The discharge on July 17,1993, resulted in 31.92 pounds of zinc being.discharged from Outfall
001.
Regulatory Action/Response: In a 1994 Compliance Evaluation Inspection, TDEC recommended that
Savage Zinc take additional steps to limit the effluent discharged from Outfall 003 until the high
concentrations of metals were reduced. Specific actions taken by the facility were not available in the
reviewed files.
The facility recalibrated the alarms on the pH meters in its reactor tanks and added the pH
meters to the site's computer monitoring system to allow for a prompt response in the future. In addition
to the changes implemented by Jersey Miniere, TDEC recommended that the company make an effort to
prevent the accumulation of solids in the effluent weir and clarifier treatment unit.

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References:
NPDES Compliance Inspection Report July 21,1994.
State of Tennessee NPDES Permit Savage Zinc, Inc. Issued August 31,1995.
Tennessee Department of Environment and Conservation. Letter from Joe £ Holland, Jr. to David Rice, Savage Zinc.
August 25, 1994.
U.S. Geological Survey. AURAS Raw Data Report for Water Quality, Cumberland River, Mile 124. February 23,1996.

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¦ . 	 				 	 	 	
Page 190]
W.R. Grace & Co.:
"Thorium Discharges to Creek"
Waste and Material Management Practices: The site is permitted to discharge storm water run-off through three
main outfalls (SWA, SWD, and SWE) to the South Chickamauga Creek, approximately 1.2 miles
upstream from its confluence with the Tennessee River. Outfall SWA receives storm water run-off from
the administrative areas of the plant. Outfall SWD receives storm water run-off from an 11-acre lowland
area, which is consistently flooded by the activity of beavers. The northern inundated portion of this area
contains a titanium tailings fill created by a former owner of the site. No contamination from this area
was documented in the reviewed files.
Outfall SWE includes three separate outfalls, E1, E2, and E3. All storm water from the
processing areas of the plant goes to a rare earth settling pond and the "first flush" is sent to the plant's
pretreatment system, then to a publicly owned treatment works. After the first 330,000 gallons have
been routed to the pretreatment system, the rest is discharged through Outfall SWE. Storm water run-off
from the buried titanium tailings areas and past drum disposal sites are also discharged through these
outfalls.
The thorium hydroxide wastewater processes were discontinued in the early 1990s, however, the
thorium holding pond still receives other process wastewater and contaminated storm water for
pretreatment. During an inspection in April 1996, seepage from the ground was noted below the
permitted thorium holding pond. The pond contains thorium hydroxide sludge. Since February 1996, the
seepage has been captured in a ground water collection system and sent to the on-site pretreatment
system.
According to site personnel, three days before the April 1996 compliance evaluation inspection,
the pump had failed, sending the seepage running over the ground with potential discharge through
Outfall SWE. The seepage was white and oily in nature. Site personnel failed to report the spill within
24 hours, as is required by the site's permit. Memoranda from 1995 indicate that prior to February 1996,
the site operator allowed the seepage to mix with storm water and discharge to surface water.
Type of impact/Media Affecta± The extent of contamination has not been fully determined. Sampling data
from Outfall SWE after the April incident were not available in the reviewed files. In 1995, the
Tennessee Department of Environment and Conservation (TDEC) requested information on the material
buried on-site to determine the source of the white precipitate. A map of burial areas provided by W.R.
Grace indicated that a burial site containing thorium exists below the thorium pond and at an elevation
just above the white precipitate seepage. Based on the site inspection, TDEC believes the source of the
white precipitate to be either the unlined thorium holding pond or thorium burial site. The burial sites
were closed before enactment of RCRA regulations. A 1995 memorandum states that the Division of
Radiological Health reported that the discharge downgradient of the thorium pond was contaminated with
thorium. Based on ground water monitoring data from 1992 to 1996, TDEC believes that the thorium
pond is resulting in contamination to ground water. TDEC is concerned that adjacent surface waters and
wetlands may be affected by the thorium pond seepage. There are nearty industrial users of ground
water.
Regulatory Action Response: The April 1996 incident was reported by the site at the time of a compliance
evaluation inspection. TDEC asked W.R. Grace to install the necessary backup or auxiliary systems to
control the overflow should the pump fail in the future. TDEC also recommended some changes to the
site's Storm Water Pollution Prevention Plan, which is currently being revised. The contamination of
ground water at the site is under review by TDEC.
References:

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State of Tennessee NPDESPermit, WJ\. Grace & Co. Issued December 29,1989.
Storm Water Permit Application, WJR. Grace & Co. Prepared by Piedmont Olsen Hensley. February 1992.
Tennessee Department of Environment and Conservation. Letter from TerrenceP. Whalen to Mallory Miller, U.S.
EnvironmentalProtection Agency, Region IV. May 8,1996.
Tennessee Department of Environment and Conservation. Memorandum from April ingle to Water Pollution Control
files. February 15,1995.
Tennessee Department of Environment and Conservation. Memorandum from Terry Whalen to Guy Moose.
December 21,1995.
Tennessee Department of Environment and Conservation, Division of Solid and Hazardous Waste.
Compliance Evaluation Inspection Report 1996.

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Page 192
American Minerals, Inc.:
"Fugitive Dust Is a Likely Source of
Heavy Metal Soil Contamination"
Wasto and Material Management Practices; This facility grinds minerals to cut them into smaller sizes prior to
packaging them for shipment throughout the United States. Because the facility does not use water
during the grinding operation, the process creates fugitive dust. No information was available in the
State files reviewed in Austin that described the history of the site.
The soil found on a right of way adjacent to this facility's property is contaminated with heavy
metals. In addition, another nearby business, Southwest Industrial Growers (SWIG), which is a cotton
delinter, also has metal contamination of its soil. SWIG is located across the right of way from American
Minerals.
Type of Impact/Media Affecte± Based on informal verbal communications, EPA has learned that samples of
soil taken from SWIG's property failed the metal Toxicity Characteristic Leaching Procedure (TCLP).
There was no information in the State files available for review in Austin that indicated the dates of
sampling or the concentrations of metals in the soil samples. The Texas National Resources
Conservation Commission (TNRCC) staff commented that they consider fugitive dust blown from the
American Minerals site as the likely source of soil contamination on adjacent and nearby properties. At
the time of the file review and conversations with TNRCC staff, the source of the contamination had not
yet been demonstrated.
Regulatory Action/Response: TNRCC's compliance manager indicated that this is an ongoing problem that
has only recently begun to be investigated. Therefore, information on file was limited. One concern is
that contamination of ground water may be a risk. Although the drinking water aquifer begins at
approximately a 400 foot depth, a shallow aquifer that alternately is recharged by the Rio Grande or
flows toward the river, depending on river water levels, is less than 10 feet below ground surface.
References:
American Minerals. Letter from Frank Senkowsky to Mr. Lockay, Texas Water Commission, Re: letter concerning a June20,1986
site inspection. July 14, 1986.
McMillan, Terry, TNRCC Region 6 Compliance Officer. Personal Communication. November 14,1996.

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Texas
Anzon Incorporated:
"Antimony Contaminates Soil and Ground Water"
Waste and Material Management Practices: The Anzon Incorporated facility in Laredo, Texas has been the site
of metals refining operations since the Texas Mining and Smelting Company began operations in 1928.
The property was sold twice in 1947, first to the United States Government, then to National Lead. After
being shut down in 1977, the facility was reopened in 1978 when it was sold to Anzon Incorporated. The
102-acre site is located in an industrial, manufacturing, trucking, and warehouse area of Laredo.
Approximately 28 acres in the southern portion of the property are used for plant operations, with the
remaining 73 acres being undeveloped. Land west and southwest of the property is undeveloped. A
200-foot-wide railroad right-of-way forms the northern boundary of the site. A machine shop servicing
heavy equipment occupies 22 acres along the plant's eastern property boundary. No property adjacent
to the site now serves as residential property, nor is any adjacent property zoned for residential uses in
the future.
The plant used a blast furnace to process antimony-bearing ores to produce antimony oxide until
1992 when the furnace was shut down. Anzon now imports antimony oxide as a feed material to its
refining process. No additional information was available concerning the processes or waste
management practices at the site.
Antimony has been detected in ground water near the plant operations portion of the site.
Concentrations of antimony in the soils of the undeveloped portion of the site are elevated to a level
posing a risk of ground water contamination.
Type of ImpactlMedia Affected: Dissolved antimony concentrations in ground water samples were as high as
2.5 mg/l in the plant operations portion of the site. Concentrations were no higher than 0.005 mg/l in
samples collected from wells in the undeveloped portions of the property. The State's closure criterion
for a contaminant in ground water is adjustable based on the background water quality. Given the
concentration of total dissolved solids in ground water at the site, the calculated Medium Specific
Concentration (MSC) for antimony, which is the allowable maximum concentration of total antimony in
the site's ground water, is 0.6 mg/l. This concentration is well above the observed concentrations in
wells on the undeveloped portions of the site. Thus, unacceptable antimony concentrations in ground
water on the site are limited to the western property boundary area of the active plant. In addition, those
concentrations were observed to attenuate rapidly before reaching the surface water body that is the
hydraulic divide on the site, Manadas Creek.
Antimony concentrations in the soils of the undeveloped portion of the property are more
problematic. Observed concentrations have been as high as 231 mg/kg in samples collected from zero
to two feet below the land surface. Generally, the highest observed concentrations of total antimony in
the near-surface soils of the undeveloped property were adjacent to the plant area and decreased with
distance from the plant operations. The calculated Ground Water Cross-Media Protection Standard
(GWP-Ind) for the site, adjusted based on the background quality of the ground water, is 60 mg/kg in
soils. Thus, soil concentrations of antimony on approximately five acres of the undeveloped portion of
the site present an environmental risk caused by the likelihood of ground water contamination.
Regulatory Action/Response: The State's central files available for review in Austin, the State capital, did not
contain any information on regulatory responses by EPA, the State, or any correspondence delineating
the events that led to the closure studies undertaken by Anzon at this site. Several references were
made to Texas Natural Resource Conservation Commission (TNRCC) designations of constituents of
concern in soils and ground water; however, no copies of TNRCC memoranda or letters were present in

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Page 194
the files. TNRCC's representative (the Enforcement Division Director) declined to provide information in
support of the current effort beyond allowing research of the central files which are available to the
general public. Additional information related to this site may, however, be available in the Regional
Office in Harlingen, Texas.
In November 1991, nine ground water monitoring wells were installed on the active plant site.
Ground water samples were collected and analyzed for nine heavy metals and other water quality
parameters. As a result of the analyses, three metals, antimony, selenium, and zinc, were identified as
constituents of concern. A year later, four more monitoring wells were installed along the northern
perimeter of the property in anticipation of the sale by Anzon of the 200-foot-wide right-of-way. An
additional six wells were installed in May 1993. Based on analysis of samples from these wells, TNRCC
reduced the number of constituents of concern to two: antimony and selenium. Following an
investigation based on samples collected from five more wells installed in 1994, TNRCC again reduced
the constituents of concern in ground water to antimony only.
Based on the analyses conducted by Anzon's contractor, the antimony concentrations detected
in the surface soil and ground water on 68 acres of the 73-acre undeveloped portion of the site do not
exceed TNRCC Risk Reduction Standard 2 (RRS2) closure criteria, (n 1996, Anzon indicated its
intention to close that section of the site. No information was available in State files regarding TNRCC's
approval or rejection of the report submitted to TNRCC by Anzon as a requirement to certify site closure.
That report had been submitted to TNRCC eight months prior to the file search. The remaining five
acres of the undeveloped portion of the site did not meet the RRS2-adjusted leaching protection
standard for antimony.
Anzon's management has stated that it intends to close the remaining five acres of the
undeveloped portion of the site using TNRCC Risk Reduction Standard Number 3. At some unspecified
later date, a closure/remediation analysis will be completed in conjunction with the RRS3 analysis. This
will be completed during the RRS3 analysis for the active portion of the Anzon facility.
Anzon has implemented the following plant improvements to reduce levels of discharges to the
environment:
Upgraded stack emission and industrial hygiene controls;
Ceased all point source discharges;
Constructed a storm water containment and evaporation pond to capture all run-off from
the active plant area;
Connected the discharge of sanitary waste to the city of Laredo, thus closing the on-site
septic system;
Ceased all outside storage of ore and other raw materials;
Recycled all settler boxes and other antimony-bearing residues; and
Recycled most of the inorganic slag by-product north of the plant process area.
References:
Geraghty & Miller, Inc. Baseline Risk Assessment Anzon Incorporated. March, 1996..
Geraghty & Miller, Inc. Environmental Investigation and Risk Assessment Report, Anzon Incorporated, Undeveloped Property.
June 12,1995.

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Texas
ASARCO El Paso Plant:
"Contaminated Ground Water Seeps to a Canal
Supplying Drinking Water"
Waste and Material Management Practices: ASARCO's El Paso Plant is located at the western end of El Paso
County in the Rio Grande Canyon, several hundred feet immediately east of the Rio Grande River.
ASARCO's El Paso Plant is a copper smelter that generates sulfuric acid as a by-product of air
emissions cleaning. The plant has unloading, crushing, bedding, and other related ore handling facilities,
a system of belt conveyors leading to wet storage bins, a fluid bed dryer, cyclone separators with a
product baghouse, dry storage bins, a "ConTop"-based reactor system with cyclone smelting, a furnace,
copper converters, two anode furnaces, and an anode casting facility. The gas handling systems include
draft fans, spray chambers, and electrostatic precipitators serving the roasters, furnace and converters,
and two sulfuric acid and associated gas cleaning plants serving the roasters and converters. The slag
produced by the plant is processed and shipped off-site for use as sandblast media and railroad track
ballast.
Copper concentrate from Arizona, Montana, and Chile is the primary feedstock, but recycled
material from other plants also is used. This material includes matte, by-product dust, anode oxide slag,
blister copper, and scrap copper. The feedstock is deposited on a concrete pad next to the bedding plant
and also is stored on the ground near one of the ponds. At the plant's Delumper, copper concentrate
collects on bare ground with no impervious cover.
No information was available in State files concerning the history and operation dates of this
facility. The site is roughly one mile long, 1,800 feet wide, and relatively flat due to landfilling with slag
and gravelly soil. Depth to ground water was not described in the files available. Fill material in several
arroyos on the site reaches a thickness of up to 55 feet. In addition, three ponds were constructed in two
of the arroyos.
The American Canal, which originates near the facility, also is nearby. The canal distributes
water diverted from the river to downstream users, including El Paso Water Utilities, via a system of
canals and ditches. For approximately 1,100 feet, the canal is adjacent to ASARCO's main plant.
Downstream from the ASARCO plant the canal is referred to as the Franklin Canal. El Paso's public
drinking water is withdrawn from the Franklin Canal for treatment prior to distribution. The withdrawal
point from the canal is approximately two miles from the dam on the river that diverts water into the
canal. On December 4,1995, the Texas Natural Resources Conservation Commission (TNRCC)
conducted a case development inspection of the American Canal in the immediate vicinity of ASARCO's
El Paso Plant. TNRCC collected ground water and sediment samples from three points in the canal, in
which arsenic concentrations in ground water seeping into the canal from ASARCO property were 37
mg/l, which is above drinking water standards - sediment in the canal had arsenic concentrations of 13
parts per million (ppm).
Type of ImpactlMedia Affected: TNRCC personnel have concluded that the American Canal was affected by
arsenic contamination from ground water seeping into the canal. Although not fully documented,
TNRCC personnel theorized that the arsenic in the ground water can be reasonably concluded to have
originated from unauthorized discharges at the ASARCO plant. TNRCC staff also concluded that a
concentration of arsenic of 1.3 ppm shows that the contamination migrated under the canal and is a
direct threat to the Rio Grande River. Although TNRCC personnel indicated in January 1996 internal

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correspondence that additional sampling of river bank soil, river sediment, and river water would be
conducted in the near future, no information was present in the files to indicate that such sampling had
been undertaken.
Regulatory Action Response: From mid-1994 through 1995, TNRCC's Industrial and Hazardous Waste (IHW)
Enforcement section evaluated eight possible violations. On August 25,1994, the IHW enforcement
screening committee directed that a petition be prepared as a formal enforcement action against the
plant. This was done after TNRCC's Legal Services Division concluded that the dumping of copper
smelting slag or lead smelting slag was the only violation at the facility that was excluded under the
Bevill amendment. Several meetings with ASARCO and TNRCC personnel occurred during 1995. No
information was present in the files to indicate that any
enforcement action had been taken against ASARCO or whether the concerns about the contaminated
water and sediment had been resolved.
References:
Texas Natural Resource Conservation Commission.	Interoffice Memorandum to files, fromAyala, K, He: A Compliance
Evaluation Inspection. December 14,1995.
Texas Natural Resource Conservation Commission.	Interoffice Memorandum to files, fromAyala, K He: A Compliance
Evaluation Inspection. August 15, 1996.
Texas Natural Resource Conservation Commission.	Interoffice Memorandum to Vickery, fromAyala, K, Re: A case
development inspection. January 9, 1996.
Texas Natural Resource Conservation Commission.	Interoffice Memorandum to Vickery, fromAyala, IC Re: A
sampling inspection. August 15,1996.

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ASARCO El Paso Plant:
"Improper Management of Hazardous Waste Results
in Soil Contamination"
Waste and Material Management Practices: ASARCO's El Paso Plant is located at the west end of El Paso
County in the Rio Grande Canyon, immediately east of the river. The site is roughly one mile long and
1,800 feet wide. Several arroyos on the site were filled with slag and gravelly soil to create a relatively
level surface. Three ponds were constructed in two of the arroyos. Although the thickness of the fill on
the site generally varies from five to ten feet, the fill in the arroyos is up to 55 feet thick.
The plant's copper circuit consists of the unloading, crushing, bedding, and related ore handling
facilities, a system of belt conveyors leading to wet storage bins and a fluid bed dryer, cyclone separators
with a product baghouse, dry storage bins, a "ConTop"-based reactor system with cyclone smelting, a
furnace, copper converters, two anode furnaces, and an anode casting facility. The gas handling
systems include draft fans, spray chambers and electrostatic precipitators serving the roasters, furnace
and converters, and two sulfuric acid and associated gas cleaning plants serving the roasters and
converters. Copper concentrate is the primary feedstock, but recycled material from other plants also is
used. This material includes matte, by-product dust, anode oxide slag, blister copper, and scrap copper.
The feedstock is deposited on a concrete pad next to the bedding plant and is also stored on the ground
near one of the ponds. No information was available concerning the history and operation dates of this
facility.
Type of Impact/Media Affecte± Prior to June 1993, a contractor used an abrasive blast media for an
ASARCO facility project. Once the project was completed, the contractor left the site without removing
all waste material. During a June 1993 U.S. EPA inspection, the waste material was sampled and
determined to be a hazardous waste. Following extent of contamination tests for TCLP lead and total
lead, it was determined that the wastes contaminated approximately 946 tons of soil on-site.
Regulatory Action Response: EPA issued a Notice of Violation for improperly managing a hazardous waste.
After formal enforcement proceedings, ASARCO was assessed an administrative penalty of $80,000.
ASARCO proposed a closure plan to remove the residue and the underlying soil and to transport
the material to an authorized hazardous waste facility. TNRCC approved the proposed plan, stipulating
that soil samples to verify the extent of contamination be taken at a depth of at least six inches, and that
an independent laboratory be used to analyze the samples for both TCLP lead and total lead. Between
May 13 and May 22,1996, ASARCO removed a total of 946 tons of material and transported it to
USPCI's Lone Mountain facility for disposal. The available files contained no additional information on
concentrations of constituents or removal costs.
References:
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala, V. to files, He: A Compliance
Evaluation Inspection. August 15, 1996.

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ASARCO El Paso Plant:
"Spills and Improper Waste Management Results
in Heavy Metals Soil Contamination"
Waste and Material Management Practicaa: ASARCO's El Paso Plant is located at the western end of El Paso
County in the Rio Grande Canyon, just east of the Rio Grande River. The site is roughly one mile long
by 1,800 feet wide, and relatively flat due to landfilling with slag. This site has been actively used for
mineral processing for more than 100 years. In 1887, a smelter was constructed on 1,156 acres to
process lead ores from mines in Mexico and the American Southwest. In 1899, the smelter was
incorporated in the newly organized American Smelting and Refining Company, which became ASARCO
in 1975. Zinc operations were closed in 1982, and lead smelting ceased in 1985. An antimony plant on
the site was closed in 1986.
ASARCO's current plant is a copper smelter that generates sulfuric acid as a by-product of air
emissions cleaning. The plant has unloading, crushing, bedding, and related ore handling facilities, a
system of belt conveyors leading to wet storage bins, a fluid bed dryer, cyclone separators with a product
baghouse, dry storage bins, a "ConTopB-based reactor system with cyclone smelting, a furnace, copper
converters, two anode furnaces, and an anode casting facility. The gas handling systems include draft
fans, spray chambers and electrostatic precipitators serving the roasters, furnace and converters, and
two sulfuric acid and associated gas cleaning plants serving the roasters and converters.
Copper concentrate from Arizona, Montana, and Chile is the primary feedstock, but recycled
material from other plants also is used. This material includes matte, by-product dust, anode oxide slag,
blister copper, and scrap copper. The feedstock is deposited on a concrete pad next to the bedding
plant, and also is stored on the ground near one of the ponds.
Waste slag has been deposited in various dumps on-site and includes smelting slag from zinc,
lead, and copper processes. Many of the plant's present structures are built on old waste slag deposits.
In 1970, the City of El Paso filed a suit charging violations of the Clean Air Act. Lead was
discovered in the soil of an adjacent neighborhood and all residents were relocated.
Over a two week period in May and June of 1994, the Texas National Resource Conservation
Commission's (TNRCC) Region 6 Field Operations Division conducted a detailed multi-media inspection
of ASARCO's El Paso Plant. Numerous samples showed that various processes at the plant were being
managed without regard for protecting the environment from releases of heavy metals. During the
inspection, unauthorized discharges to soil from spills, fugitive dust, breaches in berms, and cracked
monitoring well pads were observed.
Type of ImpactfMedia Affected: Following the TNRCC inspection, ASARCO collected samples from several
of the process sites that failed the Toxicity Characteristic Leaching Procedure (TCLP) tests for cadmium
and lead, including the following:
• Spilled copper concentrate from rail gondolas east of the receiving facility (samples of
soil beneath the spilled concentrate failed the TCLP test for cadmium and lead);
Dust on uncovered ground at the base of the Delumper Unit (samples of dust on the
ground at the base of the unit failed the TCLP test for cadmium and lead);
Wastewater from the treatment plant from Pond No. 1 that is spread and sprayed on
roads and dirt piles (samples of the wastewater and pond water both failed the TCLP test
for cadmium);

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Material from the berm behind the maintenance building west of the lead plant (samples
of soil at the fence line failed the TCLP test for cadmium and lead);
Material from the berm north of the rubber pond at the south portion of the facility
(samples of soil at a breach failed the TCLP test for cadmium and lead); and
Spillage to the ground from wastes stored in a roll-off container at the acid plant
(samples of soil failed the TCLP test for cadmium and lead).
Regulatory Action/Response: As a result of the inspection, TNRCC Region 6 requested that immediate action
be taken to address the releases of hazardous wastes identified. From mid-1994 through 1995,
TNRCC's Industrial and Hazardous Waste (IHW) enforcement section evaluated eight possible violations
at this site. ASARCO claimed that the copper concentrate and other materials with high metal content
were excluded from RCRA by the Bevill Amendment. On August 25,1994, the IHW enforcement
screening committee directed that a petition be prepared to initiate formal enforcement action against the
plant. This direction came after TNRCC's Legal Services Division concluded that the dumping of copper
smelting slag or lead smelting slag was the only violation cited at the facility that was excluded under the
Bevill Amendment. Several meetings with ASARCO and TNRCC staff occurred during 1995. There was
no information present in the files to indicate that any formal enforcement action had been taken against
ASARCO or whether the concerns about the handling of materials at the plant had been resolved.
TNRCC's representative (the Enforcement Division Director) declined to provide information or other
support to develop this case, beyond allowing research of the central files that are available to the
general public. In addition, the director refused to allow TNRCC enforcement staff to be contacted for
questions on behalf of U.S. EPA. Additional information related to this site might be available in the
Regional Office in El Paso, Texas.
References:
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala, V. to Bredehoeft, Re: A
Mufti-Media Inspection. July 29, 1994.
Texas Natural Resource Conservation Commission. Interoffice Memorandum from Ayala, V. to files. Re: A Compliance
Evaluation Inspection. December 14,1995.

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Texas
Dal-Tile/Dal-Minerals:
"Lead-Contaminated Sludge Dumped
at Seven Texas Sites Contaminates Soils"
Warte and Material Management Practices: This site is a mine that supplies talc to the Dai-Tile tile
manufacturing plant in Dallas. The mine is located approximately ten miles west of Van Horn and three
miles northeast of Allamore. Talc mining and cattle ranching are the principal businesses in the region.
The land at the site is locally owned, but Dai-Tile leases mineral rights on the land and operates the site
for product removal. The site is not permitted or otherwise authorized to accept hazardous and industrial
wastes.
At its tile manufacturing facility in Dallas, Dai-Tile generates substantial quantities of dewatered
sludge. The sludge is characteristically hazardous due to leachable concentrations of lead. Dai-Tile
packaged the waste in an unspecified number of polypropylene bags prior to shipping them. Dai-Tile
dumped each shipment into an unlined trench at the mine and then covered the bags with 60 to 80 feet
of soil overburden. Dai-Tile also disposed of this same type of waste at a gravel pit and a landfill in
Dallas County.
Type of Impact/Media Affected: Sampling by the State showed that the dewatered sludge had a leachable
lead concentration of 220 mg/l, which is 44 times the regulatory level of 5 mg/l. Dai-Tile made three
shipments of the sludge to this mine in October 1987, with the total volume of waste sludge disposed of
at the mine exceeding 1,700 cubic yards.
Regulatory Action/Response: Upon the discovery and subsequent investigation of the gravel pit and landfill
sites by the State, Texas issued an Enforcement Order against the Dai-Tile Corporation in March 1991.
Texas assessed administrative penalties of $650,000, with the deferral of $300,000 pending satisfactory
completion of technical requirements of the Order. A number of technical investigations and reports,
including site assessment and closure activities, also were required by the Order. However, at the time
the Order was issued, neither EPA nor the State of Texas was aware of the disposal activities conducted
at the site. The Order was not available at the time the files were reviewed.
Several months after the Order was issued, in August 1991, Dai-Tile notified Texas that the
company also had disposed of sludge at the mine. The State named the west Texas mine as one of
seven unauthorized disposal sites for the hazardous wastewater treatment sludge that was generated at
the Dai-Tile tile manufacturing facility in Dallas.
Closure work began at the site in May 1992 with the excavation of the bagged sludge. Most of
the bags were reported by the contractor as being intact at the time of excavation. Recovered bags of
sludge that were intact were shipped to one of Dal-Tile's Texas plants for recycling. Recovered sludge
mixed with soil and debris was shipped to the Dallas plant for recycling in the tile manufacturing process.
Lead-contaminated soil surrounding the waste bags, which was reportedly non-hazardous, was shipped
to a landfill in New Mexico.
Final confirmation testing of the excavation and closure verification was performed by State
inspectors in December 1992. In February 1993, Dal-Tile's contractor submitted a closure report to the
State's compliance office. In October 1993, State compliance inspection staff visited the site to verify
the closure activities stated in the report submitted by Dal-Minerals. At that time, no evidence of
additional waste was found and the site was determined to have undergone complete clean closure. A
recommendation was made that the site be removed from the RCRA inspections list. No information

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was present in the files to provide any information on further enforcement actions by the State or EPA.
References:
Texas Water Commission. Interoffice Memorandum from McMillan, T. toRozacky, Wv fie: A Compliance Evaluation Inspection
conducted on October28,1993. November 19, 1993.
T exas Water Commission. Interoffice Memorandum from Vilas, J. to Industrial and Hazardous Waste Screening Committee, Re:
A Record Review. December 7,1992.

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